Privacy Policy

This privacy policy (“policy”) is intended to inform you of our policies and practices regarding how CMS collects, uses and discloses information you submit.

BY ACCESSING OR BROWSING OUR WEBSITE OR BY REGISTERING WITH US, YOU CONSENT TO THE COLLECTION AND USE OF YOUR INFORMATION, INCLUDING PERSONAL INFORMATION, AS OUTLINED IN THIS POLICY.

Contractor Management Services, LLC (“CMS”) makes certain software, hardware, equipment and other information technology assets, systems and resources (collectively, “System Resources”) available to its customers through an online platform known as ICM Power ® located at the domain https://ictherightway.com/ (“Website”).

CMS collects personal information from you for a variety of reasons, including to deliver products and services you request, to enable your participation in online activities, and to personalize your experience on our Website. This policy, our Terms and Conditions, our End User Agreement, and any other applicable legal agreement between you and CMS, are intended to work together and supplement each other. This policy does not apply to websites and applications owned by (a) end users of our Website, (b) third party service providers, or (c) entities that we do not own or control.

Users are allowed to visit and browse the Website, on condition that they comply with our Terms and Conditions, End User Agreement, any other applicable legal agreement between you and CMS, and this policy; however, in order to access our System Resources, you must be a registered end user in good standing. This Website is not for use by any minors (defined as those who are not at least of majority age, which is age 18 in jurisdictions), and you must not use this Website if you are a minor.

By registering with CMS, you consent to, and voluntarily accept, the terms and conditions of this policy, the Terms and Conditions, the End User Agreement, and any other applicable legal agreement between you and CMS. All personal information provided to CMS is deemed voluntarily disclosed by you. If CMS participates in a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, then your personal information may be transferred to another entity. You acknowledge that such business transition may occur and that disclosure of your personal information in that context is permitted by this policy.

FOR CANADIAN CITIZENS ONLY

You may have the right to withdraw your consent to our use of your personal information under federal Canadian law and/or under the laws of your Province. Upon CMS’ receipt of your notice withdrawing your consent to our use of your personal information, CMS will have the right to immediately terminate your access and use of our Website and all systems and applications available through our Website.

INFORMATION YOU PROVIDE

Accessing Our Website. Like most websites, CMS and our service providers may automatically track, collect and store information such as (a) Internet Protocol (IP) address; (b) Uniform Resource Locators (URL); (c) domain name; (d) type of computer; and (e) type of web browser and location using cookies, web log files, and other code tracking devises from any device you use to access our Website and any pages you visit at our Website. That type of information is helpful for marketing purposes and allows us to examine traffic to the Website, identify any misuse of the Website, and improve the Website to provide you a better experience.

Cookies & Tracking Codes. A cookie is a small data file that is sent to your browser from a web server and stored on your computer, mobile phone or other device. Cookies store information about your use of a particular website or service and are typically used to make our Website easier to use and to make services more convenient and personalized. Cookies allow us, for example, to recognize you as an end user when you return to the Website using the same computer and web browser, and to identify which areas of the Website you visited, so the next time you visit the Website, those pages may be readily accessible. Our service providers may also use cookies to ascertain how many times you access their website and to obtain information to better personalize the content and promotions that you see on our respective websites. Our service providers may use tracking codes, which are different than cookies, to gather information about your use of our Website. You can remove or block cookies using the setting in your browser, but in some cases that may impact your ability to use our Website.

Do Not Track Disclosure. Our Website does 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).

Registration. When you register with CMS, you voluntarily provide us with your first and last names and an email address, and you may create a user name and a password of your choice. In addition, you may be asked to provide other personal information such as your mailing address, date of birth, and social security number, social insurance number or employer identification number. In addition, CMS may collect information in the form of information that you or another person inputs or uploads onto our System Resources.

CMS uses Secure Socket Layer (SSL) line on pages where you enter personal information provided you are using an SSL enabled browser. An SSL line encrypts your information as it travels over the internet. This mode is enabled before any personal information is transmitted from your computer or web-enabled devise provided you are using an SSL enabled browser. If you have any hesitation about providing personal information to us and/or having that information displayed on the Website to authorized end users or otherwise used in any manner permitted in this policy, then you should not register with us.

