Effective date: April 15, 2022

Ʒ (“CAC,” “we,” “us,” or “our”) understands that you care about how we collect, use, and share information when you interact with us, whether on our websites, email, and online services, when you call us, enter a transaction with us, or otherwise communicate with us or use our services (collectively, the “Services”). This Privacy Policy explains:

This Privacy Policy applies when you interact with us or use our Services. It also applies anywhere it is linked or otherwise provided to you. It does not apply to non-CAC websites and mobile applications that may link to the Services or be linked to or from the Services. Please review the privacy policies on those websites and applications directly to understand their privacy practices.

Compliance with Regulations

CAC regularly reviews this Privacy Policy and ensures that we process your information in a manner that is compliant with regulations, as applicable.

Consent

CAC collects personal information about you in connection with our Services. When working for or with our company, you may be prompted to make an account which may hold personal information such as your name, mailing address, phone number, email address or bank account information. When contacting our company, you may be required to submit contact information. When communicating with CAC, all communications will be transmitted and stored by us. By visiting our website or using any of our Services, you consent to CAC’s collection, use, disclosure, transfer, and storage of information relating to you as set forth in this Privacy Policy.

Information We Collect

Information you give us

Some of the Services may include features that permit you to enter information about you. We collect and store any information you enter on our Services or otherwise provide to us. This may include any of the following, depending on your relationship with us, such as if you are registering for our email list, inquiring about our Services, applying for a position with CAC through our Services, applying to join the Shareholder Advisory Committee (SAC), completing a survey, or otherwise interacting with us:

  • Personal identifying information such as your name, contact information, age, and various other information that may be requested when completing different forms on our Services.
  • If you are a CAC shareholder (a “Shareholder”) or relative of a Shareholder, depending on the purpose of your interaction with CAC, we may collect information related to your lineal heritage and status as an Alaska Native, which may include your Certificate of Degree of Indian or Alaska Native Blood, proof of tribal membership, relationship information, wills, share ownership, banking information, death certificates, birth records, and your Social Security Number or Driver’s License Number.
  • If you register for an account on our shareholder portal, we will collect personal identifying information including your name, email, phone number, date of birth, last four digits of your Social Security Number, and your username and password.
  • Email address information when subscribing to our email newsletters or registering for an account.
  • Information you provide when you complete a survey administered by us or a service provider acting on our behalf.
  • Information you may submit to inquire about or apply for a job or internship with us or to volunteer with us.
  • If you contact us, we may keep a record of that correspondence.
  • When you engage in a transaction using a credit or debit card on our Services, we use a payment processor to process your payment, and that third party will collect and process your payment card data. CAC itself does not collect or store payment card information.
  • If you choose to submit your story to us or explain why you wish to become an SAC member, we will collect any information included within that story.
  • Completion of a conflict-of-interest questionnaire.
  • Consent to allow CAC to conduct a background check for you.
  • Any other information you voluntarily provide to us in connection with your use of our Services.

Information We Collect From Other Sources

If you decide to invite others to use the Services, we may collect your and the other person’s names, email addresses, and/or phone numbers in order to send an email (or text message if specified) and follow up with the other person. In some cases, the information you provide to us may be collected on our behalf by various service providers, which is then shared with us, as described below.

Information We Collect Automatically

We use cookies and other technologies to provide features on our Services. CAC relies on various third parties to provide many features of our Services using data about your use of CAC sites and other Services. We also partner with other companies that use these technologies to collect information about your use of our Services and your interaction with emails or promotional messages sent on our behalf. When you interact with the Services, we collect certain information about your use of our Services automatically. This includes:

  • Analytics about your interaction with our Services, including, traffic data, location data, weblogs and other communication data, the resources that you access, and how you reached our Services.
  • Details regarding the device you use to access our Services, including, but not limited to, your IP address, operating system, and browser type.
  • Information about how you interact with our newsletters and other content or digital promotions, including whether you open or click links in any correspondence.
  • Information that you make available to us on a social media platform (such as by clicking on a social media icon linked from our Services), including your account ID or username and other information included in your posts.

Below is a list of these partners with links to more information about their use of your information and any options they may make available regarding tracking.

