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Privacy Policy

LAST UPDATED: July 14, 2023

Welcome to Cacilian! Cacilian is provided by Cacilian, LLC (collectively referred to herein as “we,” “us,” “our,” or “Cacilian”). We respect your privacy and the importance of the information you entrust to us. With this in mind, we provide you this privacy policy (the “Policy”) to help you understand the kinds of information we may gather about you when you use our online and/or mobile services, website, and software provided by or in connection with the service (collectively the “Services”), how we may use and disclose the information, and how you can control, correct and/or update the information. By accessing or using the Services, you are accepting the policies and practices described in this Policy. Each time you visit or use the Services, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Policy. This Policy shall be read in conjunction with our Terms of Service and all the relevant provisions of the Terms of Service (including but not limited to indemnification, limitation of liability, governing law and dispute resolution) shall mutatis mutandis apply to this Policy and be deemed to be incorporated herein by reference. Any capitalized terms not defined herein shall have the meaning as set forth in the Terms of Service.

Please note that this Policy does not apply to your use of third-party sites, services, or applications you may access through the Services. We encourage you to review the privacy policies of those third parties for more information regarding their privacy practices.

INFORMATION WE MAY COLLECT

  • Information You Provide to Us
    • We collect information you provide directly to us when using the Services. For example, we collect information when you download our mobile application(s), register for our Services, sign up for an Account, complete a form, participate in any interactive features of the Services, request customer support, or otherwise communicate with us. The types of information we may collect include your name, email address, mailing and billing address and payment information, and any other information you choose to provide. For purposes of registering and using the Services, we collect certain information that can identify you, such as your name and contact information (email, address and phone number) (“Personal Information”). We will never sell, rent, or trade your Personal Information or use Personal Information other than as needed to provide the Services requested by you. If you choose not to provide information that is necessary to provide the Services, you may not be able to use certain aspects or all of the Services. Cacilian discloses Personal Information only to those of its employees, contractors and affiliated organizations that (i) need to know the information in order to process it on yours and our behalf, and (ii) that have agreed in writing to non-disclosure restrictions at least as strong as those herein. We also may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). We may associate your device identifiers or phone number with your account. Depending on the nature of your inquiry or activities on the Services, we may also ask for other information relevant to your use of the Services.

You acknowledge and agree that communications, including phone calls or “chat” services, with Cacilian or our third-party agents may be monitored, recorded and retained by Cacilian. You consent to the monitoring and recording of all conversations between you and Cacilian and you release us from and against any and all claims, liabilities and losses that may result from any such monitored and/or recorded conversations.

  • Information We Collect Automatically When You Use the Services

When you access or use the Services, we automatically collect information about you, including the following:

    • Log Information: We log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to the Services. Publicly available tools can sometimes provide the approximate location for IP addresses.
    • Device Information: We collect information about the computer or mobile device you use to access the Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
    • Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored in device memory that help us to improve the Services and your experience, see which areas and features of the Services are popular, and count visits. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in the Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon.

We also may collect other types of information in the following ways when you use the Services:

    • Details of how you used and interacted with the Services, such as your search queries and how you responded to certain questions.
    • Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
    • Our server logs automatically collect information, such as your IP address, your browser type and language, and the date and time of your visit, which helps us track your movements around the Services and understand trends.
  • Information We Collect From Other Sources
    • We may also obtain information from other sources and combine that with information we collect through the Services. For example, we may collect information about you from third parties who provide services on our behalf, such as maintaining and monitoring usage of the Services and processing payment transactions. We also may receive information about you from the third parties with whom you interact through the Services.

USE OF INFORMATION

We may use information about you for various purposes, including the following:

  • Provide, maintain, improve and deliver the products and Services you request, process transactions, and send you related information;
  • Verify your identity and, if applicable, authorization for you to use the Services;
  • Facilitate use of the Services;
  • Process payment for Services;
  • Analyze and draw trends from the aggregated statistics of the User activity;
  • Provide personalized recommendations and maintain general and personalized content;
  • Manage your account and your preferences;
  • To prevent or address service, security, technical issues at your request in connection with customer support matters;
  • Respond to your comments, questions, and requests;
  • Send you technical notices and other administrative messages;
  • Communicate with you about products, services, offers, promotions, rewards, and events offered by us or others, and provide news and information we think will be of interest to you;
  • Monitor and analyze trends, usage, and activities in connection with security-related initiatives and the Services;
  • Conduct research, analysis, and surveys;
  • Personalize and improve the Services and provide content or features that match user profiles or interests;
  • Enforce our Terms;
  • Link or combine with information we get from others in connection with the Services; and
  • Carry out any other purpose for which the information was collected.

