You can interact with some of the Sites by just browsing as a “Visitor”, or by engaging with the Sites and Services after creating and maintaining an account.

This account may be utilized for instance, to seek, try or demo a product; apply for and/or be accepted for one or more products through the Sites, designating you as a “Cadency Subscriber”. 

Without forgoing the generality of the above, you are a Cadency Subscriber if you use our products:

1. Customer Portal:

• • Personal Information: When you create an account on the customer portal, we may collect information such as your name, contact details, and other relevant details required for the efficient functioning of our services.
  • Financial Information: To facilitate transactions and payment processing, we may collect and store financial information, including bank account details and transaction history.

1. Merchant Portal:

• • Business Information: For merchants utilizing our services, we may collect information about the business, including its name, address, tax identification number, and other relevant details.
  • Financial and Transactional Data: This includes information related to transactions, invoices, and payment history processed through our platform.

You may also become a Cadency Subscriber by providing us with information (as described below) when seeking, applying for and/or are getting approval for one or more account services, card services, or payment services over the telephone with one of our representatives.

In the context of this Privacy Policy, both Visitors and Cadency Subscribers may be collectively referred to as “users”, “you” or “your.” Please note that certain Services are exclusively accessible to Cadency Subscribers.

1. Sources of Information
   

   The types and sources of personal information we gather depend on the specific Service utilized, your interactions with us and our Sites, and/or how you were referred to us. The types and sources of information may include:

   • Information You Provide Directly: This includes data you provide to us directly when using our online tools, on applications or forms, during your transactions and communications with us, our representatives, or our business partners (e.g., through telephone conversations, emails, text messages or chats).
   • Information From Third Parties: This category involves data from external sources, including consumer, credit, and/or other reporting agencies, Referral Partners (as further described below), regulatory technology firms, and identity authentication/verification providers.
   • Information Generated Through Your Interaction with Our Sites: Data generated through your interaction with our Sites, as well as information derived from social networks or other third-party platforms you may use to access our Sites and Services (see “Social Features” below).
     
     
2. Types of Information We Collect and How We Use It:
   
   1. Data Gathered Directly from Individuals or Businesses
   

   We may collect personal data directly from individuals and businesses, inclusive of prospects. This encompasses parties that directly engage with our applications or apply for jobs, parties to which we provide Services (such as clients, banks, financial institutions, merchants, and individuals, collectively, “Cadency Clients”), parties that provide services to us (collectively, “Service Providers”), and other parties with whom we collaborate to jointly promote Services (Referral Partners as further described below).

   This information may be gathered in a variety of contexts, such as when completing our online forms, applying for our Services, interacting with us in person or on social media, or corresponding with us through various channels. The types of information we obtain in these instances include:

   • Contact information of the business entity and its personnel interacting with us, such as name, job title, address, telephone number, and email address.
   • Profile information, such as usernames and passwords established on our Sites along with any other information entered into individual account profiles.
   • Demographic details, such as date of birth, country of citizenship and/or country of residence.
   • Details regarding an individual’s affiliation with a legal entity, including an individual’s role, and whether they are a beneficial owner or authorized signatory.
   • Consent details and releases for written statements, audio, digital media and image rights to Cadency.
   • Government-issued identification numbers (to the extent permitted under applicable law), such as national identification numbers (e.g., Social Security Number, Social Insurance Number, tax identification number or passport number), state or local identification numbers (e.g., a Driver’s License or other government-issued identification number), and a copy of your government-issued identification card.
   • Feedback and correspondence, covering information you provide to us during inquiries, customer support interactions, or other communications with us, including interactions on social networking sites or services.
   • Financial account information, such as payment card or bank account details.
   • Merchant information, including names, merchant IDs, category codes, transaction locations, and information about transactions processed by the merchant (volume, velocity, amounts, goods or services sold, and chargeback ratios).
   • Information related to the use of Cadency’s Services, such as account information, transaction limits, transaction activity and patterns, and other transaction-related information.
   • Precise geolocation information, if authorized by users for any of our applications to access their location.
   • Marketing information, such as your preferences for receiving marketing communications and details about how you engage with our marketing communications.
   • Other information supplied by job applicants, such as professional credentials and skills, educational and work history, and other information of the type included on a resume or curriculum vitae.

