PRIVACY IS OUR POLICY

We collect both “Non-Personal Information” and “Personal Information.” Personal Information is any information, alone or in combination, that can identify an individual, such as your name, email address and phone number and that is not otherwise publicly available. Non-Personal Information includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks.

INFORMATION WE COLLECT AUTOMATICALLY

There is also information about your computer hardware and software that is automatically collected via your browser and relayed to CONFIANT. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used by CONFIANT for the operation of the Site and Services, to maintain quality of the customer experience, and to provide general statistics and conduct analytics regarding use of the Site and Services. Please keep in mind that if you directly disclose Personal Information through CONFIANT public message boards, this information may be collected and used by others. We may use third party analytics providers to help us understand and use this statistical data.

INFORMATION YOU PROVIDE DIRECTLY

CONFIANT also may collect Personal Information such as your e-mail address, name, work address and/or telephone number. Providing this information is entirely voluntary.

For example, to activate the Services you do not need to submit any Personal Information other than your email address. To use the Services thereafter, you may need to submit further Personal Information to become a subscriber by registering for an account and creating a personal profile. You can create a profile by registering with the Service and entering your email address and creating a unique username and a password. By registering, you are authorizing us to collect, store, and use your email address in accordance with this Privacy Policy.

We do not knowingly collect any “special categories” of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Please do not provide this information to us.

Note: CONFIANT does not read any of your private online communications. CONFIANT encourages you to review the privacy statements of any third-party websites and social media sites you choose to link to from CONFIANT so that you can understand how those websites collect, use, and share your information. CONFIANT is not responsible for the privacy statements or other content on websites outside of the CONFIANT.com domain and CONFIANT family of sites including related landing pages and subdomains.

Information collected via Cookies

In an effort to improve the quality of the Site and Services, we track information provided to us by your browser or by our software application when you view or use the Site or Services, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the Site or Services, the time and date of access, and other information that does not personally identify you. We track this information using cookies, or small text files which include an anonymous unique identifier. Cookies are sent to a user’s browser from our servers and are stored on the user’s computer hard drive. Sending a cookie to a user’s browser enables us to collect Non-Personal Information about that user and keep a record of the user’s preferences when accessing and utilizing our Site and Services, both on an individual and aggregate basis.

The Company may use both persistent and session cookies; persistent cookies remain on your computer after you close your session and until you delete them, while session cookies expire when you close your browser. For example, we store a persistent cookie to track popular content, clicks, referring sites, and customer journeys.

The following cookies are deployed on the Site:

Strictly Necessary Cookies: These cookies are strictly necessary to provide the Website. For example, they are used to authenticate and identify returning users.

Performance and Functionality Cookies: These cookies provide statistical information on site usage, such as web analytics. They also help us to personalize and enhance your online experience.

Just like any other usage information we collect, information from cookies allows us to improve the Site and customize your online experience. You can set your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. See www.allaboutcookies.org to learn how to disable cookies on your browser or otherwise opt out of cookies. if you set your browser to disable all cookies or opt out, some features of the Site may not function properly.

We also use web beacons and pixels on our Site and in emails. For example, we may place a pixel in marketing emails that notify us when you click on a link in the email. We use these technologies to operate and improve our Website and marketing emails.

This Privacy Policy does not cover the use of cookies used by third parties, and we are not responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Website.

We use Google Analytics to track Site views and general/aggregate data on website users. For more information on how Google uses data when using its partners' sites or apps, please visit this webpage. To provide website visitors more choice on how their data is collected by Google Analytics, Google has developed an Opt-out Browser add-on to enable you to opt-out of Google’s programs available at https://tools.google.com/dlpage/gaoptout

CONFIANT collects and uses Personal Information to operate the CONFIANT Site and deliver the products and services you have requested. Personal Information shall be used only in the context of the Services offered by CONFIANT through the Site, and such use may include the following purposes:

• (i) to allow users to activate, access and use the Services
• (ii) to allow communication of information to users relating to the Services offered by the Site and/or to follow up on requests by users relating to processing such requests and to fulfilment of legal, administrative, accounting, and tax obligations relating to purchases made by users
• (iii) to manage correspondence and service alerts relating to the Services
• (iv) to verify the completeness, validity, and correctness of the data, to avoid high-tech fraud, and
• (v) for marketing and promotional activities relating to the Services offered by CONFIANT and/or partners with whom CONFIANT collaborates from time to time.

Providing Personal Information to us is optional, except as required by applicable laws and regulations. The refusal to submit such data means that CONFIANT may not be able to offer the Services described on the Site to users and/or may not start, manage, or complete commercial offers to users relating to the above-mentioned Services.

CONFIANT may use user Personal Information in the absence of user consent consistent with applicable law.

