Effective Date: March 8, 2019
Last Updated July 12, 2023
Current’s Online Channels may provide links to other third-party websites and features, or contain third-party cookies, which are not owned or controlled by Current. Please review the privacy policies of these third parties to familiarize yourself with their practices. You may also exercise your choices regarding third-party cookies using our Cookie Consent Tool by clicking on “Cookies” at the bottom of the first page of Current’s Online Channels.
Personal Information We Obtain
We may obtain personal information through the Channels. We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
We have collected from our consumers one or more items of personal information from the following categories within the last twelve (12) months:
|Category||Examples||Items Potentially Collected|
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
The types of personal information we may obtain include:
- Contact information (such as name, phone and fax number, email and postal address) for you or for others (e.g., principals in your business);
- Information used to create your online account (such as username, password and security question and answer);
- Biographical and demographic information (such as date of birth, age, gender, job title/position, marital status and dependent, spousal and other family information);
- Purchase and customer service history;
- Financial information (such as payment information, including name, billing address and payment card details (i.e., card number, expiration date and security code); bank account information; financial statements; income; and credit score);
- Location data (such as data derived from your IP address, country and zip code) and the precise geolocation of your mobile device where we have provided notice and choice, as appropriate;
- Contact information you provide about business contacts, friends or other people you would like us to contact;
- Other personal information contained in content you submit to us through the “contact us” link on our Online Channels.
In addition, in connection with any of our systems used to generate purchase orders, invoices, or payments, we may obtain government-issued ID numbers and Tax ID numbers, which may include US Social Security numbers.
Please note that providing personal information to us is voluntary on your part. If you choose not to provide us certain information, we may not be able to offer you certain products and services, and you may not be able to access certain features of the Online Channels.
Cookies and Similar Technologies
Cookies contain small amounts of information which are downloaded to your device when you visit our websites. Generally, Cookies are sent back to our websites to allow us to recognize your device.
Essential Cookies allow us to recognize your device to help you navigate efficiently to obtain the information and services you have requested.
Advertising Cookies may be used in some cases to make advertising messages more relevant to you.
Unless you disable the cookies on our website, by using our website you agree to our use of those cookies.
Making Cookie Choices
You may see the list of Current and selected partner cookies on our website and make choices about those cookies by visiting our Cookie Consent Tool, by clicking on “Cookies” at the bottom of the page for the Current Online Channel you are interested in managing cookie preferences for. In addition to our Cookie Consent Tool, most browsers allow you to manage cookie preferences. If you decide to disable cookies on our site, you may not be able to take full advantage of all our website features once you have done so. Except for cookies that are essential to the operation of this website (Essential Cookies), you may make choices about the cookies on this website. Please note that if you choose to manage cookies on our websites, the Tool will place a cookie on your device to allow your choices to be honored.
To enhance your experience on our websites, we sometimes embed content and sharing tools from other third-party sites, such as “like” buttons from social networking sites; these third-party sites may also place and access cookies on your device. Current does not control the placement or access of these third-party cookies. The third parties can be found in our Cookie Consent Tool. Please review the privacy policies of these third parties to familiarize yourself with their practices. You may exercise choices regarding third party cookies using our Cookie Consent Tool, by clicking on “Cookies” at the bottom of the page for the Current Online Channel on which you are interested in managing cookie preferences.
How We Use Personal Information
We may use, [sell,] or disclose the personal information we obtain to:
- Provide and administer our products and services;
- Process and fulfill orders and keep you informed about the status of your order;
- Communicate about and administer our products, services, events, programs and promotions (such as by sending alerts, promotions, newsletters and other marketing communications);
- Conduct and facilitate surveys, sweepstakes, contests, focus groups and market research initiatives;
- Perform data analytics (such as market research, trend analysis, financial analysis and customer segmentation);
- Engage in ad retargeting and evaluate the effectiveness of our marketing efforts (including through our participation in ad networks);
- Provide customer support;
- Process, evaluate and respond to requests, inquiries and applications;
- Create, administer and communicate with you about your account (including any purchases and payments);
- Administer and register participants in our courses;
- Provide investor services;
- Conduct marketing and sales activities (including generating leads, pursuing marketing prospects, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns and managing our brand);
- Operate, evaluate and improve our business (such as by administering, enhancing and improving our products and services; developing new products, services and Online Channels; managing our communications and customer relationships; and performing accounting, auditing, billing, reconciliation and collection activities);
- Verify your identity and protect against and prevent fraud and other unlawful activity, unauthorized transactions, claims and other liabilities, and manage risk exposure and quality;
- Maintain and enhance the safety and security of our products, services, Online Channels, network services, information resources and employees.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We may combine personal information we obtain through Online Channels with information we obtain through Offline Channels, as well as other information, for the purposes described above. We may anonymize, pseudonymize, or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes that we identify at the time and place of collection. We will obtain your consent for these additional uses to the extent required by applicable law.
Where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes.
The legal basis for Current processing your personal information as described above will typically be one of the following:
- Your consent;
- Performance of a contract with you or a relevant party;
- Our legitimate business interests; or
- Compliance with our legal obligations.
