California Privacy Policy – CCPA

Effective Date: January 1, 2020
Last Updated: December 31, 2019

If you are a California Consumer, you have certain rights with respect to the collection, use, transfer, and processing of your “Personal Information”, as defined by the California Consumer Privacy Act (CCPA). Communications Systems, Inc., Transition Networks, Inc., Net2Edge, Limited, Suttle, Inc., and JDL Technologies, Inc. (“Company”, “us”, “we”, or “our”) reserve the right to limit these rights where permitted under applicable law, including where the personal information we collect concerns our business partners, your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us via the contact information below. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

Collection of Personal Information
When California Consumers access the Company websites, purchase Company products, or contact the Company, we collect the following Personal Information as provided by the person contacting the Company.

  • Contact name
  • Postal address
  • E-mail address
  • Phone number
  • IP address if accessing a company Website and Chat features

Internet or Electronic Network Activity Information

  • Browsing history
  • Search history
  • Information regarding a consumer’s interaction with an Internet Web site, application, or advertisement
  • Internet Protocol address
  • Device ID
  • Cookies
  • Unique Personal Identifier
  • Online Identifier
  • Beacons
  • Pixel Tags
  • Mobile Ad Identifiers

The foregoing pieces of Personal Information have been collected about our consumers in the past 12 months:

Sources from which Personal Information is Collected
• We collect your internet or other electronic network activity information and geolocation information from your interactions with our website.

Business or Commercial Purposes for which Personal Information is Collected
Your Personal Information is used for the following purposes:
• Operate, understand, optimize, develop, or improve our sites, applications, products, services and operations;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Debugging to identify and repair errors that impair existing intended functionality; and
• Investigate and prevent activities that may violate our policies.

Third Parties with whom Personal Information is Shared
Company shares your Personal Information with affiliates, analytics providers, service providers, benefits providers, IT vendors, and law enforcement (if necessary).

In the preceding 12 months, we have not sold Personal Information about consumers.

In the preceding 12 months, we have not sold Personal Information about minors.

In the preceding 12 months, we have disclosed the following Personal Information about consumers for business purposes:

1. Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
a. Internet or other electronic network activity information

2. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
a. Internet or other electronic network activity information

3. Debugging to identify and repair errors that impair existing intended functionality.
a. Internet or other electronic network activity information

4. Short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
a. Internet or other electronic network activity information

5. Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
a. Internet or other electronic network activity information
b. Geolocation Data

Individual Rights
Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that Company disclose the Personal Information it collects, uses, and discloses about you to third parties. There are two types of Right to Know requests you can make:
1. Right to Know (Abbreviated Request): If you make a Right to Know (Abbreviated Request), you will receive the following information about you:
a. Category of personal information collected,
b. Categories of sources from which that information was collected,
c. The business or commercial purpose(s) for which the information was collected,
d. The categories of third parties to whom Company sold or disclosed the category of personal information for a business purpose, and
e. The business or commercial purpose for which Company sold or disclosed the category of personal information.
2. Right to Know (Specific Pieces of Information Request): If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:
a. Specific pieces of Personal Information collected about you.
Company does not sell any Personal Information of California consumers. This information will be provided to you free of charge, unless Company determines that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.

Right of Deletion
You have the right to request that Company and our service providers delete any Personal Information about yourself that Company has collected from you upon receipt of a verifiable request. This right is subject to exceptions.

Submitting Requests
You can submit your request by calling us at 952-996-1674 . You may also submit a request via email at privacy@commsysinc.com

Verifying Requests
Company provides California Consumers with the ability to submit requests through our request website, our telephone number, and our email address. Company must verify that the person requesting information or deletion is the California Consumer about whom the request relates in order to process the request. To verify a California Consumer’s identity, we may request up to up to three pieces of Personal Information about you when you make a request to compare against our records. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request. Company reserves the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe a request is fraudulent.

Authorized Agent
You may choose a person registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, Company requires that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with Company. Failure to do so may result in Company denying your request.

Right to Equal Service
Company will not discriminate against you because you exercised any of your rights, including, but not limited to, by:

  • Denying goods or services to you.
  • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
  • Providing a different level or quality of goods or services to you.
  • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Contact Us
If you have any questions about this Privacy Policy, please contact us:

By e-mail: privacy@commsysinc.com

By telephone: 952-996-1674

By mail:
Communications Systems, Inc.
Attn: Privacy Officer
10900 Red Circle Drive
Minnetonka, MN 55343