Privacy Notice

Exadel, Inc., a Delaware corporation, together with its subsidiaries and affiliates worldwide (“Exadel”, “we”, or “us”), provides software development, consulting, data and AI advisory, as well as engineering services, and is headquartered in Tampa, Florida. Exadel, Inc. owns and operates this website on behalf of the Exadel group of companies. This Privacy Notice applies globally, regardless of where you are located, subject to applicable local law.

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This Privacy Notice describes how Exadel processes Personal Information (as defined below) when acting as a data controller, and is intended to comply with applicable data protection and privacy laws, including where applicable U.S. state privacy laws, the EU General Data Protection Regulation (“GDPR”), UK Data Protection Act 2018, and the GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of Section 3 of the European Union (Withdrawal) Act 2018 (the “UK GDPR”), Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), Brazil’s Lei Geral de Proteção de Dados (“LGPD”), and other applicable data protection laws, in each case as amended or superseded from time to time (the “Data Protection Laws”).

What does this Privacy Notice cover? 

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This Privacy Notice describes the Personal Information we collect about you, how we use that Personal Information, and your rights and choices in relation to your Personal Information. It applies to individuals who visit our website or interact with us in a business context, including business contacts, prospective customers, customer representatives, partner representatives, vendor representatives, and event participants (“you” or “your”).

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“Personal Information” is information that identifies, relates to, describes, could reasonably be linked to, or is reasonably capable of being associated with you, including online identifiers and other information collected automatically.  

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Who is responsible for processing your Personal Information? 

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Depending on the nature of your interaction with us, Exadel, Inc. or another relevant Exadel affiliate may act as the data controller. Where a local affiliate primarily manages your relationship, that affiliate may act as controller or joint controller as required by applicable law. For general website visitors and global marketing, the primary controller is Exadel, Inc. (Tampa, Florida). You can find a full list of the Exadel group entities globally in Appendix 1.

What Personal Information we process?

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We process Personal Information for different purposes depending on our relationship with you. To help you understand how your data is used, we have organised our processing activities into the following categories:

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Client engagement and provision of services

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We collect and process the following Personal Information about you:

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Identifiers: Name, business email, phone number, job title, signature and company name;

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Commercial information: Records of services purchased or considered, payment information and other information we request from you or you provide to us, including information used to facilitate the processing of your company’s orders;

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Communications information: When you communicate with us, we retain the contents of those communications so that we can respond to your questions and comments, and to help us improve our communications;

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Professional profiles: for example from platforms such as LinkedIn, information you choose to share via social media interactions with our official profiles;

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Direct marketing: including your communication preferences and interests;

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Physical access data: relating to details of your visits to our premises.

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Supplier engagement

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Identifiers: Name, business email, phone number, job title, signature and company name;

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Commercial information: Records of services purchased or considered, payment information and other information we request from you or you provide to us, including information used to facilitate the processing of your/ our orders; 

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Communications information: When you communicate with us, we retain the contents of those communications so that we can respond to your questions and comments, and to help us improve our communications.

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Use of Exadel website, forms and tools

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Device and online activity information: Exadel and our third–party service providers may use a variety of technologies that passively or automatically collect information about how our visitors are browsing the website. The information collected through these technologies includes online identifiers such as IP address, device ID and operating system, and online activity, such as the browser you use, , the type of device you use, browsing activity, referring websites, web page visits, use of tools on the services and links clicked and other analytics data.  If you access our services using a mobile device like a smartphone, we may also collect your phone’s unique device ID and other similar mobile device data.

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Online forms data: Name, business email, phone number, job title, company name, any other information that you share with us in the free text field;

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Cookies: Like many websites, we use “Cookies” for our website, which are small text files placed on your browser to facilitate site navigation and to personalize your experience. The tracking technology is further described in the “Cookies and Similar Technologies” section below.

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Engagement data: Includes likes, comments, and messages on professional networking platforms.