Personal Information Sharing
We do not sell or otherwise disclose personal information about you except as described here or at the time of collection.
- We may share personal information with service providers we have retained to perform services on our behalf (such as payment processing, order fulfillment, customer support and data analytics). These service providers are contractually required to safeguard the information provided to them and are restricted from using or disclosing such information except as necessary to perform services on our behalf or to comply with legal requirements.
- We may disclose personal information about you (1) if we are required or permitted to do so by applicable law or legal process (such as a court order or subpoena), (2) to law enforcement authorities or other government officials to comply with a legitimate legal request, (3) when we believe disclosure is necessary to prevent physical harm or financial loss, (4) to establish, exercise or defend our legal rights, (5) in connection with an investigation of suspected or actual fraud or illegal activity or (6) otherwise with your consent.
- We reserve the right to transfer to relevant third parties any information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) or other business combination. In such case, we will require the relevant third parties to provide comparable levels of protection as Current provides with respect to the information we share.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Current has disclosed the following categories of personal information for a business purpose:
Category A: Identifiers
Category B: California Customer Records personal information categories
Category D: Commercial information
Category F: Internet or other similar network activity
Category G Geolocation data
Category I: Professional or employment-related information
Category K: Inferences drawn from other personal information
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers.
Sales of Personal Information
In the preceding twelve (12) months, Company has sold the following categories of personal information:
Category A: Identifiers
Category B: California Customer Records personal information categories
Category D: Commercial information
Category F: Internet or other similar network activity
Category G: Geolocation data
Category I: Professional or employment-related information
Category K: Inferences drawn from other personal information.
We sell your personal information to the following categories of third parties:
- Ad Exchanges
- Analytics Providers
- Ad Servers
- Demand Side Platforms
- Ad Networks
- Social Media
- Ad Optimizers
You also may exercise choice over how information about your interests is used by ad networks to deliver you relevant advertising. To learn how to opt out of ad network interest-based advertising in the United States, please visit Digital Advertising Alliance or the Network Advertising Initiative. In the European Union, please visit European Interactive Digital Advertising Alliance. In Canada, to consent to receiving electronic communications, please review the CASL language below, and to learn how to opt out of receiving electronic communications, please use the Contact Us button on the Current website. Current’s Online Channels are not designed to respond to “do not track” signals received from web browsers. To exercise California opt out rights, visit the “Do Not Sell My Personal Information” link here.
California Residents: Rights and Choices
The California Consumer Privacy Act of 2018, as amended (“CCPA”) provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- Sales, identifying the personal information categories that each category of recipient purchased; and,
- Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
We do not provide these access and data portability rights for B2B personal information.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We do not provide these deletion rights for B2B personal information
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us toll free at 1-833-328-7669
- Emailing us at [email protected]
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
- First and last name
- Email address
- Order number, if applicable
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
For instructions on exercising sale opt-out rights, click here.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically the information will be in a Microsoft Excel, Power Point, or Word file format and shall reflect the data category, date, information type, and any other item required by applicable law.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following link here.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by clearing your cookies cache on your browser and relogging to our website and electing NOT to opt out.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
How We Protect Personal Information Transmission
We maintain administrative, technical and physical safeguards, consistent with legal requirements where the personal information was obtained, designed to protect against unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the personal information provided to us through the Channels.
Retention of Personal Information
Notice to California Residents
Subject to certain limits under California law, California residents may ask us to provide them with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties. To obtain this information, please send an email to [email protected] with "California Shine the Light Privacy Request" in the subject line and in the body of your message.
Children’s Personal Information
How to Contact Us
Attn: Enterprise Compliance Officer
25825 Science Park Drive
Beachwood, Ohio 44122
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Canada’s Anti-Spam Legislation
CASL became effective on July 1, 2014 and impacts all commercial electronic communications. CASL generally prohibits sending commercial electronic messages - including emails, text messages and some social media - without recipient consent.
To provide your consent to receive commercial electronic messages from Current, please email [email protected]
Candidate Privacy Notice
This notice (Notice) describes how Current and its subsidiaries and related companies (collectively, “Current”) handle and protect data to which Current is provided access in connection with the recruiting process.
By making available your Candidate Data, as defined below, you confirm that:
- You have reviewed this Notice and agree that Current may process your Candidate Data in accordance with this Notice;
- You have provided any notices and obtained any consents needed to provide information concerning others (e.g., information about employment references); and
- Your Candidate Data may be transferred and processed worldwide, including the US and other countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this Notice.
Current will process Candidate Data in accordance with this Notice, unless in conflict with requirements of applicable law, in which case applicable law will prevail.
Your consent to the provisions of this Notice is required in order to submit or make available Candidate Data. If you decline to submit or make available your Candidate Data, it may affect your ability to apply for or receive an offer of employment.
This Notice does not form part of any contract of employment offered to candidates hired by Current.
