Legal Information
Privacy Notice
Last updated: August 20, 2026
Who are we and what is the purpose of this Notice?
Zafin and its group of companies (“Zafin”, “we”, “us” or “our”) are committed to protecting
the privacy and security of Personal Information and handling it in accordance with data
protection and privacy laws.
This Privacy Notice (“Notice”) and Cookie Notice are part of the Zafin privacy program and
describe how we collect, use, and disclose your Personal Information in the course of our
business. This Privacy Notice also describes your choices and rights with respect to your
Personal Information, including your rights of access and correction. We have published
this Notice to ensure that you are fully aware of what Personal Information we collect from
you, how we Use it, who we share it with, and what your rights are. This Notice applies to
our website visitors, platform users, those who contact us, and those who we send
marketing messages to, where you work for a prospective, current or former customer. If
you are applying for employment, an internship, or scholarship, please review Zafin’s Candidate Privacy Notice.
Table of contents:
- Definitions
- Personal Information we collect and how we Use it
- Will we share your Personal Information?
- Security and Retention of Personal Information
- Rights Regarding Personal Information
- Children’s Privacy
- Governing Law
- Changes to this Notice
- Contact Us
- Notice for individuals in the UK and EEA
- Notice of Residents of Certain States of United States
Definitions
We have included the following definitions to help you understand the contents of this
Notice:
Automated decision-making – “Automated decision-making” is the process of making a
decision by automated means, using algorithms or software, without any human
involvement. These decisions can be based on factual data, as well as on digitally
created profiles or inferred data.
CCPA – “CCPA” means the California Consumer Privacy Act of 2018 and California Privacy
Rights Act of 2020 (Cal. Civ. Code 1798.100 et seq) and their regulations.
Collection – “Collection” occurs when Zafin finds itself in custody or control of personal
information. Note that this includes information that Zafin receives even when the data
was not requested.
Consent – “Consent” is an individual’s freely given, specific and informed agreement to
the processing of their personal information.
EEA – “EEA” means European Economic Area, which includes countries like Austria, Belgium,
Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France,
Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania,
Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia,
Spain, and Sweden.
GDPR – “GDPR” means the General Data Protection Regulation (EU) 2016/679.
Personal Information – “Personal Information” is information that (a) can be used to
identify an individual to whom the information relates, or (b) is or might be directly or
indirectly linked to an individual in the context of the processing of the data.
PIPEDA – “PIPEDA” means Canada’s federal Personal Information Protection and Electronic
Documents Act S.C. 2000, c. 5.
Process – “Process” is an operation or set of operations performed upon Personal
Information.
Sell, Sale, Share – We do not “sell” your Personal Information for monetary or other valuable
consideration, nor do we “share” your Personal Information for cross-context behavioral
advertising, as these terms are defined under applicable U.S. privacy laws.
Sensitive Data – A subcategory of Personal Information which may include government
identifiers (like Social Security numbers), precise geolocation data, racial or ethnic origin,
religious beliefs, or health information. Definitions of Sensitive Data vary by jurisdiction.
Where we process Sensitive Data, we do so in accordance with applicable law and, where
Zafin processes such information on behalf of a customer, in accordance with our
agreement with that customer. We do not process Sensitive Data without your prior
consent.
Targeted Advertising – Displaying advertisements to you where the advertisement is
selected based on personal data obtained from your activities over time and across
nonaffiliated websites or online applications to predict such as your predispositions or
interests.
UK GDPR – “UK GDPR” means the General Data Protection Regulation, Regulation (EU)
2016/679 as it forms part of domestic law in the United Kingdom by virtue of section 3 of
the EU (Withdrawal) Act 2018 (including as further amended or modified by the laws of
the United Kingdom or a part of the United Kingdom from time to time).
Use – “Use” means the process of collecting, accessing, storing, reading, modifying,
analyzing, or changing Personal Information. This includes when Zafin uses a service
provider or vendor to carry out these tasks on its behalf.
Personal Information we collect and how we Use it
When you engage with Zafin through our websites, or any platforms, or when you use our
Services, we may gather Personal Information and other information from you.
