Privacy Policy

Overview

This Privacy Policy describes how we, CorMetrix Inc (referred to as "CorMetrix", "we," "our," or "us"), collect, use, and share your personal information. This Privacy Policy applies to information that we collect when you visit one of our websites (including www.cormetrix.com and other websites and applications (including mobile applications)) (the "Sites"), when you interact with the features of our Sites, when you interact with us through our email, advertising, or social media campaigns and postings or when you use our services ("Services"). By accessing or using our Sites or Services, you agree to this Privacy Policy.

This Privacy Policy clearly describes where we collect information on our behalf, for business purposes, and for our partners.

This Privacy Policy does not apply to employees or job applicants. Our services are not intended for individuals under 16, and we do not knowingly collect personal information from them. We will delete it if we learn that we have collected personal information from them.

This policy is intended to help you understand:

  • Personal Information We Collect, Purpose for Processing & Categories of Third Parties Personal Information is Shared with;
  • How We Collect Personal Information;
  • How We Use and Share Personal Information;
  • Your Rights Under Applicable Law;
  • How We Protect Personal Information;
  • How Long We Retain Personal Information;
  • Your Choices With Respect to Your Personal Information; and
  • How We Can Make Changes to this Policy.

Personal Information We Collect, Purpose for Processing & Categories of Third Parties Personal Information is Shared with

Categories of Personal Information Example Purpose for Processing Categories of Third Parties Shared With
Identifiers Name, email address, unique identifier, online identifier, transaction identifiers, device ID, advertising ID, and IP address • To provide, support and improve our website or services
• To communicate with you about our products and services
• For our own billing and administrative purposes
• For security purposes
• Market and advertise our Services
• For internal training purposes, such as for our sales team
Service Providers
Third Party Partners
Select information in customer records Name, email, address, and telephone number. Our payment processors information is collected about the transactions you make (such as transaction date, payment information, credit card or debit card number and zip code). • To provide, support and improve our website or services
• To communicate with you about our products and services
• For our own billing and administrative purposes
Service Providers
Geolocation Course IP address • To provide, support and improve our website or services
• For security purposes
Service Providers
Commercial information Name, address, telephone number, products or services purchased or considered, and other purchasing or consuming histories • To provide, support and improve our services
• To communicate with you about our products and services
• For our own billing and administrative purposes
Service Providers

How We Collect Personal Information

We collect personal information as follows:

  • Information that you provide us when you fill out forms or questionnaires respond to surveys, provide comments, respond to our emails, or interact with our marketing campaigns and
  • We may collect information through our social media accounts, including your name, email address, username, profile, picture, or interaction with our accounts.

Information We Collect in Connection with Our Services

After establishing a relationship for our services, we may collect the following personal information:

  • Name, email address, account and profile information, telephone number.

How We Use Personal Information

We use information that we collect about you or that you provide to us:

  • To present the Sites and their contents to you, to provide our Services, and to support and improve the Site and our Services;
  • To provide recommendations and customize the Services and your experience with our Services;
  • To validate information about you;
  • For internal research and development purposes;
  • To analyze the Sites and the Services and to estimate audience size or usage;
  • To provide you with information, products, or services that you request or that we think may be of interest to you;
  • To send you technical notices, updates, security alerts, support or administrative messages, and respond to your comments, questions, or other messages or requests.
  • For administrative purposes, such as providing you with notices about your account, processing invoices, responding to support tickets, or other communications;
  • To carry out our legal obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • To notify you about changes to our Sites or the Services;
  • To investigate misuse or misconduct relating to the Sites or Services;
  • To help protect you, our service providers, and others from fraud, malicious activity, and other privacy and security-related concerns;
  • For other notified purposes with your consent or at your direction; or
  • To allow you to participate in interactive features on the Sites or Services.

How We Share Personal Information

We share personal information with the following categories of third parties:

  • Service Providers: Service providers (e.g., data analytics, marketing, cloud storage, software development, infrastructure, information security, support, billing, or other service providers);
  • Marketing Service Providers: With third parties like analytics providers (e.g., Google Tag Manager and Google Analytics) or social media for marketing and promotional purposes;
  • Analytics and Advertising Partners: With third-party marketing tools, like email campaign providers or social media platform providers;
  • Professional Service Providers: With legal, accounting, and other professional service providers;
  • Legal Authorities: With legal authorities or third parties if we deem necessary to enforce our rights or the rights of third parties (including in connection with your breach of this Privacy Policy or any other agreement between us) or when required by any applicable law, rule regulation, subpoena, or other legal process, or to prevent illegal, harmful, fraudulent, or damaging activities;
  • Corporate Transactions: In connection with the negotiation or execution of a merger or sale of our business or
  • Consent: we may share your information with certain, specified third parties with your consent.

