PRIVACY POLICY

WEBSITE PRIVACY POLICY

This Policy was last updated on August 16, 2019.

INTRODUCTION

KANAVA® International, LLC (referred to herein as “KANAVA,” “we,” “us,” and “our”) is committed to protecting the privacy and security of the personal information we collect, use, share and otherwise process as part of our business. We also believe in transparency, and we are committed to informing you about how we treat identifiable information relating to individuals (“personal information”).

We have established this Privacy Policy to inform you about the privacy practices that we apply to personal information for the activities listed below.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND WHAT CHOICES AND RIGHTS YOU HAVE IN THIS REGARD. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE SITE OR ENGAGE IN COMMUNICATIONS WITH US CONCERNING OUR SERVICES OR PRODUCTS.

This Privacy Policy applies to personal information we collect when you:

Visit our website, kanavainternational.com (the “Site”);
Receive electronic communications from us, including emails, etc.; and
Request information from us online.

WHAT INFORMATION DO WE COLLECT?

We may collect and process the following personal information from you for the purposes set forth below:

  
      Category
      Types of Data and Purpose
    
      Contact Information
      When you visit the Site or request our services, we may ask you for your name, address, telephone number, email address, or other contact details in order to respond to your request or inquiry.
    
      Business Information
      When you seek services from us in the course of contractual or customer relationships between you, your organization, and us, we collect business contact information and other personal information in order to provide you with the services you have requested.
    
      Cookies and Similar Technologies
      When you visit the Site, we collect cookies and use similar technologies to enhance your experience, gather general visitor information, and track visits to the Site, all in order to provide you with a more personal and interactive experience on the Site, to improve our marketing efforts, and for usage analytics purposes (e.g., page response times, download errors, length of visit, webpages visited, etc.).

Please see the “Cookies and Similar Technologies” section of this Policy for additional information.  If you choose to disable cookies and similar technologies, some areas and features of the Site may not work properly.

      Automated Information
      When you visit the Site, we automatically collect information from your browser or your mobile device, which includes the date and time of your visit, your Internet Protocol (IP) address or unique device identifier, domain server, your browser type, cookies and data about which pages you visit in order to allow us to operate and provide the Site and our services.  This information is used to understand how you interact with the Site and to provide you with advertising and a more personalized experience.  To learn more about our collection of technical data, please see the “Cookies and Similar Technologies” section of this Policy.
    
      Feedback / Support / Inquiries
      If you provide us with feedback or contact us for support or to ask us questions, we will collect your name, address, telephone number, email address, and other information needed to respond to your feedback, or request for support, or to answer your question.
    
      Your Communications
      When you communicate with us, we may retain your communications in order to process and respond to them, as well as to improve our services. We may use your email address to communicate with you about our services or send you periodic emails if you decide to opt-in to any of our mailing lists. If at any time you would like to unsubscribe from receiving future emails, you may unsubscribe using the link at the bottom of each email.
    
      Location Information
      When you use the Site, we may collect information about your use of the Site, including your interaction with advertising and analytics services on the Site, in order to (a) serve you the content and functionality you request, and (b) maintain the privacy and security of the Site and services.  Location information collected may include your Internet Protocol (IP) address or unique device identifier.
    
      Email Interconnectivity
      If you receive email communications from us, we may use certain tools to capture data related to if/when you open our message and if/when you click on any links or banners it contains.  Other information collected through this email tracking feature includes: your email address, the date and time of your “click” on the email, a message number, the name of the list from which the message was sent, a tracking URL number, and a destination page.  We use this information to enhance our marketing efforts.  We do not sell or distribute this information to third parties.
    
      Mailing List
      When you sign up for one of our mailing lists, we collect your contact information, including your email address.
    
      Third Party Information
      In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly-available sources.