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How is your Personal Information collected? 

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We use different methods to collect Personal Information from and about you, including through the channels set out below.

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Direct interactions with you

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• When you complete contact forms on our website;
• When you request information, proposals or demos;
• When you subscribe to newsletters, events, or webinars;
• When you communicate with us by email, phone, video call, or message tools;
• When you provide business cards or contact details at meetings or events;

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Data collected automatically when you use our website

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• IP address, device and browser information; 
• Website usage data (e.g. pages visited, time spent, interactions; 
• Data collected via cookies or similar technologies (subject to your cookie preferences);

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From third parties

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We may receive data from business partners, lead generation services, or public sources like LinkedIn.

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Publicly available sources

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• Professional profiles on platforms such as LinkedIn;
• Company websites, press releases, or published articles;
• Business directories and publicly accessible registers;

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Referrals and Business Contacts

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• Information shared by colleagues, partners, or mutual business contacts;
• Contact details provided by your employer or organization in a business-to-business context;

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Events, conferences, and networking activities

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• Registration lists from events, trade fairs, or webinars;
• Information collected during in-person or online networking activities;

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Marketing and lead generation partners

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• Data obtained from marketing agencies or lead generation service providers;
• Information received from co-organised events or joint marketing campaigns;
• Contact data from business-to-business databases, where permitted by law;

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Social media and professional networking platforms

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• Information you choose to share via social media interactions with our official profiles;
• Engagement data (e.g. likes, comments, messages) on professional networking platforms;

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Third party applications

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We also offer and deliver services, content or interactive features through and/or using third party application programming interfaces (API), gadgets, extensions that are hosted on our services or through other third party websites, or social networking platforms. When you participate in these services, products, applications, or otherwise connect with, or “accept” or “allow” third party applications, networks, platforms or services through our services and/or one of our services or products, you are authorizing those third parties to receive your information and additionally to potentially share any or all of your information with us, based on your privacy or other settings on the particular third party network or platform. Any personal or other information we receive by these means will be treated and/or processed according to this Privacy Notice.

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Purposes of processing Personal Information and legal bases 

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We process Personal Information only where we have a valid legal basis under applicable law. Depending on the circumstances, these legal bases may include consent, performance of a contract, compliance with legal obligations, or our legitimate business interests, provided such interests are not overridden by your rights and freedoms. Where we rely on legitimate interests as a legal basis for processing, we have assessed that such interests are not overridden by your rights and freedoms.

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Detailed legal bases and purposes of processing

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Who do we disclose your Personal Information to?

Personal Information will be disclosed for the purposes set forth herein or in accordance with applicable laws.  We may disclose aggregated or deidentified information about our users, and information that does not identify or allow for the reidentification of any individual, without restriction. 

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Internal and external parties we may share your data with

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• Exadel subsidiaries and affiliates

For the purposes described in this Privacy Notice, including, but not limited to, internal administration, service delivery, relationship management, security, and business operations.

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• Contractors, service providers, and other processors

Cloud hosting (e.g., Google cloud), CRM providers, and other processors we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for specific purposes for which we disclose it to them.

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• Buyer or other successor in interest 

In the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding in which Personal Information held by us about our website users is among the assets transferred.

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• Third parties and business partners 

For business, marketing or advertising purposes, such as with social media sites when you respond to an ad there or advertising networks, agencies or analytics partners, where permitted by applicable law and subject to contractual confidentiality and data protection obligations. 

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• Professional advisors

 Lawyers, auditors, and insurers.

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• Public Authorities

To cooperate with law enforcement officials, comply with any court order, law or legal process, including to respond to any government or regulatory request.

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• Other

When you direct or authorize us to share Personal Information for any other purpose, we will do so. We do not sell personal information for monetary consideration. We do not knowingly share personal information for cross-context behavioral advertising where prohibited by law.

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How do we protect your Personal Information? 