European Data Privacy Rights

We do not currently offer our Service outside of the United States of America and our Service is not recommended for residents of a country other than the United States of America.

U.S. State Privacy Rights

If you are a resident of California, Colorado, Connecticut, Delaware, Indiana, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia, or any other state that has passed data protection legislation, you may have additional rights regarding our use of your personal information. The rights outlined in this section do not apply to information exempted under applicable state privacy law. Further, the rights described in this Section are not absolute, are subject to exceptions and limitations, and may not be afforded to residents of all states. In certain cases, we may decline requests to exercise these rights where permitted by law.

Persons with disabilities may obtain this notice in an alternative format upon request by contacting us using the Contact Us section below.

U.S. Privacy Rights

To the extent you are provided additional privacy rights in the state you reside, you have the following rights with respect to the information that we collect (in each case, subject to applicable law):

  • Right to Know: To know the categories and specific personal information we have collected, the categories and sources from which we collected the personal information, the categories of third parties with whom we share personal information, and the business or commercial purpose for collecting or selling (if applicable) personal information, and the right to request information about and opt out of automated decision making (if applicable).
  • Right to Access: To request a copy of the personal information that we have collected about you during the past 12 months.
  • Right to Opt-Out of Sales or Sharing: To opt out of sales of personal information (if applicable) or sharing personal information for Cross-Contextual Behavioral Advertising.
  • Right to Delete: To request that we delete the personal information that we have collected from you.
  • Right to Correct: To correct inaccurate information that we maintain about you.
  • Freedom from Discrimination: To exercise the rights described above free from discrimination or retaliation as prohibited under applicable law.

Right to Opt-Out of the Sale or Sharing of Personal Information to Third Parties

Sale of Personal Information

Exercising Your State Privacy Rights

If you reside in a state that provides specific data privacy rights, you may contact us using the Contact Us section below.

Your rights may only be exercised by you or by your designated agent. You may submit a request to know twice within a 12-month period unless applicable data privacy law grants you additional rights.

Your request must include enough information to allow us to reasonably verify that you are the person about whom we collected personal information or an authorized representative, which may include: (1) verifying your account information if you have an account with us; or (2) requesting two forms of identification that are reliable for verification purposes, unless the request includes sensitive information and, in which case, we may require additional verification. The information included in your request must allow us to properly understand, evaluate, and respond to it.

We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. If we cannot verify your identity or authority, we will not fulfill your request. We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

You may submit a request through a designated agent. You must instruct that agent that they will need to state that they are acting on your behalf when making the request, have reasonably necessary documentation, and be prepared to provide the necessary personal information to properly verify your request.

We will acknowledge receipt of your request and provide a substantive response within 45 calendar days or inform you in writing of the reason and extension period (up to 90 days).

You may appeal our decision with respect to a request you have submitted by contacting us using the Contact Us section below.

Special Information for Nevada Residents

Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to other companies who will sell or license their information to others. At this time, we do not engage in such sales.

California Shine the Light

Residents of the State of California have the right to request information from us regarding other companies to whom CorMetrix Inc. has disclosed certain categories of information during the preceding year for those companies' direct marketing purposes. If you are a California resident and would like to make such a request, please contact us as described below.

How We Protect Personal Information

We take reasonable steps to protect your personal data from loss, misuse, or unauthorized access, disclosure, alteration, or destruction, taking into account the risks involved in the processing and the nature of the information. However, no website, application, Internet, or email transmission is ever fully secure or error-free, and we do not guarantee the security of any information.

How Long We Retain Personal Information

We retain your personal information for as long as we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).

The criteria used to determine the appropriate retention period for personal information include:

  • The amount, nature, and sensitivity of personal information.
  • The purpose(s) for which the personal information was collected and used.
  • Whether we have a legal obligation to retain personal information or whether retaining personal information is necessary to resolve disputes, including the establishment, exercise, or defense of legal claims.

Your Choices Regarding Your Information

We offer the following choices for updating your information or opting out of other uses of your personal information:

  • Customer Information: If you are an authorized user of our Services, you can sign into your account to update your information.
  • Our Emails: If at any time you would like to unsubscribe from receiving future emails, you can click the unsubscribe link at the bottom of any email or email us at the email address in the Contact Us section below, and we will promptly remove you from all correspondence.
  • Google Analytics: You may manage the information that Google Analytics receives by downloading and installing the browser plugin available here.

