Colexit Holdings, LLC, (an Arizona registered entity) (“Colexit”, “we” or “us”) respect your right to privacy. This Privacy Policy applies to COLEXIT’s non-European offices and explains how we may collect, share, use and process personal information about you, and how you can exercise your privacy rights. It applies to personal information we collect through our websites (www.Colexit.com and www.Colexit.app), software apps, social media pages, as well as through our marketing activities, services we provide to our clients, live events, any offline business interactions you may have with us, and other activities described in this Privacy Notice (collectively, the “Service”).

We may provide additional or supplemental privacy notices for specific products or services that we offer at the time of collection. Unless otherwise noted, those supplemental notices should be read together with this Privacy Notice.

Table of Contents

1. Personal Information We Collect
2. How and Why We Use Your Personal Information
3. Information Sharing And Disclosure
4. Security
5. Retention
6. Children’s Information
7. Privacy Rights and Choices
8. Notice To California Residents
9. Links To Third Party Services
10. Changes to this Privacy Notice
11. How To Contact Us

 1. Personal Information We Collect

When you use our Service, we collect personal information about your use of our Service and information that you send us.

We may collect and store the following information when running the Service:

• Information You Provide Voluntarily. We collect information that you voluntarily provide to us, including: when you communicate via email or other channels; when you sign up for news, publications and marketing communications and events; when you seek career information; when you register for alumni communications newsletters, alerts, or other materials; when you submit an application for a position with us; when you sign up for a webinar or event; when you respond to our communications or requests for information. The information you provide may include:  your name, address, email addresses, contact information, title, social security number, date of birth, information from your credit report, credit card or banking information used for payment of services, if any, as well as other identifiers and information about the organization with which you are affiliated. If applying for a job with Colexit, the information you provide may also include employment history. We only collect and process the personal information we need to allow us to respond to your request and/or provide the particular service you have sought.
• Information We Collect Automatically. We may automatically collect information about you when you use our Services such as, but not limited to:
  • Device Information. We may collect information about devices you use to access the Services and how you use the Services, such as your Internet Protocol (“IP”) address and which websites you visited before accessing our Services.
  • Performance and Log Data. Our servers may automatically record information created by your use of our Services, which may include information such as, but not limited to, your IP address, browser type, operating system, command line information, diagnostic information related to the Services (e.g., crash activity reports), the referring web page, pages visited, location, your mobile carrier, device and application IDs, and search terms. For instance, when we send you an email, we may collect certain information including the nature of the email, whether you opened or deleted our email, action you took upon receipt of our email, or your name and contact information.
  • Cookies. We use cookies to display information more effectively, store, on a user’s computer or device information about the user’s preferences and settings, gather statistical information about the use of our Services to improve our design and functionality, and for security purposes. Please review our Cookie Notice for more information or click the “Cookie Settings” link in our website footer to update your browser’s cookie preferences for our website at any time.
• Information We Receive From Third Parties. When we receive personal information about you from third parties and use such information, this can include: your name, email address, contact information, the company you work for, your position, business and home address, identification and background information, professional experience and qualifications, previous positions, financial information, such as payment related information and shareholdings, and other personal information.If you connect to us from a social network, such as LinkedIn or Facebook, we will collect personal information from the social network in accordance with your privacy settings on that social network. The connected social network may provide us with information such as your name, profile picture, network, gender, username, user ID, age or age range, language, country, friends list, follower list, and any other information you have agreed it can share or that the social network provides to us. We will assume that such social network or other third parties are entitled to collect and share such personal information with us.

• Sensitive Information. We may collect sensitive information about you when you use our Services. Any use of such information is limited to such purposes described to you at the time of collection.