䲹ٱ𲵴ǰ   Partner Further Information
Analytics Google

How We Use and Protect Your Information

We may use the information we collect from you for the following purposes:

  • To make decisions regarding eligibility for Services or Shareholder benefits from CAC.
  • To provide you with our Services and improve and grow our Services, including by understanding our beneficiary base.
  • To understand how our Services are being used, track site performance, and make improvements.
  • To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, and to comply with legal requirements regarding the provision of products and services.
  • To provide various Services to our Shareholders.
  • To process a job or internship application you have submitted through our Services.
  • To analyze users of our Services and the ways in which our Services are used.
  • To provide you with information you may request from us, or to share information we believe would be of interest to you.
  • To target advertising to you based on your visit to one of our websites or other interaction with us.

We secure the information we collect from or about you through a combination of physical, technical, and administrative safeguards to protect the information we collect through the Services. While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

How We Share Your Information

  • Service Providers: We engage several types of vendors to perform functions on our behalf such as: billing and collection providers, auditing and accounting firms, professional services consultants, providers of analytics services, security vendors, website/data hosting providers, email service providers, IT vendors, printers and mailing providers, and service providers related to our shareholder surveys or events. For example, our shareholder portal is provided to us by a third party, and that service provider then shares the received information with us.
  • Corporate Affiliates: We share certain data with other members of our group of companies, and we may share with other entities affiliated with us in the future (collectively, “Affiliates”). For example, we may share our Shareholders’ names, addresses, phone numbers, emails, degree programs, enrolled school name and location, as well as date of birth and your lineal descendant status for purposes of confirming your status as a Shareholder. Any Affiliate of ours will be required to maintain that information in accordance with this Privacy Policy.
  • Government: We may in some cases share certain information about Shareholders and distributions they have received with the IRS, to the extent required by law.
  • Investigations and Law: Regardless of the choices you make regarding your information (as described below) and to the extent permitted by applicable law, we may disclose information about you to third parties in order to: (1) comply with law, in response to subpoenas, warrants, or court orders, or in connection with any legal process or to cooperate with government or law enforcement officials or private parties; (2) protect our rights, reputation, safety and property, or that of our users or others; (3) protect against legal liability; (4) establish or exercise our rights to defend against legal claims; or (5) to investigate, prevent or take action regarding suspected illegal activities, suspected fraud, the rights, reputation, safety or property of CAC and Affiliates, users or others, violation of our policies or agreements or as otherwise required by law.
  • On Our Website and Social Media: If you share a story with us or otherwise provide content to us with the intent of sharing it, we may, but we are not obligated to, post it on our website or our social media channels.
  • Promotions: If we offer a contest, sweepstakes, or other promotion together with a third party, we may share your information with that party.
  • Social Media Platforms and Advertising Networks: We may sometimes engage in advertising on social media platforms or via advertising networks, which would both involve sharing your information with third parties in order to target advertising to you, create custom audiences on social media, or for other promotional purposes.

Additional Information About our Data Collection and Sharing Practices

We may combine information from one of our Services together with information we obtain from another one of our Services, our business records, or Corporate Affiliates. We may do this for assorted reasons, including to confirm your eligibility to receive Services, to better understand our community, and to provide you with information about other Services we think would be of interest to you (whether from us or third parties).

If you use our Services outside of the United States, you understand that we may collect, process, and store your information in the United States and other countries. The laws in the U.S. regarding personal information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by applicable law. By using the Services, you consent to the collection, international transfer, storage, use, and other processing of your data as described in this Privacy Policy and as otherwise necessary in connection with the business of CAC.

Your Options and Rights Regarding Your Information

If you are a Shareholder, please visit our Shareholder portal and log onto your personal account to update your contact information. Others can send us an email to CAC-Legal@chugach.com.

If at any time you would like to unsubscribe from receiving future emails, you can click the unsubscribe link at the bottom of any email newsletter or email us at CAC-Legal@chugach.com and we will promptly remove you from all correspondence.

Your Privacy Rights

The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of personal information about them, as well as rights to know/access, delete, and limit sharing of personal information. You have the right to be free from discrimination based on your exercise of your CCPA rights. To the extent that we collect personal information that is subject to the CCPA, that information, our practices, and your rights are described below.

Residents of Canada or other states or countries may also have certain rights related to their personal information. You may exercise those rights as described below.