Zafin’s primary source of information for processing is de-identified Personal Information
provided to us by our customers. Our customers remove direct identifying attributes from
data sets by excluding them or replacing them with random data ‘tokens’. Zafin delivers
data analytics and related services on this de-identified data. Zafin does not attempt to
re-identify individuals in these data sets. Notwithstanding this, Zafin’s policy protects
these data as Personal Information.
We take steps designed to ensure that only authorized personnel have access to your
Personal Information. The sections below further describe where we collect your Personal
Information from, what we collect, and how we Use it. This Notice also provides links to
more detail specific to your region, to help you to understand the Use of your Personal
Information.
When you visit and use our Website
We will collect browser and device information such as IP address, browser history,
aggregated data, and usage data via cookies. Cookie related details are provided in the Cookie Notice. This information does not reveal your identity and is not directly
about you.
We will use this information:
- To operate, maintain, enhance, and provide all features of our Website;
- To understand which parts of the website are visited and how frequently;
- To provide access to desirable content based on your preferences
- To provide support to users of the Website.
If you choose to withhold any Personal Information requested or deny the placement of
cookies required for the purpose of providing a service, it may negatively impact your
experience on the site and limit the services we are able to provide.
For marketing purposes
When you fill in a form
If you fill in a form on our website, on an advertiser platform (e.g. LinkedIn), or at an event,
we will collect the information you include on the form such as your name, contact details
(telephone number, mailing address and email address), business contact details (job
title, business email address, business telephone number) and details of the organization
you work for. We will also capture your areas of interest, types of communications you
would like to receive, and marketing preferences.
We will use this information:
- To fulfil your request;
- To send you information about our products and solutions;
- To provide access to content (e.g. whitepapers, case studies);
- To administer subscriptions to Zafin publications and newsletters;
- To organize events;
- To respond to questions about Zafin;
- To provide support to visitors of our Website
Publicly available Personal Information
We may collect information such as your name, business contact details (job title, business
email address, business telephone number) and details of the organization you work for, using
publicly available information, such as social network profiles (e.g. LinkedIn).
We will use this information:
- To design marketing campaigns;
- To market our products and services;
- To organize events;
- To tailor our marketing and sales activities to your company’s interests;
When you use our products and services
When you use certain Zafin products and services, you or the organization you work for may provide information to us for processing as part of the service. Depending on the service, this
may include transaction information, transaction descriptions, amounts, location or country
information, identifiers, or other information submitted through Zafin applications or APIs.
We use this information to provide, operate, secure and support the applicable service,
including to process information submitted to us and provide requested results or outputs. We
may also collect technical and usage information relating to your interaction with the service
for security, fraud and abuse prevention, troubleshooting, service administration and
performance monitoring.
Where Zafin processes Personal Information on behalf of an organization using our services,
that organization is responsible for determining the purposes for which the Personal Information is processed and for providing appropriate privacy information to the individuals concerned. Zafin processes such information in accordance with its agreement with that organization and applicable data protection law.
When the organisation you work for is a prospective, current or
former customer or strategic partner
If you register for or use a Zafin product or service, or work for an organization that is a
prospective, current or former customer, we will collect your name, contact details (telephone number, mailing address and email address), business contact details (job title, business email address, business telephone number), in-application usage data, user behavioral insights and details of the organization you work for. We may also collect account registration information, login and authentication information, IP address, account activity and service usage information.
We will Use this information:
- To organize a demonstration of our products and services;
- To provide a quotation if requested;
- To negotiate and conclude contracts;
- To set up and administer the commercial arrangement;
- To set you up with a login for any of our platforms or systems;
- To provide data analytic and related services to the organisation you work for;
- To collect and analyze in-application usage data and user behavioral insights to
better understand how our products and services are used, improve user
experience, identify product enhancements, and provide support; - To administer contracts;
- To process and manage invoices and payments;
- To protect our services, prevent fraud or misuse, and comply with legal, regulatory,
sanctions and geographic access requirements - To resolve disputes;
- For the purposes of any company acquisition or disposal, for compliance with legal
obligations, for law enforcement and any other purpose required by law.
