Privacy Policy

Last updated: February 26, 2021

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.

What does this privacy policy cover?

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 policy does not apply to the practices of third parties that we do not own or control.

What personal information do we collect?

Our primary goal in collecting personal information is to provide you with a friendly, customized, and efficient experience.

In the 12 months preceding the date of this Privacy Policy, we may have collected the following categories of personal information, which we continue to collect:

Personal identifiers, including your name, physical address, billing address, email address, phone numbers, cookie information, and password, IP address or other unique identifiers.
Commercial information, including records of services purchased, and payment information.
Internet or other electronic network activity, including your browsing history, 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 may have collected your personal information 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. Additionally, we may have collected your personal information when you interacted with the Site.

What about cookies?

Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your Web browser to enable our systems to recognize your browser and tell us how and when pages in our website are visited and by how many people. CIH cookies do not collect personal information, and we do not combine information collected through cookies with other personal information to tell us who you are or what your screen name or email address is. We do not, and do not allow third parties to, use cookies or other tracking technologies to collect information about individuals’ online activities over time and across third-party websites or online services.

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.

Will CIH share any of the information it receives?

Information about our users is an integral part of our business. In the 12 months prior to the date of this Privacy Policy, we shared personal information with the following categories of third parties, and may continue to share personal information with them:

Service providers that help us operate our business. These include entities that process payments or provide technical support and assistance for the Site.
Data analytics providers. We use data analytics to help us manage how visitors use and interact with our Site, including the services we offer. In this regard, we use Google Analytics. Visit this website to find out more about how Google Analytics collects and processes data.
Business Transfers – In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the business assets that is transferred. Moreover, if we, or substantially all of our assets, were acquired, user information would be one of the assets that is transferred.
Protection of CIH and Others – We may release personal information when we believe in good faith that release is necessary to comply with that law; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of CIH, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
With Your Consent – Except as set forth above, you will be notified when your personal information may be shared with third parties or used for a purpose incompatible with the purpose(s) for which it was originally collected, and you will be able to prevent the sharing of this information by opting out.

Is information about me secure?

Your CIH account information is protected by a password for your privacy and security. You need to work to protect against unauthorized access to your password and to your computer by logging off once you have finished using a shared computer.

Additionally, 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.

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 pages, such as those listed in the “What Personal Information About Users Does CIH Collect?” section above. When you update information, however, we may maintain a copy of the unrevised information in our records.

You may request deletion of your CIH account by emailing us.

As explained earlier, 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.

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 with which we shared the personal information
The categories of personal information we disclosed for a business purpose, and for each category identified, the categories of third parties to whom we disclosed that particular category of personal information
The specific pieces of personal information we collected

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.

How can you make a request to exercise your rights? To submit requests to know or delete, you may contact us at 1.866.299.9333 or 1.312.596.7755.

How we will handle a request to exercise your rights. For requests to know or delete, we will first acknowledge receipt of the request within 10 business days of receipt of your request. We will provide a substantive response to your request within 45 days from receipt of your request, although we may be allowed to take longer to process your request under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we’ll let you know.

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.

You are also entitled to submit a request for personal information that could be associated with a household as defined in the CCPA. To submit a request to know or delete household personal information, such requests must be jointly made by each member of the household, and we will individually verify all of the members of the household using the verification criteria explained above, and separately verify that each household member making the request currently resides in the household. If we are unable to verify the identity of each household member 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 our denial.

You may also designate an authorized agent to submit requests on your behalf. If you do so, you will be required to verify your identity by providing us with certain personal information as described above. Additionally, we will also require that you provide the agent with written and signed permission to act on your behalf, and we will separately confirm with you that you provided the agent with permission to submit the request. We will deny the request if the agent is unable to meet submit proof to us that you have authorized them to act on your behalf or if any of the above verification criteria are not met.

We are committed to honoring your rights. If you exercise any of the CCPA rights explained in this Privacy Policy, we will continue to treat you fairly.

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.

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 sell any personal information, including the personal information of minors under age 16.

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.

Changes to this privacy policy

We may amend this Privacy Policy from time to time, at its sole discretion. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes to the Privacy Policy, we will notify you by posting an announcement on the CIH website so you are always aware of what information we collect, how we use it, and under what circumstances if any, it is disclosed.

Conditions of use

If you decide to visit our website, 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.

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

Questions and Contact Information

If 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.