Privacy Policy
Last updated: July 18th, 2023
We at CIH understand that your personal information is important to you. Commodity & Ingredient Hedging, LLC and its affiliated companies (“CIH,” “we,” or “us”), takes your privacy seriously. Please read the following to learn more about our privacy practices. By visiting our website and using our apps, you agree to our collection and use of personal information as described in this Privacy Policy and in our Terms of Use.
I. Introduction and Scope
This Privacy Policy covers our treatment of personal information we collect from and about you online through our website located at https://www.cihedging.com (including any subdomains) or apps (the “Site”) or offline.
The term “personal information” as used herein is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include de-identified or aggregate information, or public information lawfully available from governmental records.
This Privacy Policy does not apply to the practices of third parties that we do not own or control, or information we collect about employees, job applicants, and independent contractors.
II. Notice at Collection: Personal Information We Collect
We may collect personal information such as:
- Personal identifiers, including your name, physical address, billing address, email address, phone numbers, cookie information, password, IP address, FCM account number, or other unique identifiers.
- Commercial information, including records of services purchased, and payment information.
- Internet or other electronic network activity, including your browsing history, device and browser type, information about how you interact with the Site including the pages you visit and the number of times a page has been viewed, and information regarding any strategy or other simulation exercises in which you engage on the Site.
- Professional or employment-related information, including your regulatory licenses and registration information, if any, the name and contact information of your employer, and your job title.
We have collected the same categories of personal information in the 12 months preceding the date of this Privacy Policy.
III. Notices at Collection: Purposes for Collection of Personal Information
We use your personal information in the following ways:
Additionally, we use personal information, including about your use of our Site; to prevent fraud, activities that violate our Terms of Service, or that are illegal; and to protect our rights and the rights and safety of our users or others.
IV. Notices at Collection: Retention Periods
We retain the categories of personal information we collect for the length of time necessary to provide our services and to comply with legal obligations or to protect our legal rights.
V. Sources From Which We Collect Personal Information
In the 12 months preceding the date of this Privacy Policy, we may have collected your personal information when you visited our Site; when you registered for an account with us; when you contacted us for information about our services; when you engaged in any strategy or other simulation exercises or purchased services from us; when you registered for our seminars or other educational offerings; when you applied for CPE credits; when you subscribed to any of our publications; when you referred people to us and participated in our referral reward program; when you voluntarily provided information to us. We will continue to collect personal information from the same sources.
VI. Disclosure of Personal Information For Business Purposes in the Past 12 Months
The following chart describes the categories of personal information that we disclosed to third parties for a business purpose in the 12 months prior to the date of this Privacy Policy:
| Categories of Consumers’ Personal Information | Categories of Third Parties With Which We Shared Personal Information for a Business Purpose |
|---|---|
| Personal identifiers, including your name, physical address, billing address, email address, phone numbers, cookie information, password, IP address, FCM account number, or other unique identifiers. | Service providers that provide customer relationship management (CRM) services; assist us in operating, analyzing, and displaying content on our website; provide analytics information; provide website hosting. |
| Commercial information, including records of services purchased, and payment information. | Service providers that provide customer relationship management (CRM) services; assist us in operating, analyzing, and displaying content on our website; provide analytics information; provide website hosting. |
| Internet or other electronic network activity, including your browsing history, device and browser type, information about how you interact with the Site including the pages you visit and the number of times a page has been viewed, and information regarding any strategy or other simulation exercises in which you engage on the Site. | Service providers that provide customer relationship management (CRM) services; assist us in operating, analyzing, and displaying content on our website; provide analytics information; provide website hosting. |
| Professional or employment-related information, including your regulatory licenses and registration information, if any, the name and contact information of your employer, and your job title. | Service providers that provide customer relationship management (CRM) services; assist us in operating, analyzing, and displaying content on our website; provide analytics information; provide website hosting. |
Business Purposes for Such Disclosures
We disclosed the aforementioned categories of personal information to the categories of third parties identified above for the following purposes: to manage customer, supplier and vendor accounts and relationships; process payments; verify customers’ identities; fulfill orders and transactions; operate our IT systems and secure our systems; prevent fraud and other illegal activities; and to obtain professional advice, including about legal and accounting matters.
Additional Information About How We May Share Personal Information
We may also share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share your personal information with third parties to help detect and protect against fraud or data security vulnerabilities. And we may share or transfer your personal information to a third party in the event of an actual or proposed sale, merger, reorganization of our entity or other restructuring.
VII. Personal Information We Sold to Third Parties in the Preceding 12 Months
In the 12 months prior to the date of this Privacy Policy, we sold personal information to third party service providers by allowing such third parties to place cookies or other trackers on our Site. The data they collected may be used to provide you with personalized content. For more information about the use of cookies and trackers, see the Cookies and Other Tracking Technologies section below.
VIII. Our Use of Cookies and Analytics
Like most websites, our Site use small data files stored on your computer or mobile device called cookies. Cookies consist of two different types; session and persistent. Session cookies enable us to recognize your actions during the browsing session. Persistent cookies remain stored on your device after you close your browser until they expire or when you delete them.
Cookies and web beacons, typically a one-pixel image, used to pass information from your computer or mobile device to our Site, enable us to provide you with great customer service, improvements to our website design, product assortments, and special promotions by:
- remembering you when you return to visit the Site;
- identifying the pages you click on during your visit to the Site;
- the name of the website you visited immediately before clicking onto our Site; and
- helping track whether our communications are reaching you, measuring their effectiveness and allowing us to better design future communications.