This data is processed by us on the basis of our legitimate interest in improving our services and supporting users, or where applicable, based on your consent. If you choose to withhold any Personal Information requested by us for the purpose of providing a service, you may not be able to access or use the requested service. If you have any concerns about whether you need to provide the Personal Information, please contact the Privacy Office .
Call Data
Will we share your Personal Information?
In some cases, we may share Personal Information with trusted service providers for processing and to help us provide, maintain, and improve our services. We remain accountable for that Personal Information’s privacy and security and use contractual or other means to ensure that service providers meet our privacy and security requirements.
We may make certain automatically collected, aggregated, or otherwise non-personally identifiable information available to third parties. We do not sell or rent personal information collected to third parties.
Who do we share your Personal Information with?
We have set out below the third parties we may share your Personal Information with. If we do this, we will put in place a contract with them which controls how your Personal Information may be used and which requires that your Personal Information is treated in accordance with
relevant data protection laws.
- With companies who provide support for our internal IT systems: We use reputable third
parties to provide us with our IT systems (including our Website’s hosting service
provider) and support for them. They may access your Personal Information to the extent
that they need to in order to provide their services and deal with any issues. - With companies who provide marketing services: We may make certain automaticallycollected, aggregated, or otherwise non-personally identifiable information available to
third parties for various purposes, including, to assist such parties in understanding your
interests, habits, and usage patterns for programs, content, services, and functionality
available through the Website. - With companies who support our products and services: We use reputable third parties
to assist with sales and marketing (including customer service and incident
management), product engineering and design tools (including software issue
tracking), and identity services (including identity federation for single sign on and
authentication). They may access your Personal Information to the extent that they need
to in order to provide their services and deal with any issues. - With a company that we merge with or transfer our business assets to: In the event that
we sell all or part of our business, or merge with another company, we may transfer Personal Information that we have collected as described in this Notice, along with our
other business assets, to the company that we are selling to or merging with. - For compliance with employment reporting or other obligations
- With entities, organisations or individual for legal reasons: We will share your Personal
Information with entities, companies or individuals where this is strictly necessary to
comply with any law, rule, regulation, governmental request or legal procedure that is
applicable to us. - With entities, companies or individuals to obtain advice: We will share your Personal
Information with external professional advisors such as lawyers or accountants in order
to take advice and for the purposes of legal and tribunal proceedings or enforce the
terms of our agreements.
We will only disclose such Personal Information to any third party as is necessary to enable them to carry out the function or purpose for which it is disclosed. If you would like further information on the third parties we may share your Personal Information with and our legal basis for sharing your Personal Information with third parties, please contact the Privacy Office.
Security and Retention of Personal Information
Zafin has implemented various physical, administrative, and technical safeguards
designed to protect Personal Information from being accidentally lost, used, or accessed
in an unauthorized way, altered, or disclosed. These safeguards include security reviews
and controls such as limiting access to your Personal Information to those employees
and other third parties who have a business need to know, and who are subject to a duty
of confidentiality. However, no security measures are absolute or wholly guaranteed. You
agree to be responsible for all activities conducted on the Website. While we will strive to
protect your personal information, the transmission of such data to and from our Services
occurs at your own risk. It is advisable to use the services exclusively in a secure
environment. If you have reason to believe that your interaction with us is no longer
secure, please contact us immediately.
We will only keep your Personal Information for as long as reasonably necessary to fulfil
the relevant purposes set out in this Notice and to comply with our legal and regulatory
obligations.
If a dispute arises between us, we will keep your Personal Information for the purposes of
responding to and dealing with this dispute and this may mean that we keep your
Personal Information for longer. If you would like further details, please contact the Privacy Office .
Rights Regarding Personal Information
On written request and subject to proof of identity, you may
- Access copies of the Personal Information we hold about you;
- Request that any necessary corrections be made, where applicable, as authorized or
required by law; and - Request deletion of your Personal Information, where applicable, as authorized or
required by law.
To ensure that the Personal Information we maintain about you is accurate and up to date,
please inform us immediately of any change to your Personal Information. Note that this applies if we have a direct relationship with you and you have supplied us with your information, such as in an application for employment. With respect to de-identified personal data that we process for our customers, we can not re-identify individuals and cannot prove the requestor’s identity.