   
   2. Information We Collect from Private and Publicly Accessible Sources
   

   We, along with our Service Providers and Partners, may collect information about individuals and businesses from publicly available sources. This includes searching publicly accessible government lists of restricted or sanctioned persons, such as the Specially Designated Nationals and Blocked Persons List, as well as public records databases like company registries and regulatory filings. Additionally, we may retrieve information by searching media and the internet. We, along with our Service Providers that offer us verification services, may collect information from private or commercially available sources. This could involve requesting reports or information from credit reference and fraud prevention agencies, in compliance with applicable laws.

   Furthermore, we maintain pages for our company and Services on various third-party platforms, such as LinkedIn, Facebook, Twitter, YouTube, Instagram, and other social networking services. Your interactions with our pages on these third-party platforms are governed by the privacy policy on the respective platform. If the third-party platform provides us with information about our pages on those platforms or your interactions with them (e.g. for lead generation purposes), we will treat that information in accordance with this Privacy Policy.

   3. Site Users
   

   We collect “Usage Information” which may include details about the technical mechanisms you used to access our Sites. This may include specifics such as your browser and operating system type, the referral link that directed you to our Sites, data points aiding our analytics function to understand the path that led you to a particular section on our Sites, details about your specific mobile device and its ID, as well as your IP address.

   We leverage Usage Information to inspect, analyze, and improve our Sites and Services and ensure they function well with the technology used by our Visitors and Cadency Subscribers. In addition to analytics about the demographics of our Sites’ users, we use your IP Address to comply with legal rules applicable based on your location.

   4. Newsletters
   

   Visitors and Cadency Subscribers may sign up for email newsletters by providing their first and last name, and email address. We collect and use information about your engagement with newsletter communications, such as tracking whether you view or click on those communications.
   
   5. Marketing

   As part of our marketing initiatives, we collect and use information about your engagement with our marketing communications. This includes insights into whether you view or click on marketing emails. This approach ensures that the products and offers that we communicate are tailored to be relevant to your interests.
   
   6. Email and Chat

   Visitors and Cadency Subscribers can communicate with us over email or chat on the Sites by providing their first and last name, and email address. The information provided will be used to offer Services that are relevant to you. In the case of Cadency Subscribers, additional personal information may be shared during communications about the Services, either through chat or email. We may collect this information to facilitate the provision of Services, such as completing a Cadency product or service application.
   
   7. Customer Surveys and Reviews

   We may invite you to participate in customer reviews and surveys, during which we might request certain personal information. Participation in these surveys is completely voluntary and you have the choice of whether or not to disclose this information. The requested information typically includes first and last name, contact information (such as email or address), and demographic information (such as zip code or postal code).

   We use this information to evaluate the quality of our customer service, as well as test and make improvements to our products, Sites, and Services. With your consent, we may use your first and last name, along with your responses, on our Sites, in marketing materials, or on our social media platforms. Additionally, with your consent, we may share your information with a third-party service provider to assist in resolving errors or implementing improvements related to their services.

3. We Use Your Data to Provide Our Services
   

   We use your personal data for the purposes of offering our Services to you as follows:

   • Operating, assessing, maintaining, improving, and providing the features and functionality of our Services.
   • Executing a receivable transaction initiated by you, either with us or our client.
   • Managing our relationship with you or your company.
   • Fulfilling our obligations and exercising our rights under our agreement with you or your company.
   • Corresponding with you regarding your account with us, when applicable, through service-related emails or messages (e.g., messages pertaining to account verification, changes or updates to the functionality of our Services, technical and security notifications, alerts, support and administrative messages).
   • Personalizing the way we deliver our Services.
   • Conducting checks for fraud, money laundering and/or managing risks for both our organization and our stakeholders.
   • Administering and protecting our business.
   • Providing support and maintenance for our Services, including addressing your service-related requests, questions, and feedback.
   