This policy is not intended to place any limits on what we do with data that is aggregated and/or de-identified so it is no longer associated with an identifiable user of the Services. In other words, information about how you use the Services may be collected and combined with information about how others use the same Services, but no personally identifiable information will be included in the resulting data.

SHARING OF INFORMATION

We may share or transfer information about you as follows or as otherwise described in this Privacy Policy:

  • With third party affiliates, contractors, and other service providers in connection with providing the Services;
  • With affiliates, contractors, and other service providers who need access to such information to carry out work on our behalf;
  • We will share information that we identify about security risks and/or incidents that affect or relate to our customers with those customers.
  • In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation;
  • If we believe your actions are inconsistent with the spirit or language of our Terms of Service or policies, or to protect the rights, property, and safety of you, us, or others and to enforce the provisions of our Terms of Service or policies, in cases of fraud or disputes, and/or to prevent harm to you or others;
  • In connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company;
  • With your consent or at your direction, including if we notify you through the Services that certain information you provide will be shared in a particular manner and you provide this information.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. This includes but is not limited to sharing information related to the research we conduct with various research and security organizations, including academic institutions or publications, as well as publishing our research online on our website or through third party social media sites.

THIRD PARTY PAYMENT SERVICES

We do not directly process any payments and do not store Your debit/credit card information. As detailed further in the Terms of Services, we use a third-party Payment Processor to bill You for our services. Secured socket layer technology is used for processing payment transactions with the Payment Processor. Payment processing shall be subject to the terms and conditions and privacy policy of the Payment Processor. For these third party service providers, we recommend that You read their privacy policies in order to understand the manner in which Your User Information and Your credit/debit card details will be handled by these providers.

ANALYTICS SERVICES

We may allow others to provide analytics service in connection with the Services, such as, and Google Analytics

These entities may use cookies, web beacons, and other technologies to collect information about your use of the Services, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. We and others may use this information to, among other things, analyze and track data, determine the popularity of certain content, personalize the user experience, and better understand your activity.

To learn more about Google Analytics, please visit https://policies.google.com/privacy.

SECURITY

We work hard to protect your information and take appropriate commercially reasonable physical, electronic, and other security measures to help safeguard personal information from loss, unauthorized access, alteration, or disclosure regardless of how or where it is stored. Our security practices include: encrypting many of our services using SSL; verification for account access; and frequent review of information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. However, no internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email.

PRIVACY POLICY CHANGES

Cacilian reserves the right to change, modify, add, or remove portions of this Policy at any time and without prior notice, and any changes will become effective immediately upon being posted unless we advise you otherwise. However, we will not use your Personal Information in a way that is materially different than the uses described in this Policy without giving you an opportunity to opt out of such differing uses. Your continued use of the Services after this Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Policy, as amended. We encourage you to review this Policy regularly.

CALIFORNIA PRIVACY RIGHTS

California law provides California residents (as defined in Section 17014 of title 18 of the California Code of Regulations) (“Consumer”) with specific rights regarding information that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (some of which may also constitute Personally Identifiable Information). The California Consumer Privacy Act of 2018 (“CCPA”) refers to such information as “personal information”. This section describes the rights that California Consumers have and explains how to exercise those rights, subject in all cases to any limitations set forth in the CCPA.