To make a request, please use the contact details provided in the “Contact Us” section. We will consider and act upon any request in accordance with applicable data protection laws.
Children’s Privacy
The Website is not directed to children under the age of 16, and we do not knowingly collect Personal Information from children under the age of 16 without obtaining parental consent. If you are under 16 years of age, please do not use or access the Website at any time or in any manner. If we learn that Personal Information has been collected via the Website from persons under 16 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 16 years of age has provided Personal Information, then you may alert us as set forth in the “Contact Us” section and request that we delete that child’s Personal Information from our systems
Governing Law
This website and Zafin are based in Canada and are governed by the applicable privacy and data protection laws in Canada. Your Personal Information may be stored or processed in any country in which Zafin or its service providers have facilities, and by using this Website or applicable Zafin services, you agree to the transfer of your information to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of Canada, it is subject to the laws of the country in which it is held. It may be subject to disclosure to the governments, courts, law enforcement, or regulatory agencies of such another country, pursuant to such a country’s laws.
If you are an individual in the United Kingdom (UK) or European Economic Area (EEA), see the UK/EEA Notice. If you are a resident in the United States of America, see the Notice of Residents of Certain States in United States.
Changes to this Notice
We may change this Privacy Notice. Changes to this Notice become effective when posted on our website, please note the “Last Updated” date. Your continued use of the website after the revised Notice has become effective indicates that you have read, understood, and agreed to the current version of the Notice.
Contact Us
If you have any questions or comments about this Notice or your Personal Information, to make an access or correction request, to exercise any applicable rights, to make a complaint, or to obtain information about our policies and practices, our Privacy Office can be reached using the following information:
| 123 Front St W., Suite 1501 Toronto, Ontario M5J 2M3 Attention: Privacy Office | |
| [email protected] |
Notice for individuals in the UK and EEA
If you are based in the UK or EEA, please note that the term Personal Information used in this Notice is equivalent to the term “personal data” under the GDPR and other applicable European data protection laws. Canada’s laws have been determined to be ‘adequate’ by the Commission of the European Union, which means that we are providing equivalent protection to your Personal Information by complying with Canadian law.
Personal Information we collect, how we Use it and our lawful basis
How we collect and use your Personal Information when you visit and use our Website and our lawful basis
We have explained in the above section the Personal Information we will collect about you and how we Use it when you visit our Website. Full details can be found here.
This Use is on the legal basis that it is in our legitimate interests as a business to be able
to respond to inquiries that we receive and ensure that our Website is operational,
functional and maintained. We have considered our legitimate interests carefully and
have balanced our legitimate interests against your rights under data protection law. We
consider that this Use is proportionate because we will only Use the Personal Information
we get from you to respond to your inquiry and it is in your reasonable expectations that
we would need to Use your Personal Information to be able to respond to you and ensure
our Website is operational and functional
For details about what cookies we Use on our Website and our legal basis for them click here.
How we collect and use your Personal Information when you have agreed that we can market to you and our lawful basis
We will collect your Personal Information to send you information about our services, events and news. Full details can be found here.
Under data protection law we must have a legal basis to Use your Personal Information. Where we Use your Personal Information for marketing, we do this on the basis that you have consented to us sending you marketing. You have the right to change your mind about this at any time. There will be unsubscribe links in all the marketing emails that we send you, and you can also contact us at any time to ask us to stop sending marketing to you. If you wish to do this please contact the Privacy Office .
How we collect and use your Personal Information when the organisation you work for is a prospective, current or former customer and our lawful basis
We will collect and Use your Personal Information to provide the quotation, negotiate and
conclude contracts, and set up our customer arrangement with the organisation you
work for.
The legal basis for using your Personal Information in this way is that it is in our legitimate
interests as a business to be able to contact you to provide a quote and to manage and
assist with the conclusion and ongoing performance of a contract with your organisation.
We have considered our legitimate interests carefully and have balanced our legitimate
interests against your rights under data protection law. We consider that this Use is
proportionate because it is relevant and appropriate to our relationship with you, it is in
your reasonable expectations that we would need to Use your Personal Information to
contact you in this way and we only Use your business contact details for matters which
relate directly to our relationship with the organisation you work for.