Category	Types of Data and Purpose
Contact Information	When you visit the Site or request our services, we may ask you for your name, address, telephone number, email address, or other contact details in order to respond to your request or inquiry.
Business Information	When you seek services from us in the course of contractual or customer relationships between you, your organization, and us, we collect business contact information and other personal information in order to provide you with the services you have requested.
Cookies and Similar Technologies	When you visit the Site, we collect cookies and use similar technologies to enhance your experience, gather general visitor information, and track visits to the Site, all in order to provide you with a more personal and interactive experience on the Site, to improve our marketing efforts, and for usage analytics purposes (e.g., page response times, download errors, length of visit, webpages visited, etc.). Please see the “Cookies and Similar Technologies” section of this Policy for additional information. If you choose to disable cookies and similar technologies, some areas and features of the Site may not work properly.
Automated Information	When you visit the Site, we automatically collect information from your browser or your mobile device, which includes the date and time of your visit, your Internet Protocol (IP) address or unique device identifier, domain server, your browser type, cookies and data about which pages you visit in order to allow us to operate and provide the Site and our services. This information is used to understand how you interact with the Site and to provide you with advertising and a more personalized experience. To learn more about our collection of technical data, please see the “Cookies and Similar Technologies” section of this Policy.
Feedback / Support / Inquiries	If you provide us with feedback or contact us for support or to ask us questions, we will collect your name, address, telephone number, email address, and other information needed to respond to your feedback, or request for support, or to answer your question.
Your Communications	When you communicate with us, we may retain your communications in order to process and respond to them, as well as to improve our services. We may use your email address to communicate with you about our services or send you periodic emails if you decide to opt-in to any of our mailing lists. If at any time you would like to unsubscribe from receiving future emails, you may unsubscribe using the link at the bottom of each email.
Location Information	When you use the Site, we may collect information about your use of the Site, including your interaction with advertising and analytics services on the Site, in order to (a) serve you the content and functionality you request, and (b) maintain the privacy and security of the Site and services. Location information collected may include your Internet Protocol (IP) address or unique device identifier.
Email Interconnectivity	If you receive email communications from us, we may use certain tools to capture data related to if/when you open our message and if/when you click on any links or banners it contains. Other information collected through this email tracking feature includes: your email address, the date and time of your “click” on the email, a message number, the name of the list from which the message was sent, a tracking URL number, and a destination page. We use this information to enhance our marketing efforts. We do not sell or distribute this information to third parties.
Mailing List	When you sign up for one of our mailing lists, we collect your contact information, including your email address.
Third Party Information	In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly-available sources.

COOKIES AND SIMILAR TECHNOLOGIES

A “cookie” is a small file created by a web server that can be stored on a user’s device for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” cookie). This file is set by the site or its service provider, and it is transferred to your computer’s hard drive through your web browser (if you allow). Cookies enable the site’s or service provider’s systems to recognize your browser and capture and remember certain information.

The information collected may include information about your Internet Protocol (IP) address, browser type, internet service provider (ISP), domain server, type of computer, type of web browser, URLs of any referring or exited webpages, operating system, and/or date and time stamps. We use cookies as outlined below and to help compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

First-Party Cookies

First-party cookies are set by the website you are visiting, and they can only be read by that site. Certain features of our Site use session, persistent, and/or flash cookies as outlined in the table below.

“Session” cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session or after a set time period. “Permanent” cookies remain stored on a user’s hard drive until they expire or are deleted by a user. Local stored objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. Flash cookies are not managed by the same browser settings as browser cookies. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website at:

https://www.macromedia.com/support/documentation/en/flashplayer/help/help09.html.

Third Party Cookies

You also may encounter third-party cookies on the Site, as outlined in the table below. Third Party Cookies are cookies that are stored on your web browser by a party other than us and may gather browsing activity (such as information you have entered or choices you have made) across numerous websites that you visit and across numerous browsing sessions. These cookies also help us to improve how the Site and services function and perform, to customize your interactions with the Site, and to provide more relevant messaging and marketing communications. We are currently using third-party cookies to track and analyze usage as outlined in the table below.

If you wish to delete Third Party Cookies, you should adjust your browser settings as described in the “Rights and Choices about How We Use and Disclose Your Information” section of this Policy.

Similar Technologies

In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as users navigate through and interact with the Site:

Web beacons: These are tiny graphics (sometimes called “clear GIFs” or “web pixels”) with unique identifiers that are used to understand browsing activity. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are rendered invisible on web pages when you open a page.
Social Widgets: These are buttons or icons provided by third-party social media providers that allow you to interact with social media services when you view a web page or mobile app screen. These social widgets may collect browsing data, which may be received by the third party that provided the widget and are controlled by third parties.
UTM Codes: These are strings that can appear in a URL (the “Uniform Resource Locator,” which is typically the http or https address entered to go to a web page) when a user moves from one web page or website to another, where the string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.

