CDW is a leading integrated technology solutions provider headquartered in the United States, with operations in Canada, the United Kingdom, and other locations around the world. At CDW, we understand that your privacy is an important part of the trust you place in us.
CDW participates in the EU-U.S. Privacy Shield. See below for further details.
We may collect information about you in various ways, including the following:
Information You Provide
We collect information you provide when you use our Sites from one or more devices associated with you, or that you provide in any other way, including over the phone or on paper. For example, we may collect your name, work title, email address, postal address, phone number, demographics, payment and order information, user ID, password, and other information you may provide on our Sites, such as when you complete a transaction, register for an account, log in to our Sites, subscribe to or request our services, participate in an event, contest or survey, or contact our customer service representatives.
Information from Other Sources
We may also obtain information about you from other sources and combine that with information we collect either on our Sites or directly from you. As examples, we may obtain demographic data from third-party data providers to better market to you, or we may purchase or lease lists from list brokers to correct or supplement information about you.
Information Automatically Collected - Cookies & Similar Tracking Technologies
When you visit our Sites, some information about your visit is automatically collected, such as your device's operating system, application software, Internet Protocol (IP) address, access times, browser type and language, peripherals, user log data, Active Directory information, and the websites you visited before and after our Sites. We also collect (directly or via third parties) information about your usage and activity on our Sites, including information about your orders, purchases, and cart activity through essential and non-essential cookies, Web beacons, and similar tracking technologies (collectively, "Cookies").
Cookies are small data files stored on your hard drive, our Site or our emails, which we use to provide and improve our Sites and your experience, such as to see which areas and features are popular, count visits to our Sites, understand usage and campaign effectiveness on our Sites and other websites you may visit, and/or tell if an email has been opened and acted upon.
We may also use and allow third parties to place Cookies on our Sites to collect information about your online activities over time and across websites, including our Sites and other websites you may visit. We may use this information and other information about you, including order and cart activity information, to try to understand your interests and show you advertising and information about products and services offered by CDW and its partners that may interest you.
Certain third-party ad services may also use information collected via Cookies, as well as your IP address, your ISP, and the browser and device you use to visit our Sites in order to deliver advertising relevant to your interests and to better understand the usage and visitation of our Sites and the other sites tracked by these third parties.
If you delete your Cookies, use a different browser, or buy a new computer, you will need to renew your choices. Please visit the respective privacy policies and/or review the privacy settings of the social networking services you use, to make choices about online advertising on those services. While we and others give you choices described in this Policy, there are many ways Web browser signals and other similar mechanisms can indicate your choice to disable tracking, and we may not be aware of or honor every mechanism.
Although you may opt-out of receiving personalised ads from one network, you may still receive ads from other ad networks you did not opt out of or ads that are not personalized to your interests.
Do Not Track
Some Internet browsers include the ability to transmit "Do Not Track" signals. Since uniform standards for "Do Not Track" signals have not been adopted, CDW does not process or respond to "Do Not Track" signals.
California Privacy Rights
If you are a California resident, you may have the right to request information from us about how we may share certain information about you with third parties for their own direct marketing purposes. Please see the YOUR RIGHTS AND CHOICES section below for details on the choices you may have regarding such sharing of your information.
USE OF INFORMATION WE COLLECT
We may use information collected for purposes described in this Policy or as otherwise disclosed to you on our Sites or in connection with our services. For example, where permitted under applicable law, we may use information that you provide or about you to:
- Provide and deliver products and services you request
- Administer your account with us;
- Send you transaction information, including confirmations, invoices, technical notices, product and services information, updates, security alerts, and support and administrative messages
- Respond to your comments and questions and provide customer service
- Operate and improve our Sites, products, and services
- Facilitate the provision of software updates, product support, and other services related to our mobile applications
- Process and deliver contest entries and rewards
- Ask you to take part in research and surveys used to measure our performance and improve our products, services and customer experience
- Send you catalogs and communicate with you about new contests, promotions and rewards, and upcoming events
- Provide you with news about products and services offered by CDW and our selected partners
- Provide you with advertisements based on your interests
- Provide you with an interactive social media experience that allows you to connect your social networking community to our Sites
- Link or combine with other information we get from third parties, to help understand your needs, customize our offerings to those needs and provide you with better service
In order to process your information, we and the third parties detailed above rely on our legitimate interest in providing, securing, customising, improving, and developing our Sites and services to you, your consent (e.g., marketing), and the need to process your information in order to provide the requested services, and as necessary to comply with any legal obligations, as our legal bases (where required) for processing your information.
The information we collect about you is necessary for the purposes listed above. If you refuse to provide information to us or if you request that we stop processing information about you, we may not be able to provide the same level of service to you.
We may retain your personal data as necessary for the purposes described in this Policy, in accordance with CDW's record retention practices. When we no longer need your information we will, - unless needed to comply with applicable legal requirements or carry out corporate tasks and achieve business objectives - remove your personal data and/or take steps to anonymise it.