Transactions & Communications With Us, End Users & Third Parties. CMS may collect and retain: the details of transactions and communications you have with us, other end users, and/or third parties; copies of your agreements, subscriptions and authorizations; the details of payments made to you and those you make to us or third parties; the full content of any emails sent to us including attached files; any feedback submitted to us; and other information you provide. CMS may ask you to submit additional information to authenticate yourself or if we have any concerns about activities on our Website. For example, CMS may ask you to submit government issued photo identification or a copy of a bill to verify your physical address, and CMS may request that you answer additional questions to verify your identity or ownership of the business you are registering.

Feedback. If you provide CMS with feedback, we will collect that information and we may use it for any purpose we choose. Personal information included in your feedback will be treated in accordance with this policy. You agree that any comments and any emails we receive immediately become our property. Nothing in this policy, CMS’ Terms and Conditions, our End User Agreement, or any other agreement(s) with you entitles you to a fee, royalty, commission, compensation or any consideration whatsoever for your feedback or for the content of any communications you submit to us such as ideas, suggestions, recommendations, methods, processes, or the like whether in writing, verbal or otherwise.

PRIVACY SETTINGS

Password. When you register with CMS, you will be asked to create a password associated with your account. The combination of your user name and your password is the key to your account. CMS recommends that you use a combination of letters, numbers and special characters to create your password. You are responsible for all actions taken using your user name and password. You should not disclose your password to anyone. If you decide to share your password or lose control of your password, you may jeopardize the security and confidentiality of your personal information. Moreover, you may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately notify CMS and change your password.

Sharing Information. You may choose to share information by using the technology on CMS’ Website including your personal information with other end users or with third-parties available on our Website.

In addition, if you provide personal information about another person, you should do so only with that person’s consent and failure to do so may violate that person’s privacy or data rights.

USE OF INFORMATION COLLECTED

You agree that CMS may use your personal information to: (a) send you information about our company and services, and promotional materials from us and our affiliates; (b) facilitate a transaction between you and another end user or between you and a third party; (c) provide the services and customer support you request; (d) process your subscription; (e) help resolve disputes; (f) collect fees; (g) troubleshoot problems; (h) detect, prevent, or investigate potentially prohibited or illegal activities and protect the safety, rights, property, and security of CMS and others, (i) enforce this policy, our Terms and Conditions, our End User Agreement, and any other agreement between you and CMS; (j) contact you when necessary; and (k) research, monitor, and analyze use of our Website and services, including creating aggregate and de-identified information.

CMS may share your personal information with service provider(s) and/or a contracting company(ies) with which you contract to the extent permitted under this policy, our Terms and Conditions, our End User Agreement, and/or any other agreement between you and CMS.

DISCLOSURE, CONFIDENTIALITY & SECURITY OF PERSONAL INFORMATION

CMS uses precautions to keep your personal information private and secure and we will not share your personal information with third parties, except: (a) if you authorize us to do so in this policy, in the Terms and Conditions, End User Agreement, or in any other agreement between you and CMS; (b) as set forth in this policy; (c) to cooperate with law enforcement or other government officials with investigations of purported unlawful activities, conform to the edicts of the law, or comply with judicial proceedings and legal process served on us; (d) to protect, enforce and defend our rights and property or the rights and property of our end users; (e) to investigate violations of the law, this policy, the Terms and Conditions, the End User Agreement, any of our copyrights, trademarks or other intellectual property rights, or those of any third party, or misusing our Website, our System Resources, or any related services; (f) to aid our service providers in providing services to us; (g) as part of a business acquisition, merger, sale, or other similar business transaction, including during negotiations or planning of such transaction; (h) to any current or future affiliates or subsidiaries; and/or (i) to unaffiliated third parties, including for their own marketing purposes. Your personal information is stored on servers in the United States, and CMS has taken steps to ensure that those servers are not accessible by unauthorized third parties. Nevertheless, because network security measures are not infallible and because third parties may unlawfully intercept or access transmissions or private communications, we cannot guarantee the security of your information or that it will always remain private. If you access CMS’ Website from a shared computer or a computer in an internet café, certain information about you may be visible to other individuals at the internet café and your user name or email address may be visible to other individuals who use the computer after you.