The aggregate data collected by these passive technologies typically does not target any personal information, but personal information may be linked to information stored in and obtained through these technologies in order to improve our marketing, analytics, or website functionality.

What Cookies Are In Use and Why Do We Use Them?

As detailed below, we use cookies to enable certain website functions, develop web browsing analytics, store and track your preferences, and enable the delivery of advertising and marketing, when applicable. For example, we may track the number of “hits” or visits to the Site, the most popular times of day and sections visited, and the range of devices and browsers most commonly used to view the Site. We do not sell or distribute any of this information to third parties.

  
      Cookie
      Description
      Duration
      Type
    

  
      crumb
      Prevents cross-site request forgery (CSRF). CSRF is an attack vector that tricks a browser into taking unwanted action in an application when someone’s logged in.
      Session
      Functional & Required
    

      ss_cookieAllowed
      Remembers if a visitor agreed to placing Analytics cookies on their browser if a site is restricting the placement of cookies
      30 Days
      Analytics & Performance
    

      ss_cid
      Ensures that visitors on the Squarespace 5 platform remain authenticated during their sessions
      2 Years
      Analytics & Performance
    

      ss_cpvisit
      Identifies unique visitors and tracks a visitor’s sessions on a site
      2 Years
      Analytics & Performance
    

      ss_cvisit
      Identifies unique visitors and tracks a visitor’s sessions on a site
      30 Minutes
      Analytics & Performance
    

      ss_cvr
      Identifies unique visitors and tracks a visitor’s sessions on a site
      2 Years
      Analytics & Performance
    

      ss_cvt
      Identifies unique visitors and tracks a visitor’s sessions on a site
      30 Minutes
      Analytics & Performance
    

Cookie	Description	Duration	Type
crumb	Prevents cross-site request forgery (CSRF). CSRF is an attack vector that tricks a browser into taking unwanted action in an application when someone’s logged in.	Session	Functional & Required
ss_cookieAllowed	Remembers if a visitor agreed to placing Analytics cookies on their browser if a site is restricting the placement of cookies	30 Days	Analytics & Performance
ss_cid	Ensures that visitors on the Squarespace 5 platform remain authenticated during their sessions	2 Years	Analytics & Performance
ss_cpvisit	Identifies unique visitors and tracks a visitor’s sessions on a site	2 Years	Analytics & Performance
ss_cvisit	Identifies unique visitors and tracks a visitor’s sessions on a site	30 Minutes	Analytics & Performance
ss_cvr	Identifies unique visitors and tracks a visitor’s sessions on a site	2 Years	Analytics & Performance
ss_cvt	Identifies unique visitors and tracks a visitor’s sessions on a site	30 Minutes	Analytics & Performance

What similar technologies are in use and why do we use them?

As detailed below, we use the following data collection technologies, Internet tags, web beacons (clear gifs., pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) in order to improve website functionality and analytics:

Technology	Data Collected	Uses of Data
Typekit by Adobe	Usage information about the fonts being served on our website	We use Typekit by Adobe to enhance the Site’s typography. Adobe uses cookies within Typekit to track usage statistics.
Squarespace Analytics	Statistical data about the number of people using the Site, including: the number of visits, page views, and unique users; the traffic source (where visitors come from, like a link on another site, an email campaign, or a search engine results page); location based upon IP address; which search terms drive traffic to the Site from search engines; the number of views for the Site’s forms and buttons and how many submissions or clicks they receive; top content by page views; the most popular queries from the Site’s search boxes; and the total amount of traffic that the Site’s RSS feed receives.	We use Squarespace Analytics and similar technologies to collect and process statistical data to better understand how they find and use our webpages. This does not include personal information, nor do we store or associate such analytics with personal information collected elsewhere. Any data collected is used in accordance with our Policy and Squarespace’s privacy policy. You may learn more about Squarespace Analytics and the performance and ad tracking cookies used by Squarespace by visiting https://support.squarespace.com/hc/en-us/articles/206544167-About-Squarespace-Analytics#toc-analytics-faq.
Facebook Social Graph API	We do not receive any data using the Facebook Social Graph API; but, you should review Facebook’s Privacy Policy when using any of Facebook’s services. For more information please see: https://developers.facebook.com/docs/graph-api/ and https://www.facebook.com/policy.php	The Facebook Social Graph API is being used by our Site’s Facebook share button functionality to enable you to share our blogs on Facebook.
Yahoo User Interface	This front-end developer library, which was originally developed by Yahoo, is used to develop websites/web applications. The Site does not collect data via Yahoo User Interface.	Yahoo User Interface is an open source JavaScript and CSS framework for building richly interactive web applications.
Share and Like Buttons	The share buttons allow users to share our blog posts by logging into their social media accounts on Facebook, Twitter, and Pinterest. After pressing these buttons, you can access your account and share the article. The Site does not collect data from Facebook, Twitter, and Pinterest. We also use a “Like” button. If you press this button, we will use local storage on your browser to store your likes, and we will log your IP address.	We use the share and like buttons to allow you to interact with and to share content from our Site across your social networks such as Facebook, Twitter and Pinterest. We use the “like” button to store your preferences regarding our blog posts.