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Exadel has put in place commercially reasonable and appropriate physical, electronic, and managerial procedures, including administrative, technical, and organizational safeguards designed to protect Personal Information against unauthorized access, disclosure, alteration, or destruction. However, no company, including Exadel, can fully eliminate security risks associated with Personal Information. 

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What choices and rights do you have regarding your Personal Information and contact data 

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Depending on your jurisdiction, you may have specific statutory rights regarding your Personal Information, including rights of access, correction, deletion, restriction, objection, portability, and withdrawal of consent. Additional information regarding region-specific rights is provided below.

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You may:

• Opt out of our emails

We will include unsubscribe instructions in each newsletter or promotional communication you receive from us.

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• Be informed and access your Personal Information

With some exceptions designed to protect the rights of others, you have the right to be informed about processing of your Personal Information and to obtain a copy of the Personal Information  that we hold about you. 

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• Correct your Personal Information 

You have the right to request that we correct any Personal Information we have about you that is incorrect. 

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• Restrict processing

You can request the restriction of processing of your Personal Information in certain situations.

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• Right to data portability

You have the right to receive your Personal Information in a structured, commonly used, and machine-readable format.

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• Request deletion of your Personal Information

You have the right to request that we delete your Personal Information. This right is not generally available where we still have a valid legal reason to keep the data (for example, because we are obliged to do so by law).

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• Object to processing 

You can object to the processing of your Personal Information in certain situations, such as in cases where we rely on “legitimate interests” as our legal basis for processing, but we may be able to continue processing if our interest outweighs your objection. 

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• Withdraw consent for processing

If we are processing your Personal Information on the basis of your consent, you have the right to withdraw that consent at any time, in which case we will stop that processing unless we have another legal basis on which to continue.

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• Lodge a Complaint with your local Data Protection Authority 

In the European Economic Area (EEA)

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You can find a list of all EU DPAs on the European Data Protection Board website.

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In the United Kingdom

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The competent authority is the Information Commissioner’s Office (ICO). You can contact them at www.ico.org.uk.

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In Brazil

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You may contact the Autoridade Nacional de Proteção de Dados (ANPD) via their official website at www.gov.br/anpd.

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In Canada

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You may contact the Office of the Privacy Commissioner of Canada (OPC) at www.priv.gc.ca.

To exercise your rights, please complete and submit the Personal Data Subject Rights Enforcement form at the end of this Notice. 

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Alternatively, you can contact us by sending us an e-mail to [email protected]. 

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Before submitting your request, please read the procedure for the exercise of rights relating to the collection and use of your Personal Information.

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Online advertising and third party tracking 

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Cookies and Similar Technologies

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Like many websites, we use cookies for our website, which are small text files placed on your browser to facilitate site navigation and to personalize your experience. Cookies allow us to select which ads or offers are most likely to appeal to you, based on your interests, preferences, location, or demographic information. Where required by applicable law, we use non-essential cookies and similar technologies only with your consent. You may withdraw your consent or manage your preferences at any time through our cookie preference tools or browser settings.

There are a couple different types of cookies. We use session cookies (which expire when you close your browser)  and persistent cookies (which remain for a set period) to operate the website, remember preferences, analyze website traffic, and support marketing activities. For more detail on the cookies we use and your choices, please visit our cookie settings page.

You can also change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; or set your browser to automatically not accept any cookies. While you will still be able to use the services if you disable Cookies in your browser, certain parts of the services may not function as effectively.

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Changing cookies on your browser will not change the way you are tracked on a mobile device. You can adjust your tracking preferences on your mobile device through your device settings.

We may contract with third-party service providers to assist us in analyzing cookies and similar technologies. We may use analytics providers, including Google Analytics or similar tools, to understand website performance and usage. These third parties can use cookies and other technologies to collect information, such as the browsers you use to access our site, websites viewed, time spent on websites, and links clicked.