Please note that CMS may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.

END USER CONSENT

By registering with CMS, you consent to, and voluntarily accept, the terms and conditions of this policy, the Terms and Conditions, and the End User Agreement. You understand that certain information you provide to CMS may reveal, or allow others to identify your gender, nationality, ethnic origin, religion or other aspects of your private life. All personal information provided to CMS including all information deemed “sensitive” by applicable law is voluntarily disclosed by you. If CMS participates in a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, then your personal information may be transferred to the new owner(s). You acknowledge that such business transition may occur and that disclosure of your personal information in that context is permitted by this policy. In the event of a business transition, other than disclosure to the new owner(s), your personal information would continue to be treated in the manner outlined in this policy.

CONFIDENTIALITY & SECURITY OF PERSONAL INFORMATION

CMS agrees to use reasonable precautions to keep your personal information private and secure and we will not share your personal information with third parties, unless: (a) you authorize us to do so in this policy, in the End User Agreement, or in any other agreement between you and CMS; (b) it is reasonably necessary as set forth in this policy; (c) it is necessary in order to cooperate with law enforcement or other government officials with investigations of purported unlawful activities, conform to the edicts of the law, or comply with judicial proceedings and legal process served on us; (d) it is necessary to protect, enforce and defend our rights and property or the rights and property of our end users; and/or (e) it is necessary to identify persons who may be violating the law, this policy, the Terms and Conditions, the End User Agreement, any of our copyrights, trademarks or other intellectual property rights, or those of any third party, or misusing our Website, our System Resources, or any related services.

Your personal information is stored on secure servers in the United States and CMS has taken commercially reasonable steps to ensure that those servers are not accessible by unauthorized third- parties. Nevertheless, because network security measures are not infallible and because third parties may unlawfully intercept or access transmissions or private communications, we cannot guarantee the security of your information or that it will always remain private. If you access CMS’ Website from a shared computer or a computer in an internet café, certain information about you may be visible to other individuals at the internet café and your user name or email address may be visible to other individuals who use the computer after you.

YOUR DISCLOSURE OF INFORMATION TO THIRD PARTIES

CMS cannot guarantee the privacy or security of information you disclose to others therefore, we encourage you to evaluate the privacy and security policies of all websites before entering into a transaction and choosing to share your personal information with them.

Public Communications. Please take precautions in disclosing personal information. Personal information disclosed online via email, blogs and the like can be collected and used by others. If you post personal information in those types of online environments, it is highly likely that it may be accessible to the public and you may receive unsolicited messages and advertisements commonly referred to as SPAM. You are solely responsible for maintaining the secrecy of your personal information.

SPAM. CMS and our end users do not tolerate SPAM. You are not authorized to add an end user of CMS’ Website to your mailing list or other database without that end user’s prior written permission. You are not permitted to use CMS’ Website or any related communication tool to send SPAM or to otherwise send content that may violate this policy, our Terms and Conditions, or our End User Agreement. To report SPAM or spoof emails, please forward the email to customerservice@ictherightway.com.

ABILITY TO ACCESS, UPDATE & CORRECT PERSONAL INFORMATION

In order to ensure that all of your personal information is correct or to update your personal information, you may access CMS’ Website, log into your account, and edit your account.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, then under Cal. Civ. Code § 1798.83 you may request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year.  If you are a California resident and would like to make such a request, please submit your request in writing to us at the contact information provided below. In your request, please attest to the fact that you are a California resident and provide a current California address for your response.

LOST OR STOLEN INFORMATION

You must promptly notify CMS if your user name or password is lost, stolen or used without permission, or you suspect fraudulent activity in your account. In such event, CMS will help you reset your password or assist with suspending or closing the account.

YOU CONSENT TO OUR POLICY

As stated above, by accessing or browsing CMS’ Website or by registering with us, you consent to our collection and use of your information as set forth in this policy.

UPDATES AND CHANGES TO POLICY

CMS reserves the right, at any time and without notice to you, to add to, change, update or modify this policy, simply by positing an updated policy on our Website. We will post any changes, including material changes, to our Website. Any change, update or modification will be effective immediately upon posting on CMS’ Website and will apply to any personal information provided to us on and after that date.