Other Third Party Technologies

Some third parties may use automated data collection technologies to collect information about you when you when you browse the Internet. The information they collect about your online browsing activities over time and across different websites and other online services may be associated with your personal information and used to provide you with targeted content. We do not control these third parties’ technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible party directly or consult their privacy policies.

Choices About Cookies

We provide you with choices regarding the personal information you provide to us, and we have created ways to give you control over our use of your information. Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may set your browser to refuse all or some types of cookies or to alert you when cookies are being sent by website tracking technologies and advertising. Note that, if you decline the use of cookies, you may not have access to the full benefits of the Site.

When you visit the Site, it will prompt you to confirm whether you approve of the use of a cookie. You may adjust your browser settings to opt out of accepting a “persistent” cookie and to only accept “session” cookies, but you will need to log in each time you want to enjoy the full functionality of the Site.

Please be aware that adjusting the Cookie Settings on the Site may not fully delete all of the cookies that have already been created. To delete them, visit your web browser settings after you have changed your Cookie Settings on the Site.

Additional information is provided below about how to disable cookies or manage the cookie settings for some of the leading web browser providers:

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Internet Explorer: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies

Safari: http://help.apple.com/safari/mac/8.0/#/sfri11471

For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/.

You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/ and http://youronlinechoices.eu/.

HOW WE USE PERSONAL INFORMATION

We collect and use the types of personal information listed above in an effort to operate our business, to improve your experience on the Site, to provide services to you, and to communicate with you about the information you have requested. We may also use personal information to help target specific offers to you and to help us develop and improve the Site and our services. Additionally, we may use your personal information in the following ways:

To provide you with the services you have requested and to manage our relationship with you, including, processing payments, accounting, auditing, billing and collection and taking other steps necessary to the performance of our business relationship with you;
To present and improve the Site’s content and functionality;
To personalize your experience (your information helps us to better respond to your individual needs.);
To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs.);
To respond to visitor, subscriber, and customer inquiries;
To determine user interests, needs, and preferences;
To provide notice of changes to the Site or the services and products we offer or provide through it;
To deliver services to you and to honor our Terms of Use;
To comply with your instructions;
To conduct research and analysis;
To improve our products and services;
To develop new products and services;
To manage and maintain the security of the Site and our services;
To market our services and products to you or to send you information about our company, including our affiliates, or our products or services, or to contact you when necessary. We will only provide you with marketing-related information after you have, where legally required to do so, opted in to receive those communications and having provided you with the opportunity to opt-out of such communications at any time. We do not sell or distribute this information to third parties or use it for any other purpose;
To comply with our legal and compliance obligations, including maintaining records, performing compliance audits, etc.;
For insurance purposes;
To exercise and defend our legal rights, or to comply with court orders;
For any other purpose related to and/or ancillary to any of the purposes and uses described in this Policy for which your personal information was provided to us;
Pursuant to your consent;
In any other way we may describe when you provide the information;
For any other purpose to which you have consented or for which we have a legal basis under law; and
To send periodic emails, including information and updates pertaining to your account.
We may process your personal information in connection with any of the purposes and uses set out in this Policy on one or more of the following legal grounds:
Because it is necessary to perform the services you have requested;
To comply with your instructions or other contractual obligations between you and us;
To comply with our legal obligations as well as to keep records of our compliance processes;
Because our legitimate interests, or those of a third party recipient of your personal information, make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;
Because it is necessary to protect your vital interests;
Because it is necessary in the public interest; or
Because you have expressly given us your consent to process your personal information in a particular manner.