Do we Use your Personal Information to make automated decisions?
You have the right not to be subject to Automated decisions that will create legal effects or have a similar significant impact on you, unless (i) you have given us your consent (ii) it is necessary for a contract between you and Zafin, or (iii) is otherwise permitted by law. You also have certain rights to challenge decisions made about you. We do not currently carry out Automated decision-making in connection with your Personal Information.
Will we transfer your Personal Information outside the UK/EEA?
We will only transfer your Personal Information outside the UK/EEA as follows:
- To our IT systems based in Canada;
- To Zafin group companies
- To companies who support our products and services (in Canada and the United States, as applicable)
- Where our third-party service providers who we share Personal Information with (such
as cloud service providers) are based outside the UK and/or EEA, have support services
located outside the UK and/or EEA or host Personal Information outside the UK and/or
EEA.
We only transfer your Personal Information outside the UK/EEA where we have a legal basis for doing so and where we ensure that your Personal Information is protected to the same standard as it would be protected in the UK/EEA. Since Canada has been recognized as having an adequacy status by the UK and EU, your Personal Information is held at the same level of
protection as it would within the UK and EEA.
Where appropriate, we enter into data sharing agreements with the recipients of your Personal Information based outside the UK/EEA which comply with the EU Commission’s standard clauses and the UK addendum to the standard clauses (if applicable), or the UK Information Commissioner’s International Data Transfer Agreement for the transfer of Personal Information. We carry out all necessary transfer risk assessments and transfer impact assessments for such circumstances. If you would like further details about our transfer of your Personal Information outside the UK/EEA or details of the safeguards put in place in relation to your Personal Information please contact the Privacy Office.
Personal Information Obtained from Third Parties
We may enrich our prospect database with business-contact information obtained from thirdparty providers (EEA or UK-based) that compile data drawn from publicly available sources— for example, company websites, professional social-media profiles (such as LinkedIn), and official corporate filings. The information we receive may include your name, job title, corporate e-mail address, direct dial or corporate phone number, LinkedIn URL, and employer firmographics (sector, size, headquarters country). When Zafin receives personal information about you from other sources directly, Zafin will provide the following information to you, in addition to all other information already required by the Privacy Notice:
- The categories of personal data;
- The source from which the personal data originates, and if applicable, whether it came
from publicly accessible sources; - The purposes of the processing for which the personal data are intended as well as the
legal basis for the processing; - The legitimate interests pursued by Zafin or by a third party, if processing is based on
Article 6(1)(f) GDPR (legitimate interests); - The recipients or categories of recipients of the personal data, if any;
- Where applicable, the fact that Zafin intends to transfer personal data to a third country
or international organization and the existence or absence of an adequacy decision by
the European Commission, or reference to the appropriate or suitable safeguards and
the means by which to obtain a copy of them or where they have been made available; - The period for which the personal data will be stored, or if that is not possible, the criteria
used to determine that period; - The existence of the right to request from Zafin access to and rectification or erasure of
personal data or restriction of processing concerning the data subject and to object to
processing as well as the right to data portability; - Where processing is based on consent, the existence of the right to withdraw consent
at any time, without affecting the lawfulness of processing based on consent before its withdrawal; - The right to lodge a complaint with a supervisory authority;
- Whether the provision of personal data is a statutory or contractual requirement, or a
requirement necessary to enter into a contract, as well as whether the data subject is
obliged to provide the personal data and of the possible consequences of failure to
provide such data; - The existence of automated decision-making, including profiling, and, at least in those
cases, meaningful information about the logic involved, as well as the significance and
the envisaged consequences of such processing for the data subject.
Zafin will provide this information within a reasonable period after obtaining the personal data, but at the latest within one month, or at the time of the first communication with the data subject, or when the data is first disclosed to another recipient, whichever occurs first.
Your Privacy Rights
As an individual in the UK/EEA, you have certain rights regarding our processing of your Personal
Information. This is set out in more detail below. If you wish to exercise any of these rights, you
have the right to make a complaint to the supervisory authority in your country. We would,
however, appreciate the chance to deal with your concerns before you approach the
supervisory authority and so, if you are happy to do so, please contact the Privacy Office .