Candidate Data is identifiable information that an individual makes available to Current in connection with the recruiting process. Current may collect Candidate Data directly from a job candidate or from third parties, for example, in connection with a background or employment check or employment reference, subject to your consent where required by law. Candidate Data may include a variety of information, such as candidate status, work history/job data, education, compensation, employer feedback, questionnaire results, contact information, previous addresses or names, additional information provided by the candidate (e.g., a cover letter), driver’s license number as required for certain positions, references, and criminal history where permitted by law.
Processing refers to any action performed on Candidate Data, such as collecting, recording, organizing, storing, transferring, modifying, using, disclosing, or deleting.
Sensitive Candidate Data is Candidate Data concerning nationality or citizenship, race or ethnic origin, criminal history, or trade union membership. Current does not request or consider information concerning religion, sex life or political opinions in connection with recruiting.
You may use various electronic and paper methods to submit Candidate Data to Current. You agree that, in addition to collecting Candidate Data directly from you, Current may collect Candidate Data from third parties, for example, from recruiters, in connection with a background or employment check or an employment reference (subject to your consent where required by law) or, to the extent permitted by law, from a recruiting or other web site.
Processing and Retention
Current processes Candidate Data for legitimate human resources and business management purposes. These include identifying and evaluating candidates for Current positions; record-keeping related to hiring processes; analyzing the hiring process and outcomes; and conducting background checks, where permitted by law.
In addition, Candidate Data may be used to comply with Current’s legal, regulatory and corporate governance requirements. If a candidate is hired, Candidate Data may be used in connection with his/her employment consistent with Current’s employment data protection policies. In addition to using Candidate Data for the position for which you have applied, Current may retain and use your Candidate Data to consider you for other positions. If you do not want to be considered for other positions or would like to have your Candidate Data removed, you may contact Current as specified under Inquiries, Complaints and Objections below. Unless required for tax or other legal purposes or in connection with employment as specified above, Candidate Data will be retained for a maximum of three years (or less where required by law).
Sharing with Third Parties
Current may transfer Candidate Data to external third-party providers performing certain services for Current. Such third-party providers have access to Candidate Data solely for the purposes of performing the services specified in the applicable service contract, and Current requires the providers to undertake security measures consistent with the protections specified in this Notice.
Current may be required to disclose certain Candidate Data to other third parties (1) as required by law; (2) to protect Current’s legal rights to the extent authorized or permitted by law; or (3) in an emergency where the health or safety of a candidate or other individual may be endangered. In addition, in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of Current’s business, Current may transfer Candidate Data to successor entities or parties.
International Data Transfers
Current operates globally in over 160 countries. Accordingly, Candidate Data may be transferred to and processed in the US and other countries that may not be deemed to provide the same level of data protection as your home country. Current maintains and applies employment data protection standards consistent with those specified in this Notice to its operations globally.
Sensitive Candidate Data
Current may perform background and criminal checks where permitted by law, and may process other Sensitive Candidate Data, such as citizenship or nationality information or health information, when relevant for a position and permitted by law. If Current intends to collect Sensitive Personal Data from third parties, you will be provided notice and the opportunity to consent. If you have a disability and would like Current to consider an accommodation, you may provide that information during the recruiting process. To the extent you make Sensitive Candidate Data available to Current, you consent to Current processing such Data in accordance with this Notice.
Security and Confidentiality
Current employs technical and organizational measures designed to protect the integrity, confidentiality, security and availability of Candidate Data, and to comply with applicable legal requirements for information security. Current limits access to internal systems that hold Candidate Data to individuals who need access for a legitimate business purpose.
You may exercise the following rights in relation to your Candidate Data:
Access, Correction and Deletion: Current will provide you access to your Candidate Data that Current holds to the extent required by law in your home country, regardless of the location of the Candidate Data processing. You may request correction or deletion of that Candidate Data, except where retention is required by your contractual relationship with Current, in the context of a legal dispute, or as otherwise required by law. If access, correction or deletion is denied, the reason for the denial will be communicated to you.
Automated Decisions: Current generally does not make recruiting or hiring decisions based solely on automated decision-making within the meaning of the EU Data Protection Directive. If Current relies solely on automated decision-making that could have a significant impact on you, Current will provide you an opportunity to express your views and will provide any other safeguards required by law.
Inquiries, Complaints and Objections: You may withdraw consent to the processing of your Candidate Data or submit inquiries, complaints and/or objections to the processing of your Candidate Data by sending a request in writing to: Enterprise Compliance Officer, 25825 Science Park Drive Suite Four, Beachwood, Ohio 44122 or by email at [email protected]. The processes described in this Notice supplement any other remedies and dispute resolution processes provided by Current and/or available under applicable law.
Current will not use Candidate Data to offer you any products or services for personal or family consumption (“direct marketing”) or provide Candidate Data to third parties for their direct marketing. These restrictions do not apply to contact or other personal data obtained in the context of a customer, consumer or other non-employment relationship with Current.
Changes to this Notice
Current reserves the right to modify this Notice by posting changes to relevant Current websites. If you submit additional Candidate Data or request to be considered for a Current position following the effective date of a modified Notice, your Candidate Data will be handled in accordance with the Notice in effect at that time.