CDW may store and process your information in the United States and other countries that may not have the same level of protection as your jurisdiction, including allowing access by CDW staff and the third parties identified below. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Policy and applicable law, including with respect to transfers from the EU, relying on our Privacy Shield certification, EU Model Clauses and/or the need to process your information in order to provide the requested services, as the bases for transferring your personal data. As permitted by applicable law, you may request details about the suitable safeguards we have in place by contacting us as detailed below.
SHARING YOUR INFORMATION
Ways we may share your information with third parties as follows:
- Third Party Vendors/Service Providers. We may rely on third-party vendors, consultants and other service providers to perform functions on our behalf and under our instructions in order to make our Sites available to you. For example, we may engage vendors/service providers for auditing, compliance, and corporate governance functions
- CDW Suppliers and Distributors. We may share your information with suppliers and distributors to CDW for their internal purposes including administrative purposes, as well as to improve performance, products and services; and for purposes relating to proposed or completed transactions facilitated by CDW
- Business Partners. We may share your information with third parties with whom we do business, including to facilitate your purchase of a product manufactured by a CDW partner, or for their own marketing purposes in compliance with applicable laws and subject to their separate privacy policies
- Business Reorganisation. In connection with or during negotiation of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company
- Consent. We may share your information for any other purposes with your consent
We may also share aggregated or anonymised information in a form that does not directly identify you.
EU-U.S. PRIVACY SHIELD
CDW participates in the EU-U.S. Privacy Shield framework ("Privacy Shield"), and as part of this commitment, protects personal data received about corporate customers, and their customers and employees in the European Union ("EU Personal Data") in accordance with the Privacy Shield Principles. The types of EU Personal Data we collect, the purposes for collecting such information, and the types of third parties and purposes that we disclose such information are as detailed above.
CDW remains responsible for onward transfers of EU Personal Data to third parties, unless we prove we are not responsible for the event giving rise to the damage. CDW may also be required to disclose EU Personal Data in response to lawful requests by public authorities, including in order to satisfy national security or law enforcement requirements.
CDW commits to resolve complaints about our collection or use of EU Personal Data, and is subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to Privacy Shield. EU data subjects with questions or complaints regarding our Privacy Shield certification should first contact CDW at email@example.com. 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. In addition, under certain conditions, EU data subjects may invoke binding arbitration when other dispute resolution procedures have been exhausted. To learn more about Privacy Shield and review our self-certification, please visit the Privacy Shield List here.
SECURITY OF YOUR PERSONAL DATA
CDW takes reasonable technical, physical, and administrative steps to help protect your personal data in our custody or control from loss, misuse and unauthorised access, disclosure, alteration and destruction. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone or to reuse the same user ID and password on other sites.
THIRD PARTY WEBSITES
Except for CDW's own online activities on third-party websites and online services where we post our Policy, this Policy does not apply to, and CDW is not responsible for, any other data practices of third-party websites and online services or the practices of other third parties. To learn about third-party data practices, please visit their respective privacy policies.
SOCIAL NETWORKS AND ACCOUNTS
Our Sites are general audience sites intended for corporate and governmental purchasers. Our Sites are not directed at children under the age of 13. If we obtain actual knowledge that any information we collect has been provided by a child under the age of 13, we will promptly delete that information.
YOUR RIGHTS AND CHOICES
Email and Marketing Choices
You may ask us not to process your personal data for marketing purposes. In some jurisdictions, you also have the right to opt-out of the disclosure of your personal data to third parties for the third parties' direct marketing purposes. You can exercise your right to prevent such processing by: (i) following the opt-out instructions in promotional emails; (ii) checking certain boxes on the forms we use to collect personal data; (iii) for email marketing, by visiting your account settings here (US) or here (Canada); and (iv) for Catalog subscription, by clicking here (US) or here (Canada). To manage any email or Catalog subscriptions in the UK, please contact us at firstname.lastname@example.org. You may also make requests about your contact preferences and changes to your information by contacting your account manager, or by contacting Customer Relations (US or Canada). If you opt-out of promotional emails, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.
Access and Change Requests
You may access, correct or delete some personal and account information maintained in your E-Account through your E-Account. To request access to, or the correction or deletion of any other information about you or content you post on our Sites, or to exercise any right to restrict or object to processing or data portability, please contact your account manager. If you do not know your account manager, simply click here or call 866.782.4239 (US / Canada), or contact us at email@example.com (UK). We reserve the right to decline requests unless required by applicable law.
CHANGES TO THIS POLICY
CDW may change this Policy from time to time. If we make any changes to this Policy, we will change the "Effective Date" at the beginning of this Policy. If we make material changes to this Policy that increase our rights to use personal data we have previously collected about you, we will obtain your consent either through an email to your registered email address or by prominent posting on our Sites.
If you wish to request information regarding the use or disclosure of your information by CDW, or if you have any questions about this Policy, please send an email to firstname.lastname@example.org.
Alternatively, inquiries may be addressed to:
Global Compliance & Ethics
75 Tri-State International
Lincolnshire, IL 60069
EU data subjects may also contact our Lead Supervisory Authority, the Information Commissioner's Office of the United Kingdom, with any questions about our privacy practices.