- Right to object: You have the right to object to our processing of your Personal
Information where we are relying on a legitimate interest as our legal basis for
processing. You may object on grounds relating to your particular situation. If you raise
an objection, we will stop processing your Personal Information unless we can
demonstrate compelling legitimate grounds for the processing which override your
interests, rights, and freedoms, or the processing is for the establishment, exercise, or
defense of legal claims. - You have an absolute right to object at any time to the processing of your Personal Information for direct marketing purposes: You can exercise this right by clicking the “unsubscribe” link provided in our marketing emails or by contacting the Privacy Office at any time. If you object to processing for direct marketing purposes, we will stop processing your Personal Information for such purposes.
- Access to your Personal Information: You can request access to a copy of your Personal
Information that we hold, along with information on what Personal Information we Use,
why we Use it, who we share it with, how long we keep it for and whether it has been used
for any Automated decision making. You can request access free of charge. Please
make all requests for access in writing to the Privacy Office. - Consent: Most of the time, we won’t need your consent to Use your Personal Information as we will be using it only to fulfil our contract with you as one of our clients or it is in our legitimate interests. This legitimate purpose includes Personal Information required to create, maintain, and terminate the commercial relationship. There are limited circumstances where we may ask for your consent to process your information. Where you have given us your consent to Use your Personal Information, you can withdraw your consent at any time by contacting the Privacy Office at [email protected]. Withdrawing
your consent does not impact the legality of any processing carried out before the
withdrawal, nor does it affect the processing of your Personal Data based on other valid
legal grounds aside from consent. - Rectification: You can ask us to change or complete any inaccurate or incomplete
Personal Information held about you. If we choose not to do so, we will provide you with a written statement explaining why the request could not be met. - Erasure: You can ask us to delete your Personal Information where it is no longer
necessary for us to use it, you have withdrawn consent and we have no other legal basis
to keep your Personal Information, you have asked us to review and explain our
legitimate interests to you and we don’t actually have a valid legitimate interest for
keeping it, our Use of your Personal Information is illegal, or we have to delete your
Personal Information to comply with our legal obligations. Please be aware that we may
have legal obligations to retain records for a certain period after the commercial
relationship ends. Where we are required by law to keep certain information, we will be
unable to delete such information. - Portability: You can ask us to provide you or a third party with the Personal Information
that we hold about you in a structured, commonly used, electronic form, so it can be
easily transferred where we are using your Personal Information on the basis of your
consent or on the basis that it is necessary to perform a contract with you and the Use
of your Personal Information is carried out by automated means. - Restriction: You can ask us to restrict the Personal Information we Use about you where
you don’t think the Personal Information we have about you is correct, so that we can
check if it is correct, what we are doing with your Personal Information is illegal but you
would rather we stop using your Personal Information rather than delete it, we don’t need
your Personal Information anymore, but you need us to keep it so that you can exercise
any legal rights, or you have asked us to review and explain our legitimate interests to
you, so that we can check whether we actually have a valid legitimate interest to do
what we are doing.
If you wish to exercise any of these rights, please submit your request in writing to us using the contact details provided in the “Contact Us” section. We will consider and act upon any request in accordance with applicable data protection laws. Please be aware that, to safeguard Personal Data, we may need to verify your identity using a method appropriate for the type of request you are making. If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. Find their contact details here.
Notice of Residents of Certain States of United States
This section supplements the information contained in this Privacy Notice and applies solely to
residents of U.S. states with comprehensive privacy legislation, including California, Colorado,
Connecticut, Utah, and Virginia (“Consumers” or “you”). We adopt this notice to comply with the
California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights
Act of 2020 (CPRA) and other applicable state privacy laws. At or before the point of
collection, we will inform you of the categories of Personal Information to be collected, the
purposes for which they will be used, whether the information will be sold or shared, and how
long we intend to retain each category of Personal Information.