We do not use your personal information for making any automated decisions affecting or creating profiles other than as described above.

IS ENTRY OF PERSONAL INFORMATION REQUIRED?

You may choose not to provide us with any personal information, and you may still access and use much of the Site. Some pages on the Site may give you the option of providing certain personal information about yourself. However, you will not be able to access any portions of the Site that require your personal information. If you want to change any information about yourself that you have submitted, you may contact us via the contact methods listed at the end of this Policy.

SHARING AND DISCLOSING OF YOUR PERSONAL INFORMATION

We may share your information in the following contexts:

Category	Disclosure Contexts
Subsidiaries and Acquisitions	We may share your personal information with our corporate subsidiaries and affiliates and with their respective officers, directors, employees, accountants, attorneys and agents. In addition, we may disclose your personal information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the Site’s users is among the assets transferred. For example, if another company acquires us, we will share your personal information with that company.
Disclosures With Your Consent	We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Policy. We will only disclose your personal information in this context with your consent.
Disclosures Without Your Consent	We may disclose your personal information in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our legal rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property or a violation of our Terms of Use.
Service Providers	We may share your personal information with our service providers that need access to your information to provide operational or other support services on our behalf. Among other things, service providers may help us to administer the Site; support our provision of services requested by you; provide technical support; send marketing, promotions and communications to you about our services; provide payment processing; and assist with other legitimate purposes permitted by law.

HOW LONG DO WE STORE YOUR PERSONAL INFORMATION?

We will retain your personal information as needed to fulfill the purposes for which it was collected. We will retain and use your personal information as long as necessary to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to enforce our agreements.

When we no longer have a purpose to retain your personal information, we will securely destroy your personal information in accordance with applicable law and our policies. We take reasonable steps to delete the personal information we collect if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. To the extent permitted by law, we may retain and use anonymous and aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement.

HOW DO WE PROTECT YOUR INFORMATION?

We have put security measures in place to protect the personal information that you share with us from being accidentally lost, used, altered, or disclosed or accessed in an unauthorized manner. From time to time, we review our security procedures to consider appropriate new technology and methods.

We use secure software, software services, and hardware that use encryption technologies to receive, store, and transmit personal information we collect about our users. While our security measures seek to protect your personal information in our possession, no security system is perfect, and no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee or warrant the security of any information you transmit to or from our Site, including through email communication with us, and you do so at your own risk. We cannot promise that your personal information will remain absolutely secure in all circumstances.

If a security breach causes an unauthorized intrusion into our Site or systems that compromises your data, we will notify you and any applicable regulator when we are required to do so by applicable law.

RIGHTS AND CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

Please use the Contact Us details at the end of this Policy to exercise your rights and choices under this Policy. If you would like to manage, change, limit, or delete your personal information or if you no longer want to receive any email, postal mail, or telephone contact from us or our affiliates in the future, such requests may be submitted via the Contact Us details at the end of this Policy.

Communications Opt-Out. If you no longer wish to receive communications from us via email, you may opt-out by contacting us at info[at]connexus.email and providing your full name, mailing address, phone number, and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action.

Cookies. As discussed above, you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Site may then be inaccessible or not function properly.

Disclosure of Your Information for Third-Party Advertising. We do not share your personal information with unaffiliated third parties for promotional purposes.

Updating Your Personal Information. If any of the personal information you have provided to us changes, please let us know. For instance, if your email address changes, you may wish to cancel any request you have made of us; or, if you become aware of inaccurate personal information about you, you may use the “Contact Us” details provided at the end of this Policy to update your information. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

Right of Access. If required by law, upon request, we will grant reasonable access to the personal information that we hold about you.

Accuracy. Our goal is to keep your personal information accurate, current, and complete. Please contact us if you believe your information is not accurate or if it changes.

Right to Object. In certain circumstances, if permitted under applicable law, you have the right to object to processing of your personal information and to ask us to erase or restrict our use of your personal information. If you would like us to stop using your personal information, please contact us, and we will let you know if are able to agree to your request.