Access to Personal Information by CONFIANT employees is limited to those employees with a legitimate business need to do so and who are bound by an obligation of confidentiality.

CONFIANT also may use Personal Information to inform you of other products or services available from CONFIANT and its affiliates. CONFIANT may also contact you via surveys to conduct research about your opinion of our Site, our offerings, the Services, or of privacy compliance or other matters.

You may unsubscribe from these communications at any time. For information on how to unsubscribe, as well as our privacy practices and commitment to protecting your privacy please contact us at privacy@confiant.com. Note, however, that you cannot opt out of receiving messages regarding your account, your use of the Services or other administrative or technical matters.

LOCATED IN THE UNITED STATES

CONFIANT, the Site and Services are owned and operated in the United States (US) and are governed by US law. If you are outside the US when you visit the Site, use the Services or engage in communications with us, be aware that your Personal Information may be transferred to, stored, and processed by our data centers in the US. Any information you provide to us, or that we collect through your use of the Site or Services, will be stored, processed, and transferred within, or to, the US. Please be aware that the US and jurisdictions other than the one in which you are located may not provide the same level of data protection as the location from which you are accessing the Website. Note also that your Personal Information may be available to the US Government or its agencies under legal processes in the US.

EEA AND UK PRIVACY RIGHTS

For residents of the European Economic Area (EEA) and United Kingdom (UK), we advise that your Personal Information will be transferred to and processed in the United States, which has data protection laws that are different than those in your country and may not be as protective. The United States has not sought or received a finding of “adequacy” from the European Union under Article 45 of the General Data Protection Regulation (GDPR).

Our legal basis for collecting and using your Personal Information is to do so with your consent; where we need the Personal Information for performance of a contract or requested service, or where the collection and use is in our or another’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the Personal Information in question. If we collected your Personal Information with your consent, you may withdraw your consent at any time by contacting us at privacy@confiant.com.

Our retention of your Personal Information and any subsequent communications are based on our legitimate interest in providing you with new and potentially relevant materials based on your geography, role, or company. As always, you can elect to opt out from receiving such future communications.

To the extent that we transfer Personal Information from the EEA or UK to a jurisdiction outside the EEA that has not been adduced by the European Commission as providing adequate data protections (such as the United States), we will ensure that such Personal Information is safeguarded through appropriate contractual terms or other approved mechanisms.

The GDPR provides individuals in the EEA or UK certain rights regarding their collected Personal Information. An individual may exercise these rights by making a request to Confiant (a “Data Rights Request”). Data subject rights include:

• 1. Access to a copy of the personal data retained by us.
• 2. Erasure of personal data retained by us (this right is also referred to as the "right to be forgotten").
• 3. Ceasing processing activities of personal data by or behalf of CONFIANT based on some objection;
• 4. Rectification(correction) of personal data retained by US.
• 5. Restriction of the processing activities for personal data by us;
• 6. Portability of personal data from us to another entity;
• 7. Excluding the individual from automated decision-making by us;
• 8. Removing the individual from any direct marketing by us.

Please direct any Data Subject Requests to us at privacy@confiant.com. We will respond as described below.

We will make an initial assessment of any Data Rights Request to assess whether CONFIANT is the data controller or a data processor and will verify that the request is valid. Any Data Rights Request must be made by the individual about whom the Personal Information pertains and further verification of identity may be required.

If it is determined that a customer or other third party is the data controller in relation to a Data Rights Request, we will notify the appropriate data controller of the request as soon as possible and will assist the data controller with complying with such request (in accordance with any contract terms or other obligations outlined by applicable data protection law). However, if it is determined that we are the data controller in relation to a Data Rights Request, the requestor will be contacted to confirm receipt of the request and seek confirmation of identity (if not already validated).

Data Subject Requests will be responded to without undue delay and no later than one (1) month following receipt of the request. Where a request is particularly complex, additional time may be required. Where a request cannot be completed in the typical timeframe, we are entitled to extend the response period by up to two (2) additional months provided we give the requestor notice within the original timeframe of the intent to respond and the reason for the delay.

CONFIANT is not permitted to charge for responding to a Data Rights Request unless the request is determined to be excessive and/or manifestly unfounded. In such cases and where we agree to respond to a request, a reasonable fee may be charged based on the administrative costs of providing the information or taking the action requested.

If you are not satisfied with our response, or believe we are processing your Personal Information in violation of the law, you have the right to lodge a complaint with a Supervisory Authority (also known as Data Protection Authority) or other appropriate governmental authority in your EEA Member State or UK. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en

CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have provided your personal information with the Site, you have the right to request removal of unwanted data that you publicly post on the Site. To request removal of such data, please contact us using the contact information provided below, and include sufficient detail about the public post(s) and a statement that you reside in California. We will make sure the data is not publicly displayed on the Site, but please be aware that the data may not be completely or comprehensively removed from our systems, nor can we guarantee any cached or archived version of the site will remove such data.