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Interest based advertising

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To provide you a more relevant and interesting experience, we may work with third party companies to display ads elsewhere on the Internet. These companies may use cookies (a small text file), pixels, or similar technologies that are placed in browsers to gather information about your visits to the Exadel website, your use of the services, and your visits elsewhere on the Internet. These companies use this information to provide you more relevant advertising known as interest-based advertising. Some of these companies may be participants in the Digital Advertising Alliance (“DAA”). The DAA offers a choice mechanism with respect to certain types of data collection and use. Visit www.aboutads.info to exercise choice with respect to participants of the DAA. If you change computers or browsers, use multiple computers or browsers, or delete your cookies, you may need to repeat this process for each computer and each browser. Where required by applicable law, interest-based advertising is conducted only after obtaining appropriate consent.

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Privacy of minors 

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Our Terms of Use prohibit individuals who are under the age of 16, or any higher age required under applicable local law as defined by the laws of their jurisdiction from using our services. We do not intentionally collect or maintain information from persons who do not meet these local age requirements.

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If we determine upon collection that a user is under the applicable legal age, we will not use or maintain their Personal Information without verifiable parent or guardian consent. If we become aware that we have unknowingly collected personally identifiable information from a minor in violation of these requirements, we will make reasonable efforts to delete such information from our records immediately.

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International Data Transfers 

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Your Personal Information may be transferred to, stored in, or otherwise processed in countries outside your country of residence for the purposes described in this Privacy Notice. This may include sharing your Personal Information with Exadel affiliates and trusted service providers located in other jurisdictions that support our global operations. Where required by applicable law, we implement appropriate safeguards to protect Personal Information transferred internationally. 

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Where your Personal Information is transferred internationally to countries that do not provide an adequate level of protection under applicable law, Exadel implements appropriate contractual, technical, and organizational safeguards in accordance with the more stringent data protection laws, including the GDPR, the UK GDPR, and the Brazilian LGPD.

For transfers subject to the GDPR or the UK GDPR, such safeguards may include, where applicable, standard contractual clauses adopted or approved by the European Commission or the UK Information Commissioner’s Office, other lawful transfer mechanisms recognized under applicable data protection laws, or if we have your express consent to the transfer, as well as supplementary measures where required.

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For transfers subject to the LGPD, international transfers of Personal Information will take place only in accordance with the legal mechanisms provided for under Article 33 of the LGPD, including, where applicable, standard contractual clauses, specific contractual clauses, global corporate rules, or other lawful transfer mechanisms recognised by the Brazilian National Data Protection Authority (ANPD).

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Exadel ensures that appropriate contractual, technical, and organizational safeguards are in place to maintain an adequate level of data protection consistent with the applicable standards.

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You may request further information about international data transfers and the safeguards applied by contacting us at [email protected].

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Data retention

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We will retain your Personal Information only for as long as reasonably necessary to fulfill the purposes outlined in this Privacy Notice, taking into account the nature of the data, the purpose of processing, applicable legal or regulatory requirements, limitation periods, and legitimate business needs, including, but not limited to, meeting legal, tax, accounting, contractual, and dispute resolution obligations. Except as otherwise required for such purposes, we retain Personal Information until it is no longer necessary to provide services to you, until you ask us to delete it, or until your account is deleted, whichever comes first. For more information, contact us at [email protected].

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Requirements to provide Personal Information

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Providing data is voluntary. However, not providing it may make it impossible to start or continue cooperation, for example, due to Exadel’s tax obligations.

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Provision of certain data (e.g., business contact info) is a requirement to enter into a contract. Failure to provide this data may result in Exadel being unable to provide services to you.

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Automated decision-making

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We do not make decisions based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

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Third party sites and platforms 

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Our platform may contain links to other third-party sites, platforms, services, plugins, and applications (collectively “Third-Party Site(s)”). When you click such a link you will be taken to a Third-Party Site, and we do not control that Third-Party Site, and any Personal Information you provide to that Third-Party Site is not governed by this Privacy Notice. We are not responsible for the privacy practices of such Third-Party Sites. We suggest that you read the privacy policies of such Third-Party Sites carefully.