Right to Erasure and Deletion of Your Personal Information. You may have a legal right to request that we delete your personal information when it is no longer necessary for the purposes for which it was collected, or when, among other things, your personal information has been unlawfully processed. All deletion requests should be sent to the address noted in the “Contact Us” section of this Policy. If you would like us to delete your personal information, please contact us, and we will let you know if we are able to agree to your request.

We may decide to delete your personal information if we believe it is incomplete, inaccurate, or that our continued storage of your personal information is contrary to our legal obligations or business objectives. When we delete personal information, it will be removed from our active servers and databases as well as the Site; but, it may remain in our archives when it is not practical or possible to delete it. We may also retain your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.

Right to Withdraw Consent. If you have provided your consent to the collection, processing, and transfer of your personal information, you may have the right to fully or partially withdraw your consent. To withdraw your consent, please notify us using the information in the “Contact Us” section of this Policy, and you may follow opt-out links on any marketing communications sent to you. Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our services.

Right to Complain. If you believe that your rights relating to your personal information have been violated, you have a right to lodge a complaint with the applicable enforcement authority, or seek a remedy through the courts. You may also lodge a complaint with us by contacting us using the information provided in the “Contact Us” section of this Policy.

Online Tracking. We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions. “Do Not Track” is a web browser setting that seeks to disable the tracking of individual users’ browsing activities. We adhere to the standards set out in this Policy and do not currently respond to “Do Not Track” signals on the Site or on third-party websites or online services where we may collect information.

California Residents. Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. At present, we do not share your personal information with third parties. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our site may make any changes to their information at any time by contacting us at info[at]connexus.email.

THIRD-PARTY SITES

This Policy is applicable only to the Site, and it does not apply to any third-party websites.

The Site may contain links to, and media and other content from, third-party websites. These links are to external websites and third parties with which we have no relationship. Because of the dynamic media capabilities of the Site, it may not be clear to you which links are to the Site and which are to external, third party websites. If you click on an embedded third-party link, you will be redirected away from the Site to the external third-party website. You can check the URL to confirm that you have left this Site.

We cannot and do not (i) guarantee the adequacy of the privacy and security practices employed by or the content and media provided by any third parties or their websites, (ii) control third parties’ independent collection or use or your personal information, or (iii) endorse any third party information, products, services or websites that may be reached through embedded links on this Site.

Any personal information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use. If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website.

CHILDREN’S ONLINE PRIVACY PROTECTION ACT COMPLIANCE

The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet. Our Site and services are not directed to children aged 18 or younger, nor is information knowingly collected from children under the age of 18. No one under the age of 18 may access, browse, or use the Site or provide any information to or on the Site. If you are under 18, please do not use or provide any information on the Site (including, for example, your name, telephone number, email address, and username). If we learn that we have collected or received personal information from a child under the age of 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child under the age of 18, please contact us using the contact information provided below.

For more information about COPPA, please visit the Federal Trade Commission's website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

UPDATES AND CHANGES TO THIS POLICY

We reserve the right, at any time and without notice, to add to, change, update, or modify this Policy to reflect any changes to the way in which we treat your personal information or in response to changes in law. Should this Policy change, we will post all changes we make to this Policy on this page. If we make material changes to how we treat your personal information, we will also notify you through a notice on the home page of the Site for a reasonable period of time. Any such changes, updates or modifications shall be effective immediately upon posting on the Site. The date on which this policy was last modified is identified at the beginning of this Policy.

You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Site, and from time to time, so you are aware of any changes. Your continued use of the Site after the “Last Modified” date will constitute your acceptance of and agreement to such changes and to our collection and sharing of your personal information according to the terms of the then-current Policy. If you do not agree with this Policy and our practices, do not access, view, or use any part of the Site.

CONTACT US

For more information, or if you have any questions regarding this Privacy Policy, wish to exercise your rights, or wish to lodge a complaint with us, you may contact us using the information below, and we will do our best to assist you. Please note, if your communication is sensitive, you may wish to contact us by postal mail or telephone.

In Writing: 1526 N. Edgewood Street, Arlington, VA 22201

By Telephone: +1.703.527.6870

By Email: info[at]connexus.email

Connexus CorporationAugust 20, 2019