2. How and Why We Use Your Information

• To Provide Our Services to You. We may process your personal information to inform you about our Services, new company, legal and/or policy developments, relevant information in the industries we serve, and our marketing events. Without your personal information, we cannot provide such Services.
• To Respond to Your Inquiries. We process your personal information when you contact us, such as with questions, concerns, feedback, disputes or issues. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of the Services.
• To Enforce Our Terms or Agreements. We process your personal information to actively monitor, investigate, prevent and mitigate any alleged or actual prohibited, illicit or illegal activities in connection with our Services; investigate, prevent, or mitigate violations of our terms, agreements or policies; and enforce our agreements with third parties and partners. We cannot perform our Services in accordance with our terms, agreements or policies without processing your personal information for such purposes.
• To Ensure the Security of the Service. We are committed to ensuring your safety and continued enjoyment of our Services. To do so, we process your personal information to: combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not access your account with us or your information we otherwise hold. We cannot ensure the security of our Services if we do not process your personal information for security purposes.
• To Personalize Your Experience on the Services. We may provide you with third-party services, plugins, and many other options to personalize your experience of our Services. In addition, we also use cookies and similar tracking technology for such purposes (please see our Cookie Notice for more information or click the “Cookie Settings” link in our website footer to update your browser’s cookie preferences for our website at any time). By personalizing the Services, you get to enjoy our Services even more because we keep track of your preferences (e.g. your language selection, your time zone, etc.). Without processing your personal information for such purposes, you may not be able to access or personalize part or all of our Services.
• For Research and Development Purposes. To continue to provide you with our innovative Services, we collect information about the way you use and interact with our Services for research and development purposes. Research and development help us improve our Services and build new Services and customized features or Services. We take additional security measures when processing your personal information for such purposes, by de-identifying or pseudonymizing your information, limiting access to personnel that may conduct research and development, and applying other technical, physical, and administrative security measures.
• For Potential Employment. We process your personal information when you seek employment with us to evaluate you as a candidate for the position. Without your personal information, we cannot evaluate your qualifications for employment.
• To Engage in Marketing Activities. We process your personal information to inform you about our Services, new legal and policy developments, relevant information in the industries we serve and our marketing events (including by electronic means, such as email). To do so we may process your contact information or information about your interactions on our Services to send you marketing communications; provide you with information about events, webinars, or other materials; deliver targeted marketing to you (please see our Cookie Notice for more information about digital interest-based advertising or click the “Cookie Settings” link in our website footer to update your browser’s cookie preferences for our website at any time); and keep you updated about our Services. You can opt-out of receiving our marketing information at any time by clicking an unsubscribe link in our emails.

3. Information Sharing and Disclosure

We do not sell, exchange, transfer, or give your personal information to any other company or individual for any reason except as set forth in this Privacy Notice and as described below:

• Colexit Affiliated Entities. As an organization that provides services nationwide, we may share your information with offices or data centers in other states.
• Our Service Providers. We share information with our service providers, suppliers, subcontractors, and similar third parties who provide services to us, or act on our behalf so that they can assist us with the maintenance of our Service. Our contracts with these service providers prohibit them from sharing your personal information with others for other purposes than as directed by us.
• Corporate Reorganization. We may transfer information to a third party in case of the reorganization, sale, merger, joint venture, assignment, transfer or other disposition of all or any portion of our business, asset or stocks, including in the event of corporate restructuring. We reserve the right, as part of this transaction, to transfer or assign personal information we have collected from you to these third parties. Except as otherwise provided by a bankruptcy or other court, the use and disclosure of all personal information will be subject to policies that are consistent with the policies described in this Privacy Notice. However, any personal information that is submitted or collected after that transfer may be subject to a new privacy policy adopted by the successor entity.
• Legal Concerns or Liabilities. We may use, share, or disclose information about you in order to address legal concerns or liabilities, especially when we believe, in our sole discretion, that (a) you might have misused the Services, such as to gain unauthorized access to any system, engaged in spamming, denial of service attacks, or similar attack; (b) disclosure is reasonably necessary to enforce our Terms Of Use; (c) to respond to suspected illegal or fraudulent activity; (d) to protect legal rights or defend against legal claims; (e) to allow us to pursue available remedies or limit the damages that we or a third party may sustain.
• Your Consent. We will disclose your information to a person you have given us your consent to disclose to or as required to complete the Services.

4. Security

We seek to use reasonable technical, organizational, and administrative measures to protect user information within our organization against unauthorized or unlawful access or processing, and against accidental loss, destruction, or damage. We believe that these measures are reasonably adapted to the nature of the information in our custody. In addition to the security measures detailed above, we protect personal information by taking measures: (i) to protect the ongoing confidentiality, integrity, availability, and resilience of our processing systems and services; (ii) to restore the availability of and access to personal information in a timely manner in the event of a physical or technical incident; and (iii) to regularly test, assess, and evaluate the effectiveness of our technical and organizational measures.

However, even though Colexit makes reasonable efforts to protect information in its custody, no security system or data storage or transmission over the Internet or otherwise is fully secure. Thus, we cannot guarantee the security of any information we may have collected or received from you or transmitted to you.

You acknowledge that transmissions to and from the Website, including emails, are not confidential and your communications may be read or intercepted by others. Any unprotected e-mail communication over the Internet is subject to possible interception or loss, is not confidential and is also subject to possible alteration. We are not responsible for and will not be liable to you or any third party for damages in connection with an e-mail sent by you to us or an e-mail sent by us to you, or anyone you designate, at your request. Violators of this section who use our services for any illegal purpose including but not limited to repeated unwanted emails or “Spam,” may be prosecuted to the full extent of the law. You acknowledge that by submitting communications to Colexit, no confidential, fiduciary, contractually implied or other relationship is created between you and Colexit other than pursuant to the Website Terms and any subsequent written agreement entered into with Colexit.

