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Online Privacy Policy

Effective Date: May 1, 2022

Origin, Energy and Renewables, Inc. (D/B/A Origin and Cause) is committed to protecting the privacy of the personal information we collect and providing clear information about how we handle personal information. We encourage you to read this Online Privacy Policy carefully so that you understand how we treat your personal information and what rights you may have.

Scope of this policy

This Online Privacy Policy (the “Policy”) applies to Origin and Cause and its affiliate companies as applicable (together, “Origin and Cause”, “we”, “us” or “our”), and explains how we collect, use and disclose personal information about users of our relevant websites, including associated pages and online services, that display this Privacy Policy (the “Sites”). This Policy is intended to disclose the personal information that we collect about users of our Sites, and to explain how we use and disclose this personal information, and the choices and rights individuals have regarding this personal information.

Origin and Cause is the responsible party (e.g., “data controller”) for your personal information collected and processed under this Policy.

Our primary business is to provide affinity and marketing services for our membership.

Information we collect

We may collect personal information directly from you, such as when you request information, contact us online or submit forms through the Sites. We may also collect personal information from third parties and automatically through your use of the Sites. In this Policy, “personal information” means any information that identifies or could be used to identify an individual person and includes other similar terms like personal data or personally identifiable information.

Information collected directly. We collect information that you provide to us or share on the Sites, such as:

  • Registration Information and Requests. Many of our Sites and other information available on our Sites can be accessed without registering. However, we may require you to submit your name and contact information to access certain products or information, such as reports and whitepapers or e-learning content. We may also require registration or the completion of an online form to submit certain inquiries, jobs or other requests. The information that we collect will vary depending upon the context of your request, but will generally include your name, company name, contact details, a description of your request and other relevant information. We will tell you what information is mandatory and what is optional.
  • Communications. When you email us, call us or contact us, we maintain records about our interactions and communications with you.
  • Professionals, Experts, Contractors. We work with external professionals, experts, consultants and others in order to deliver our client services and otherwise make our products and services available. We may collect information through the Sites of these third parties, in order to consider them, review their qualifications or assign specific tasks or jobs to them.

Automatically collected information

We use cookies, log files, pixel tags, local storage objects and other tracking technologies to automatically collect information when users access or use the Sites, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider (“ISP”), referring/exit URLs, operating system, language, clickstream data and other information about the links clicked, features used, size of files uploaded, streamed or deleted and similar device and usage information. This automatically collected information may also include hashed identifiers derived from email addresses for the purposes of cross-device tracking for targeted advertising.

For more information, see the “Cookies and similar devices” section below.

Use of personal informartion

In the course of conducting our business, we use personal information to provide and improve our services, to process employment inquiries, to provide information about our products and services, to respond to requests and to otherwise communicate with you and others.

  • Providing Support and Services: To provide and operate our services and the Sites, communicate with you about your use of the Sites, respond to your inquiries, provide troubleshooting, fulfill your orders and requests, process your payments, and complaints and inquiries, provide technical support and for other customer service and support purposes.
  • Personalization: To tailor content we send or display on the Sites in order to offer location customization and personalized help and instructions and to otherwise personalize your experiences.
  • Marketing and Promotions: For direct marketing and promotional purposes. To send you newsletters, special offers or promotions and contact you about our products or services or information we think may interest you. If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send you such messages if you opt-in to receive them. We do not use the information we collect from third parties in providing the client services or handling specific claims for marketing and promotional purposes.
  • Analytics and Improvement: To better understand how users access and use the Sites and other products and offerings and for other research and analytical purposes, such as to evaluate and improve our services and business operations and to develop additional products, services and features.
  • Protect Our Legal Rights and Prevent Misuse: To protect the Sites and our business operations; to prevent and detect fraud, unauthorized activities and access and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party as well as violations of our Terms of Use or this Privacy Policy.
  • Comply with Legal Obligations: To comply with the law or legal proceedings. For example, we may disclose information in response to subpoenas, court order, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
  • General Business Operations: Where necessary to the administration of our general business, accounting, record keeping and legal functions.
  • Anonymous and De-identified Information: We may de-identify information and create anonymous and aggregated data sets and reports in order to assess, improve and develop our business, products and services, prepare benchmarking reports on our industry and for other research and analytics purposes.
  • Client Services and Claims Handling: As noted, we may collect certain personal information online that is used to provide our client services (including claims handling services), and we use such personal information on behalf of and under the instructions of our clients and subject to our client agreements.