Cacilian shall comply with the California Consumer Privacy Act of 2018, Cal. Civil Code § 1798.100 et seq., (“CCPA”), which may be amended from time to time. Per the terms of the CCPA, Cacilian is a Service Provider and not a Third Party as described in the CCPA. Therefore, Cacilian shall not:

  1. Sell the Personal Information.
  2. Retain, use, or disclose the Personal Information for any purpose other than providing the Services or for a Business Purpose. Specifically, Cacilian shall not retain, use, or disclose the Personal Information for a Commercial Purpose.
  3. Retain, use, or disclose the Personal Information outside of the direct business relationship between Cacilian and its Users.

Notwithstanding anything in the Terms of Service or any related order form or other document, the parties acknowledge and agree that a User’s provision of Personal Information is not part of and explicitly excluded from the exchange of consideration, or any other thing of value, between the parties.

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to support@Cacilian.com.

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. However, we may retain personal information that has been de-identified or aggregated. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions set forth under the CCPA, such as detecting security incidents and protecting against fraudulent or illegal activity.

To exercise the access and deletion rights described above, please submit a request to us by emailing us at support@Cacilian.com. Only you, or a person or business entity registered with the California Secretary of State that you authorize to act on your behalf (an “authorized agent”), may make the requests set forth above. The request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide sufficient information that allows us to reasonably verify that you are the person about whom we collected the personal information or an authorized representative of that person.

We will respond to consumer requests in a reasonably timely manner. If we require extra time to respond, we will inform you of the reason and extension period in writing. In order to protect the security of your personal information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. The method used to verify your identity will depend on the type, sensitivity, and value of the information, including the risk of harm to you posed by any authorized access or deletion. Generally speaking, verification will be performed by matching the identifying information provided by you to the personal information that we already have. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request (and will not be made more than twice in a 12-month period). If we cannot comply with a request, or cannot fully comply with a request, the response we provide will also explain the reasons we cannot comply.

We do not sell your Personal Information or any information that may be used to identify you.

CHILDREN UNDER THE AGE OF 13

The Services are intended for users who are eighteen (18) years of age and older. If you are under the age of 13, you are not permitted to submit any Personal Information to us. If you believe we might have any information from or about a child under 13, please contact us at support@Cacilian.com.

RETENTION

We will retain your Personal Information for the period of time that is necessary to fulfil the original purposes for which it has been collected. Please keep in mind that, in certain cases, a longer retention period may be required or permitted by law or to allow us to pursue our business interests, conduct audits, comply with our legal obligations, enforce our agreements or resolve any dispute.

The criteria used to determine our retention periods include:

  1. Time needed to provide you with our Services.
  2. Whether your account with us is active. You may contact us to make your account inactive at any time.
  3. Legal, contractual, or similar obligations to retain your data, such as mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of contract or litigation.

Please note that we are not responsible for storing any information that you provide to us or for any content or information that we provide to you. You are solely responsible for retaining backup files of any information and content that you provide or receive in connection with the Services.

TRANSFER OF PERSONAL INFORMATION; INTERNATIONAL VISITORS

The Services are provided from the United States. If you are located outside of the United States, any information you provide to us may be transferred out of your country and into the United States. You understand that data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States. Personally identifiable information collected through the Services may be stored and processed in the United States or, if and as applicable for international Users, any other country in which Cacilian or its affiliates, subsidiaries or service providers maintain facilities. If your Personal Information is transferred to a country other than your home country, we will take measures to protect it with appropriate contract clauses or other applicable safeguards.

If you are an international visitor, you acknowledge that by providing your Personal Information, you are: (a) permitting the transfer of your Personal Information to the United States which may not have the same data protection laws as the country in which you reside; and (b) permitting the use of your Personal Information in accordance with this Privacy Policy.

Subject to local law, you may also have certain rights regarding information that we have collected and that is related to you. For example, if you are located in the European Union with rights under the General Data Protection Regulation (“GDPR”), you have the right to withdraw previously provided consent for our processing of your “personal data” as such term is defined under the GDPR, by contacting us at support@Cacilian.com. Such individuals also have the following rights:

Right to access – In accordance with Article 15 of the GDPR, this right allows individuals to obtain confirmation as to whether or not personal data concerning him or her is being processed and provides access to such personal data. It also allows individuals to request details of the processing of his or her personal data, including, without limitation, categories of recipients to whom the personal data has been or will be disclosed and the purposes of the processing.