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Modifications to the Privacy Notice 

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This Privacy Notice may change from time to time, and minor changes will take effect when posted. Your continued use of the services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates. If we make any material or key changes to the Privacy Notice, we will notify you as required by law. 

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SUPPLEMENTAL EXADEL PRIVACY NOTICE FOR CALIFORNIA  RESIDENTS

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This Supplemental Privacy Notice for California Residents supplements the information contained in Exadel Privacy Notice. Any terms defined in the California Consumer Privacy Act (CCPA) have the same meaning when used in this Privacy Notice.

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Categories of Personal Information collected and disclosed

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The following chart details which categories of Personal Information about California residents we collect, as well as which categories of Personal Information we have disclosed within the last twelve (12) months:

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We collect this information from you and from third parties as described above in the “How is your Personal Information collected?” Section.

We collect this information for our business purposes as described above in the “Purposes of processing Personal Information and legal bases” Section.

We share this information with the service providers and contractors described above in the “ Who do we disclose your Personal Information to?” Section.

We also share your personal information for targeted advertising purposes with online advertising technology providers that help us market and advertise to you.

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Personal Information of children under age 16

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We do not collect, sell or share Personal Information of users we know to be less than 16 years of age.

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Your rights and choices

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The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

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• Right to know

You have the right to ask us to disclose the Personal Information we have collected, shared, or sold about you in the past 12 months. If we are able to verify your identity, we will provide the categories of Personal Information we have collected about you, the categories of sources from which we collect it, our business or commercial purpose for collecting the Personal Information, and the specific pieces of Personal Information we collected. If we have disclosed your Personal Information to any third party for any reason, we will also tell you the categories of Personal Information we disclosed, the categories of third parties with whom we shared it, and the purpose for which we shared it.  You also have the right to request that we provide you the specific pieces of Personal Information that we collected and retained about you.

• Right to opt out of sale or sharing of your Personal Information and/or /cross contextual advertising

You have the right to tell us “Do Not Sell or Share My Personal Information” or to the right to direct us not to sell or share Personal Information we have collected about you to third parties, including without limitation for cross-contextual advertising.

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• Right to deletion

You have the right to request that we delete any Personal Information we have collected about you. We will only do this if we can confirm your identity, and in some cases, we are required or permitted by law to retain all or some of your information for specific purposes.

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• Right to correct

You have the right to request that we correct your inaccurate Personal Information maintained by us.  

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• Authorized agent

You have the right to appoint an authorized agent to exercise these rights for you.  We have the right to verify that the authorized agent acts on your behalf.

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We will not discriminate against you if you exercise any of these rights.

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Response timing and format

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To exercise your rights, please complete and submit the Personal Data Subject Rights Enforcement form at the end of the Privacy Notice. 

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Alternatively, you can contact us by sending us an e-mail to [email protected]. 

We will respond to verifiable consumer requests within the timeframes required by applicable California law. If additional time is needed, we will notify you of the reason and extension period. We do not charge a fee to process or respond to requests unless permitted by law. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. 

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Browser-based opt-outs

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Some browsers offer you the ability to opt out of cookie-based “sales” and sharing of personal information for targeted or other cross-contextual behavioral advertising.  The Global Privacy Control (https://globalprivacycontrol.org/) is currently the most recognized signal.  

The Exadel website is not currently configured to recognize “do not track” or other browser-based signals. However, other settings within your browser may permit you to block cookies or other technology that enable websites to collect information that can be used to tailor advertisements to your interest. Please check your browser’s settings or consult your browser’s help information for more details. 

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Other California Privacy Rights

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California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. We do not share Personal Information with third parties for their direct marketing purposes.

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APPENDIX 1

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List of Exadel Group Companies

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Personal Data Subject Rights Enforcement