Notice Regarding the Categories of Personal Information Collected

California residents have the right to receive notice of the categories of personal information we collect, and the purposes for which we use personal information, as well as the right to know about the sources of the personal information and whether (or to whom) it is disclosed or sold. The categories we use below to describe personal information are those enumerated in the CCPA.

Entities to whom we disclose information for business purposes are service providers, which are companies that we engage to conduct activities on our behalf. Service providers are restricted from using personal information for any purpose that is not related to our engagement. Some of our service providers are further described above.

Under the CCPA, a business “sells” personal information when it discloses it to a company for monetary or other benefit. We do not currently “sell” personal information as defined by the CCPA.

We collect personal information from the sources described in the Information We Collect section above for the purposes described in the How We Use Your Information section above.

 

Information Type Collected Disclosed to? Sold to?
Personal Identifiers

 

·   Contact information (name, phone number, address, e-mail)

·   Social security number, driver’s license number

Service Providers, Affiliates Not sold

 

Financial Information ·   Payment or credit card data

·   Bank account information

Service Providers Not sold
CAC Shareholder Status ·   Number of Shares owned in CAC

·   Voting Status

Service Providers, Affiliates Not Sold
Protected Classifications ·   Age

·   Date of Birth

·   Gender

·   Alaska Native status

Service Providers, Affiliates Not sold
Commercial Information

 

·   Registration for programs

·   Business contact information (name, phone number, address, e-mail)

·   W-9

Service Providers, Affiliates Not sold
Geolocation Information ·   Coarse information (e.g., address, IP address) Service Providers Not sold
Internet or Electronic Network Activity Information ·   IP address

·   Device identifier (e.g., MAC)

·   Advertising identifier (e.g., IDFA, AAID)

·   Cookie or tracking pixel information

·   Information about your interaction with our website, app, or email correspondence

Service Providers Not sold
Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information ·   Audio recordings (voicemails) Service Providers Not sold
Professional or Employment-Related Information ·   Current employer

·   Employment history

Service Providers Not sold
Education Information ·   Education history

·   Level of education

Service Providers, Affiliates, Schools Not sold

 

We do not collect biometric information or your precise location data.

Right to Opt Out of Sale of Personal Information to Third Parties

Residents of California and certain other jurisdictions may have the right to opt out of any sale of your personal information by CAC to third parties. However, we do not engage in any disclosures that would be considered sales of data under the CCPA.

Other Personal Information Requests

California residents, and individuals in certain other jurisdictions, may have the right to request access to personal information collected about them and information regarding the source of that personal information, the purposes for which we collect it, and the third parties and service providers with whom we share it. You may also have the right to request in certain circumstances that we delete personal information that we have collected directly from you, or you may have other rights depending on the jurisdiction in which you live. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

How to Submit a Personal Information Request

You may submit a request to exercise your rights to know/access or delete your personal information, to opt-out of the sale of your personal information, or other personal information rights you may have, through one of two means:

  • By filling out a Consumer Data Request Form available .
  • By calling us at 1-907-563-8866
  • If you are a Shareholder and you have created an account in our Shareholder Portal, you may be able to exercise certain data rights (such as correcting your information) within the Shareholder Portal.

You may authorize another individual or business registered or authorized in accordance with applicable law (such as an authorized agent) to make requests on your behalf through these means, to the extent permitted by the law of your jurisdiction, however, please note that additional forms and procedures may be required.

In order to process your request to know/access or delete personal information we collect, disclose, or sell, we must verify your request.

We verify your identity by asking you to provide personal identifiers we can match against information we may have collected from you previously and confirm your request using the email address or telephone number stated in the request, if it matches the information in our records.

We will not use personal information we collect in connection with verifying or responding to your request for any purpose other than responding to your request.

Special Information for Nevada Residents

Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to other companies who will sell or license their information to others. At this time, CAC does not engage in such sales. If you are a Nevada resident and would like more information about our data sharing practices, please email CAC-Legal@chugach.com.

Changes to This Privacy Policy

We may make changes to this Privacy Policy from time to time. We will post any changes here, and such changes will become effective when they are posted. Your continued use of our Services following the posting of any changes will mean you accept those changes.

For questions about our privacy practices, contact us at:

Ʒ

3800 CENTERPOINT DR., SUITE 1200, ANCHORGE AK 99503

907-563-8866

Email: CAC-Legal@chugach.com