  • Right to rectify – In accordance with Article 16 of the GDPR, this right allows individuals to rectify any inaccurate personal data about him or her.
  • Right to restrict processing – This right allows individuals to block or suppress processing of personal data under certain circumstances in accordance with Article 18 of the GDPR.
  • Right to be forgotten – This right is also known as the “right to erasure.” In accordance with Article 17 of the GDPR, it is an individual’s right to have personal data erased or to prevent processing in specific circumstances.
  • Right of data portability – In accordance with Article 20 of the GDPR, this right allows individuals to move, copy or transfer personal data from one place to another in a secure manner without interrupting the integrity and usability of the information.
  • Right to object to processing – In accordance with Article 21 of the GDPR, this right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.
  • Right to withdraw your consent - You shall have the right to withdraw your consent at any time with regard to the processing of the User Information in accordance with Article 7 para. 3 GDPR.
  • Right to lodge a complaint - You may lodge a complaint with the supervisory authority in accordance with Article 77 para. 1 of the GDPR, if you feel that the processing of the data relating to you infringes the GDPR.
  • Right to effective judicial remedy - You shall have the right to an effective judicial remedy where You consider that Your rights under the GDPR have been infringed as a result of the processing of Your personal data and the same is in non-compliance with the GDPR.

Legal Bases for Processing: We rely on the following legal basis to process your personal data: (i) it may be necessary for us to use and disclose your personal data for the performance and fulfillment of the contract between us and to provide you with our Services; (ii) if you specifically consent to certain uses of your personal data, we may use your personal data in a manner consistent with that consent; and (iii) we will also process, transfer, disclose and preserve personal data when we have a good faith belief that doing so is necessary.

To exercise any of the above rights, or if you have any questions or comments about the Policy or our privacy practices, please contact us at support@Cacilian.com.

OPTIONS

Your Information

We use reasonable processes to ensure compliance with this privacy policy and periodically verify that the policy is accurate. We encourage you to raise any concerns by contacting us at support@Cacilian.com, and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of information. Unless legal restrictions apply, you have the right to access the information we hold about you free of charge. You may update, correct or delete your information at any time by contacting us at support@Cacilian.com. You can help us maintain the accuracy of your information by notifying us of any changes. To avoid delays in obtaining your information, please provide sufficient detail to permit us to identify you and the specific information that you are requesting. We will respond to your request within 30 days of receipt, unless we inform you that it will take longer, as permitted by law under certain circumstances. Please note that there may be instances where access

may be restricted as permitted or required by law. We will advise you of the reasons for restricting access subject to any legal or regulatory limitations. In addition, please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period. Please note that we are not responsible for storing any information that you provide to us or a third party or for any content or information that we or a third party provide to you. You are solely responsible for retaining backup files of any information and content that you provide or receive in connection with the Services.

Promotional Communications

By providing Personal Information to us, you expressly consent to receive messaging and information from us. You may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us atsupport@Cacilian.com. If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations.

Please note that we do not respond to or honor 'do not track' (a/k/a DNT) signals or similar mechanisms transmitted by web browsers. If you have consented to have your Personal Information shared with any third party and you no longer wish to have your Personal Information shared with such parties, then you may opt-out of such disclosures by sending an email to support@Cacilian.com. However, we are not responsible for removing your Personal Information from the lists of any third party who has previously been provided with your information in accordance with this privacy policy or your separate consent.

Please note that there might be a brief delay between when you submit your request to 'opt-out' and when it is processed and reflected in our systems; accordingly, you may continue to receive communications from us for a limited time after you unsubscribe. We appreciate your patience.

Non-Discrimination

We will not discriminate against you because you elect to exercise any of the rights related to your Personal Information, including but not limited to:

Denying you products or Services;

Charging you different prices or rates for Services, including through the use of discounts or other benefits or imposing penalties on you;

Providing a different level or quality of Services to you; or

Suggesting that you will receive a different price or rate for Services or a different level or quality of Services.

HOW TO CONTACT US

If you have any questions about this Policy, or our information practices, please contact us by email at support@Cacilian.com.

LAST UPDATED: July 14, 2023