Changes to This Policy

We may change this privacy policy from time to time. We will post any changes here, and they will become effective when they are posted. Your continued use of the Sites or our Services or your interaction with us after posting any changes will mean you consent to those changes.

Contact Us

For questions about our privacy practices, contact us via:

Email: compliance@cormetrix.com

Responsibilities

Chief Compliance Officer

Accountable owner of this policy, including revision, updates, and communication. Ensuring CorMetrix's privacy practices effectively meet the requirements and commitments of this policy.

Chief Compliance Officer

Responsible for monitoring, enforcement, and handling any breaches or policy issues.

All Employees

Responsible for reading, acknowledging, and supporting this policy's requirements and reporting any non-compliance to the Chief Compliance Officer.

Exhibit A: Privacy Statement

Introduction

When you use our services, we collect your personal data to support those services. Data privacy is important to us at CorMetrix. This Privacy Policy details how we use personal data and your privacy rights and choices. CorMetrix is a Data Controller responsible for determining the purpose and means of personal data processing.

How We Use Personal Information

We use information that we collect about you or that you provide to us:

  • To present the Sites and their contents to you, to provide our Services, and to support and improve the Site and our Services;
  • To provide recommendations and customize the Services and your experience with our Services;
  • To validate information about you;
  • For internal research and development purposes;
  • To analyze the Sites and the Services and to estimate audience size or usage;
  • To provide you with information, products, or services that you request or that we think may be of interest to you;
  • To send you technical notices, updates, security alerts, support or administrative messages, and respond to your comments, questions, or other messages or requests.
  • For administrative purposes, such as providing you with notices about your account, processing invoices, responding to support tickets, or other communications;
  • To carry out our legal obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • To notify you about changes to our Sites or the Services;
  • To investigate misuse or misconduct relating to the Sites or Services;
  • To help protect you, our service providers, and others from fraud, malicious activity, and other privacy and security-related concerns;
  • For other notified purposes with your consent or at your direction; or
  • To allow you to participate in interactive features on the Sites or Services.

How We Collect Personal Information

We collect personal information as follows:

  • Information that you provide us when you fill out forms or questionnaires, respond to surveys, provide comments, respond to our emails, or interact with our marketing campaigns and
  • We may collect information through our social media accounts, including your name, email address, username, profile, picture, or interaction with our accounts.

Information We Collect in Connection with Our Services

After establishing a relationship for our services, we may collect the following personal information:

  • Name, email address, account and profile information, telephone number.

How We Use Personal Information

We use information that we collect about you or that you provide to us:

  • To present the Sites and their contents to you, to provide our Services, and to support and improve the Site and our Services;
  • To provide recommendations and customize the Services and your experience with our Services;
  • To validate information about you;
  • For internal research and development purposes;
  • To analyze the Sites and the Services and to estimate audience size or usage;
  • To provide you with information, products, or services that you request or that we think may be of interest to you;
  • To send you technical notices, updates, security alerts, support or administrative messages, and respond to your comments, questions, or other messages or requests.
  • For administrative purposes, such as providing you with notices about your account, processing invoices, responding to support tickets, or other communications;
  • To carry out our legal obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • To notify you about changes to our Sites or the Services;
  • To investigate misuse or misconduct relating to the Sites or Services;
  • To help protect you, our service providers, and others from fraud, malicious activity, and other privacy and security-related concerns;
  • For other notified purposes with your consent or at your direction; or
  • To allow you to participate in interactive features on the Sites or Services.

How We Share Personal Information

We share personal information with the following categories of third parties:

  • Service Providers: Service providers (e.g., data analytics, marketing, cloud storage, software development, infrastructure, information security, support, billing, or other service providers);
  • Marketing Service Providers: With third parties like analytics providers (e.g., Google Tag Manager and Google Analytics) or social media for marketing and promotional purposes;
  • Analytics and Advertising Partners: With third-party marketing tools, like email campaign providers or social media platform providers;
  • Professional Service Providers: With legal, accounting, and other professional service providers;
  • Legal Authorities: With legal authorities or third parties if we deem necessary to enforce our rights or the rights of third parties (including in connection with your breach of this Privacy Policy or any other agreement between us) or when required by any applicable law, rule regulation, subpoena, or other legal process, or to prevent illegal, harmful, fraudulent, or damaging activities;
  • Corporate Transactions: In connection with the negotiation or execution of a merger or sale of our business or
  • Consent: we may share your information with certain, specified third parties with your consent.

When we share your personal data

Your personal data may be shared with third parties under one or more of the following scenarios:

  • When your explicit consent is given.
  • When you have been given notice of our intent, plans, or requirements to share it, and you have not provided an objection to disclosure within 30 days.