You are solely responsible for (a) maintaining the confidentiality and security of your login information, passwords, and any other security or access information used by you or anyone you authorize on your behalf to access the Website and your account information, (b) preventing unauthorized access to or use of the information, files, or data that you store or use in or with Colexit’s Website, (c) all electronic communications, including account registration and other account holder information, email and financial, accounting and other data entered using the Colexit Website, and (d) without limiting the foregoing, any and all activities that occur under your account. Colexit will assume that any communications received through the use of the Colexit Website was sent or authorized by you. You agree to immediately notify Colexit if you become aware of any loss, theft, or unauthorized use of the Colexit Website or your account information.

Please do not use the information on our Website to distribute unsolicited bulk e-mails, solicitations or inquiries. The foregoing acts will constitute a violation of the Website Terms.

If you believe your information is not secure, please immediately notify us of the problem at the address provided in the “How to Contact Us” section below.

5. Retention

We retain information about you for as long as necessary to perform the activities described in this Privacy Notice, or where we have an ongoing legitimate business need to do so, such as for legal, regulatory, accounting or reporting requirements.

When our legitimate interest for retaining your personal information ceases to exist, we will either delete or anonymize your information so that it can no longer be attributed to a particular individual. To the extent residual information remains within our databases, back-ups or other records and we are unable to anonymize it we will isolate such information from further processing until deletion is possible. If you have any questions, please feel free to contact us.

6. Children’s Information

We do not knowingly collect any personal information from children under 18. If we become aware that an individual under the age of 18 is submitting information without consent from their parent or legal guardian or as permitted under applicable law, we will delete the information as soon as possible from our database. If you believe we are collecting information about an individual under 16, please notify us immediately so that we can take appropriate action.

7. Notice to California Residents

The California Consumer Privacy Act of 2018, as amended by the Consumer Privacy Rights Act of (“CCPA”), requires us to explain the “Personal Information” categories, as identified and defined by the CCPA (see California Civil Code section 1798.140(o)), that we collect, the reason we collect the Personal Information, where we obtain the Personal Information, and the other entities with whom we may share the Personal Information. Under the CCPA, Personal Information is defined as any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”).

We generally collect the following categories of Personal Information in providing our Services:

• identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with your devices;
• characteristics of protected classifications under California or federal law, such as gender;
• commercial information such as records of products or services purchased, obtained, or considered by you;
• Internet or other electronic information regarding you browsing history, search history, the webpage visited before you came to our website, lenColexith of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;
• professional or employment-related information;
• your geolocation, to the extent you have configured your device to permit us to collect such information; and
• inferences about your preferences, characteristics, behavior and attitudes.

For more information about the Personal Information we collect and how we collect it, please refer to section 1 above, and our Cookie Notice.

We collect Personal Information for the business purposes described in section 2 above, and in our Cookie Notice. The CCPA defines a “business purpose” as the use of Personal Information for the business’s operational purposes, or other notified purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or another operational purpose that is compatible with the context in which the Personal Information was collected.

The categories of other individuals or entities with whom we may share your Personal Information are listed in section 4 above.

To the extent Colexit works with any separate legal entities that may be considered “third party affiliated entities” for purposes of California Civil Code Section 1798.83. California law requires us to inform California residents who have provided us with personal information that they may request of us information about our disclosures to third parties (including Colexit Affiliated Entities) for their direct marketing purposes. To do so, contact us at privacy@colexit.com and indicate in the subject line “California Privacy Rights.”

Do Not Track.  Please note that we do not currently respond to web browser “do not track” signals or other mechanisms that may allow you to opt out of the collection of information across networks of websites and online services as there is no standard for how online services should respond to such signals.

8. Links To Or From Third Party Services

Our Service may include links to third party services where you might be able to post comments, reviews, or view third party information. Please note, the inclusion of a link on our Service to a third party’s service does not imply endorsement of the third party’s data handling practices, and does not imply that the third party’s practices are covered by this Privacy Notice. We are not responsible for the privacy practices of these entities.

9. Changes to this Privacy Notice

We may update this Privacy Notice from time to time. The effective date of the current Privacy Notice is noted at the top of this page.

If we make material changes to the way we collect, use, share or process the personal information that you have provided that adversely impact you, we will notify you by posting it on the Service or other appropriate means. Any modifications to this Privacy Notice will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Notice indicates your acknowledging that the modified content of the Privacy Notice applies to your interactions with the Service and our business.

10. How to Contact Us

You can contact us via email at privacy@colexit.com If you prefer to contact us by postal mail, and you are in the United States or in any country other than the countries listed in the chart below, please contact us at: Insert address we will use.