Disclosure of information

We do not sell your personal information to third parties. In general, we disclose the personal information we collect as follows:

  • Service Providers. We may share your information with third-party service providers who use this information to perform services for us, such as payment processors, hosting providers, auditors, advisors, consultants and customer service and support providers.
  • Business Transfers. We may disclose or transfer information, including personal information, as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law.
  • Legally Required. We may disclose your information if we are required to do so by law (e.g., to law enforcement, courts or others, e.g., in response to a subpoena or court order).
  • Protect our Rights. We may disclose information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation and protect the rights, property or safety of Crawford, our clients and customers or others.
  • Anonymized and Aggregated Data. We may share aggregate or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.

Cookies and similar devices

We and our service providers use cookies, pixels, java script and other tracking mechanisms to track information about your use of our Sites, and we may combine this information with other information, including personal information, we collect about you.

Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Sites, while others are used to enable a faster log-in process or to allow us to track your activities while using our Sites. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our Sites to, among other things, track the activities users of our Sites, help us manage content, and compile statistics about usage of our Sites. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Log files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version and internet browser type and version. This information is gathered automatically and stored in log files.

Third-Party Analytics. We also use automated devices and applications, such as Google Analytics (more information here) to evaluate use of our Sites. We use these tools to gather non-personal data about users to help us improve our Sites and user experiences. These analytics providers may use cookies and other technologies to perform their services and may combine the information they collect about you on our Sites with other information they have collected for their own purposes. This Policy does not cover such uses of data by third parties.

Do-Not-Track Signals. Our Sites do not respond to do-not-track signals. For more information about do-not-track signals, please click here. You may, however, disable certain tracking as discussed above (e.g., by disabling cookies).

Direct Marketing

We may send periodic promotional emails to you and where required by law, we will obtain your consent to do so. You may opt-out of such communications by following the opt-out instructions contained in the promotional email. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any services you have requested or received from us.

Security

We have implemented appropriate safeguards and technical measures to protect the personal information that we have under our control from unauthorized access, use or disclosure (such as where appropriate, access controls and encryptions). However, no data security measures can guarantee 100% security.

Retention

As a general rule, we retain your personal information only for as long as necessary to fulfill the purposes for which it was collected or as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, as required by clients and to enforce our agreements. We may retain personal data for longer where required by our regulatory obligations, professional indemnity obligations or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others.

Your choices and rights

We know the importance of accurate data.

Access, Amend and Correct. If you wish to access personal information that you have submitted to us, to request the correction of any inaccurate information you have submitted to us, to request deletion of or object to processing of your information or to request a paper copy of this Privacy Policy, please send you request to

Direct Marketing. You may always opt-out of direct marketing emails from us by following the instructions in such emails or emailing privacynotice@oci-usa.com Origin and Cause may continue to send you transactional or service-related communications, such as service announcements and administrative messages.

Complaints. We will take steps to try to resolve any complaint you raise regarding our treatment of your personal information. You also have the right to raise a complaint with the privacy regulator in your jurisdiction.

Third-party sites

Sites may contain links to third-party websites or services. We are not responsible for the data privacy practices of such third parties, whose practices are subject to their own privacy policies and procedures and not our Privacy Policy.

Information about children

Our Site and the services are not directed towards children and we do not encourage children to participate in providing us with any personal information. We do not knowingly collect any personal information from children under the age of 16.

Changes to this privacy policy

We may update this Privacy Policy from time to time to reflect changes and will post changes by updating the Privacy Policy (and effective date) on this page. If we make any material changes that affect how we treat your personal information, we will endeavor to notify you in advance, such as by prominently posting a notice on this website or by directly sending you a notification. We encourage you to periodically review this website and our Policy to understand how Crawford protects your personal information. Once effective, the revised Policy will apply to you and your personal information.

Contact us

If you have questions or concerns regarding this Policy, please contact us at:

Origin, Energy and Renewables, Inc
Attn: Chief Privacy Officer
5335 Triangle Parkway
Peachtree Corners, GA 30092
privacynotice@oci-usa.com