Your Privacy Rights
Subject to certain legal limitations, you have the following rights regarding your Personal
Information:
- Right to Know and Access: You have the right to request that we disclose the
categories and specific pieces of Personal Information we have collected about you,
the sources of that information, the business purposes for collecting it, and the categories of third parties with whom we disclose it. - Right to Deletion: You have the right to request the deletion of your Personal
Information that we have collected, subject to certain exceptions . For instance, we
may need to retain your information to complete a transaction, comply with a legal
obligation, or for other internal and lawful purposes - Right to Correction: You have the right to request the correction of inaccurate Personal
Information that we maintain about you. - Right to Data Portability: You have the right to receive a copy of your Personal
Information in a portable and, to the extent technically feasible, readily usable format. - Right to Opt-Out of Targeted Advertising: While we do not “sell” your Personal
Information, you have the right to opt-out of the processing of your data for purposes
of targeted advertising. You may exercise this right by contacting the Privacy Office. - Right to Opt-Out of Profiling: You have the right to opt-out of profiling in furtherance of
decisions that produce legal or similarly significant effects. We do not currently engage
in such automated decision-making or profiling. - Right to Limit Use of Sensitive Personal Information (California Residents): You have the
right to limit our use and disclosure of your Sensitive Personal Information. As stated, we
will obtain your consent before collecting and processing such data. - Right to Non-Discrimination: We will not discriminate against you for exercising any of
your privacy rights.
How to Exercise Your Rights and Appeal
To exercise the rights described above, please submit a verifiable consumer request to us by contacting the Privacy Office via mail or email as detailed in the “Contact Us” section. We will verify your request by asking you to provide information that matches our records. Only you, or a person legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information.
If we deny your request, you may have the right to appeal our decision. To appeal, please contact the Privacy Office with the subject line “Rights Request Appeal.” We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
Categories of Personal Information Collected, Used, and Disclosed
We have collected the following categories of Personal Information from you within the last
twelve (12) months. This table uses categories defined by the CCPA but is intended to provide
disclosure for residents of all applicable states.
| Category | Description | Third Parties that may recieve |
|---|---|---|
| Personal Identifiers | Personal unique identifiers, such as full name and federal or state issued identification numbers and Social Security Number |
|
| Personal Information | Personal Information, including contact details such as telephone number and address, financial information such as account number and balance, as well as medical and health insurance information |
|
| Purchase Information | Purchase information, such as products and services obtained and transaction histories |
|
| Internet or Online Information | Internet or online information such as browsing history, and information regarding interaction with our websites, applications, or advertisements |
|
| Geolocation Data | Geolocation data, such as device location |
|
| Audio and Visual Information | Audio, electronic, visual, thermal, olfactory, or similar information, such as call and video recordings |
|
| Employment Information | Professional or employment-related information, such as work history and prior employer |
|
| Education Information | Education information, such as school and related information; and |
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| Inferences | Inferences based on information about an individual to create a summary about, for example, an individual’s preferences and characteristics |
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California’s “Shine the Light” Law
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our
Website that are California residents to request certain information regarding our
disclosure of Personal Information to third parties for their direct marketing purposes. To
make such a request, please contact the Privacy Office. As stated, we do not sell or rent
personal information to third parties for their marketing purposes
Key Changes
| Version | Release Date | Key Changes |
|---|---|---|
| 4.2 | Aug 20, 2026 | Self-service product access clarification; Account and usage data disclosure; Enhanced Sensitive Data treatment explanations |
| 4.1 | Aug 11, 2026 | Added Advertising and Campaign Engagement Data section; Address update |
| 4.0 | Apr 25, 2025 | Expanded data source transparency; International transfer clarification; Added legal basis sections; Updated CCPA/CPRA disclosures; Added definitions for automated decision-making, targeted advertising, sensitive data; De-identified data protection clarification |
| 3.0 | Jan 20, 2025 | Added comprehensive definitions section; Updated U.S. state-specific privacy disclosures; Improved language clarity |
| 2.0 | Apr 25, 2023 | External legal review; Added Definitions section; Separated cookies policy; Clarified collection and use purposes; Added sharing disclosures; Integrated lawful basis (EU/UK) |
| 1.0 | Jan 20, 2021 | Initial Privacy Notice release |