We use this information to improve our Site, product assortments, customer service, and special promotions. Certain of these cookies are strictly necessary to the access and operation of the Site and other cookies used are non-essential to the access and operation of the Site.
We may contract with third parties who may use cookies and web beacons and collect information on our behalf or provide services such as credit card processing, data management, or website troubleshooting and analytics.
We use Google Analytics to evaluate the use of our Site. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a website, what pages they visit when they do so, and what other websites they visited prior to visiting a website. To learn more about how Google Analytics collects personal information, review Google’s Privacy Policy.
The “help” portion of the toolbar on the majority of browsers will direct you on how to prevent your browser from accepting new cookies, how to command the browser to tell you when you receive a new cookie, or how to fully disable cookies. If you disable all cookies, you may not be able to take advantage of all of the features we offer.
IX. Is information about me secure?
Your CIH account information is protected by a password for your privacy and security. It is your responsibility to protect your password against unauthorized access.
We implement and maintain reasonable security appropriate to the nature of the personal information that we collect, use, retain, transfer, or otherwise process. We take measures to safeguard your personal information, although such safeguards may not always be adequate to prevent all breaches of security.
X. What choices do I have?
As stated previously, you can always opt not to disclose information, although you may be unable to use certain features on our website.
You are able to add or update certain information on certain pages of the Site. When you update information, however, we may maintain a copy of the unrevised information in our records for our business purposes.
You may request deletion of your CIH account by emailing us.
The “help” portion of the toolbar on the majority of browsers will direct you on how to prevent your browser from accepting new cookies, how to command the browser to tell you when you receive a new cookie, or how to fully disable cookies. Please note, however, that if your browser does not accept cookies, you will not be able to take advantage of some of the features we offer.
XI. California privacy rights
If you are a California resident, you may have additional rights regarding your personal information under California law.
Shine the Light. California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California residents asking about the business’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. We do not disclose personal information to such entities for such purposes.
California Consumer Privacy Act. The California Consumer Privacy Act (the “CCPA”) grants California residents certain rights with respect to their personal information including, as described below, the right to know about, delete, and if applicable, opt-out of, the sale of their personal information. These rights are subject to certain limitations, however, such as that they do not all apply to personal information about employees, applicants, and contractors, or information processed exclusively in the business-to-business context (e.g., information about an individual acting in his or her capacity as a representative of an entity). Where exceptions to the CCPA apply to a request you submit, we will provide you with an explanation.
Right to request disclosure of information we collect or share about you. You can submit a request to us for the following data regarding the personal information we have collected about you in the 12 months prior to our receipt of your request (a “request to know”):
- The categories of personal information we have collected.
- The categories of sources from which we collected the personal information.
- The business or commercial purposes for which we collected the personal information.
- The categories of third parties to whom the personal information was sold or disclosed for a business purpose.
- The specific pieces of personal information we collected about you.
Right to request the deletion of personal information we have collected from you. Upon request, we will delete the personal information we have collected about you, except for situations where specific information is necessary for us to provide you with a service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law.
The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us.
Your Right to Request to Correct Personal Information We Hold About You. You have the right to request that we correct personal information we hold that you believe is not accurate. We will take steps to determine the accuracy of the personal information that is the subject of your request to correct, and in doing so will consider the totality of the circumstances relating to the personal information you have identified as being incorrect. We may ask that you provide documentation regarding your request to correct in order to assist us in evaluating the request.
Our Commitment to Honoring Your Rights. If you exercise any of the rights explained in this Privacy Policy, we will continue to treat you fairly. If you exercise your rights under this Privacy Policy, you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than others.
Exercising Your Rights and How We Will Respond. To exercise your rights to know, delete or correct your personal information, or to ask a question, contact us at mail@cihedging.com or call 1.866.299.9333. For such requests, we will first acknowledge receipt of your request within 10 business days of receipt of your request. We will then provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request in certain jurisdictions or under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.
We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to provide you with an explanation as to why.
Verification of Identity – Requests to Know, Delete or Correct. When you make a request to know or delete your personal information, we will take steps to verify your identity. These steps may include asking you for personal information, such as your name, address, or other information we maintain about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.
Authorized Agents
You may designate an agent to submit requests on your behalf. The agent can be a natural person or a business entity.
If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our verification process:
- Requests to Know, Delete or Correct Personal Information: If the agent submits a request, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
XII. Do Not Track
“Do Not Track” signals are options available on your browser to tell operators of websites that you do not wish to have your online activity tracked. We do not engage in the collection of personally identifiable information about your online activities over time and across third-party websites or online services, nor do we allow other parties to do so through our Site. Accordingly, we do not process or comply with automated browser signals regarding tracking mechanisms, which may include “do not track” instructions.
XIII. Minors’ information
Our Site is not directed to minors under the age of 16 and we do not intentionally collect personal information from minors. We do not knowingly sell personal information of minors under age 16.
XIV. Links to other websites
Our Site may contain links to other websites. We are not responsible for the privacy practices or the content of other websites. This Privacy Policy applies only to the information collected by us.
XV. Changes to this privacy policy
We may amend this Privacy Policy from time to time, at our sole discretion.
XVI. Conditions of use
If you decide to visit our Site, your visit and any possible dispute over privacy is subject to this Privacy Policy and our Terms of Use, including limitations on damages, arbitration of disputes, and application of California state law.
XVII. Accessibility
We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at 1.866.299.9333 or mail@cihedging.com.
XVIII. Questions and Contact Information
If you have any questions regarding this Privacy Policy, or if you would like to request changes to any of your personal information, you can always contact us for more information at 1.866.299.9333, or by mail at 120 S. La Salle St, Suite 2200, Chicago, IL 60603.