The California Consumer Privacy Act (CCPA), enacted in 2018, creates new consumer rights relating to the access to, deletion of, and sharing of Personal Information of California residents that is collected by businesses. While we do not sell your Personal Information to any third party, we may partner with third-party service providers and affiliate partners who may gain access to your Personal and Non-Personal Information through the use of beacons, tracking pixels, or cookies as provided in this Privacy Policy. If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit our Supplementary Privacy Notice for California Residents.

NEVADA PRIVACY RIGHTS

Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. CONFIANT does not sell your Personal Information to third parties as defined in Nevada law, and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. If you have any questions regarding our data privacy practices or our compliance with Nevada data privacy law, please contact us as provided below.

PERSONAL INFORMATION

Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent or otherwise share for marketing purposes your Personal Information with third parties without your consent. We do share Personal Information with authorized service providers who are performing services for CONFIANT, such as hosting the servers for our email communications who are provided access to users’ email addresses for purposes of sending emails from us. Those vendors use your Personal Information only at our direction and in accordance with our Privacy Policy and are contractually required to protect the confidentiality and security of this information.

In general, the Personal Information you provide to us is used to help us communicate with you. For example, we use Personal Information to contact users in response to questions, solicit feedback from users, provide technical support, and inform users about promotional offers.

We may share Personal Information with outside parties if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable legal process or enforceable governmental request; to enforce applicable Terms of Service, including investigation of potential violations; address fraud, security or technical concerns; or to protect against harm to the rights, property, or safety of our users or the public as required or permitted by law.

In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Policy. If our information practices change at any time in the future, we will post the policy changes to the Site so that you may opt out of the new information practices if you desire. We suggest that you check the Site periodically if you are concerned about how your information is used.

NON-PERSONAL INFORMATION

In general, we use Non-Personal Information to help us improve the Site and Services and customize the user experience. We also aggregate Non-Personal Information to track trends and analyze use patterns on the Site and Services. This Privacy Policy does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our discretion.

Do-Not-Track Features

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

We implement industry-standard security measures designed to protect your information from unauthorized access. Your account is protected by your account password and we urge you to take steps to keep your Personal Information safe by not disclosing your password and by logging out of your account after each use. We further protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using our Services, you acknowledge that you understand and agree to assume these risks.

CONFIANT retains your Personal Information for a period of time consistent with the original purpose of collection to provide you with the Services you have requested, or as long as required to fulfill our legal obligations and in accordance with applicable law.

As part of the Site or Services, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Site and the Services. Therefore, this Privacy Policy does not apply to your use of a third-party website accessed by selecting a link on our Site or via our Services. To the extent that you access or use the Services through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

Confiant, with its partnership and commitment to Security and Privacy with Microsoft, also provides a link to their Privacy Statement.

Registered users can access and update their personal profile from within their account.

Subject to applicable law, users have the right to request from us a copy of what Personal Information that we have collected or to ask to correct or update their information. Individuals can also request that we delete their Personal Information from our systems and records. We strive to respond to these requests with 30 days or as required in accordance with applicable law. Whenever you directly provide us with your Personal Information, please be sure it is accurate and complete. We cannot be responsible for any information you provide to us that is incomplete or incorrect.

We will not collect, use, or disclose your Personal Information in any ways or for any purposes that are materially different from those set forth in this Privacy Policy. However, if we wish to do so in the future, we will obtain your consent first, and offer you the choice to opt-out of such proposed collection, use, or disclosure.

You have the right at any time to prevent us from contacting you for marketing purposes. When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional e-mail or by contacting us directly as provided below. You can also indicate that you do not wish to receive marketing communications from us in the list location of opt-out page, i.e., “Settings” section of the Site. Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out in the location of opt-out page of the Site, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Policy, and account-specific communications.

The Site and the Services are intended to adults 18 and over and not directed to anyone under the age of 13. The Site does not knowingly collect or solicit information from anyone under the age of 13 or allow anyone under the age of 13 to sign up for the Services. In the event that we learn that we have gathered Personal Information from anyone under the age of 13 without the consent of a parent or guardian, we will delete that information as soon as possible. If you believe we have collected such information, please contact us at privacy@confiant.com.

CONFIANT reserves the right to change this policy and our Terms of Service at any time. We will notify you of significant changes to our Privacy Policy by sending a notice to the primary email address specified in your account or by placing a prominent notice on our Site. Significant changes will go into effect 30 days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Site and this Privacy Policy for updates.

If you have any questions regarding this Privacy Policy or the practices of this Site or our Services, please contact us by sending an email to privacy@confiant.com