   1. Other Uses of Personal Information on Our Sites and Services
   

   In addition to the above, we may use your personal information to:

   • Otherwise provide, improve, maintain, or optimize the Services;
   • Provide, maintain, and improve customer service;
   • Tailor your experience with the Services to your interests;
   • Develop and improve the Sites and the Services;
   • Respond to your inquiries;
   • Communicate with you regarding the Services that you are approved for through the Sites as well as other products and services that may be of interest to you; and
   • In addition, we may aggregate your personal information with our other users’ personal information and use that information for benchmarking and analysis purposes.
     
     
   2. Use of Personal Information for Compliance and Protection
   

   We may use your personal information to:

   • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
   • Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
   • Audit our internal processes for compliance with legal and contractual requirements and internal policies;
   • Enforce the terms and conditions that govern the Services; and
   • Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
     
     
4. Cookies and Online Tracking Technologies
   

   Our Sites use technologies such as cookies, beacons, tags, and scripts, to analyze trends, manage our Sites, track how users move across our Sites, and collect demographic information about our user base.

   Cookies are a small piece of software or text placed on your computer when you visit a website. They store information on web browsers and manage identifiers and other data on computers, phones, and other devices. They may include data we store on your web browser or device, identifiers linked to your device and other software. In this Privacy Policy, we refer to all these technologies that store or reference data on your device as “cookies.” If you access our Sites from a mobile device, we may reference your device identifier or other information about the origin of your visit. Certain cookies used on our Sites have a duration of ninety days or more. 

   We use cookies for the following purposes:

   • To recognize you on return visits and, if you have an account, facilitate the login process, help verify and authenticate your account, and detect fraud. 
   • To display ads and provide recommendations for products and services.
   • To assess the performance of advertising campaigns.
   • To deliver and gauge ads across different browsers and devices.
   • To perform web analytics on the usage of our Sites and Services.

   Web beacons, also called “clear GIFs,” Pixel tags or action tags, are small files stored and/or served on a website, app, advertisement, or in an email. They collect, track, or transmit data points back to us or to a third party. For instance, we use a web beacon to assess whether an email message has been opened.

   We use web beacons to facilitate advertising and functionality on our Sites, as well as for:

   • Associating our users with the reports they provide about satisfaction with our Sites and Services.
   • Administering and monitoring email campaigns.
   • Analyzing the sections of our Sites that are most frequently used by our Visitors and how they interact with our Sites.
   • Performing testing on our Sites.
   • Optimizing interactions with our data stores.
   • Improving the functionality and usefulness of our support and support chat functions.
   • Analyzing the efficacy of our own advertising campaigns.
   • Customizing the content displayed to you on our Sites and Services.
   • Organizing and managing other web beacons and cookies on our Sites.
   • Conducting web analytics on the usage of our Sites and Services.
   • Enabling, improving, and implementing targeted and re-targeted advertising for our advertising partners on both our Sites and their third-party sites such as Facebook.

   In some cases, the functions of the web beacons may be carried out by custom HTML within our Sites’ code.

   We may use cookies and/or web beacons to monitor whether and when a user abandons an application before completion and make efforts to re-engage that user for the same or similar application. Additionally, we may present the user with related product or service offerings.

   For information about how to opt-out of specific cookies and tracking technologies, refer to the Online Tracking Opt-Out Guide section below.

   Web browser “Do Not Track” (DNT) – Some web browsers may transmit “do-not-track” signals to websites they communicate with. We do not currently have the ability to recognize Do Not Track signals. You can learn more about Do Not Track signals at https://allaboutdnt.com/ 

1. When We Share Specific Information
   

   We may share your information with:
   
   1. Referral Partners

   If you have been referred to us by a Referral Partner or have submitted a request for information through a Referral Partner, we will share your information, including Application Information, with that Referral Partner. This sharing is essential to adhere to the terms outlined in our agreement with the Referral Partner and to deliver the requested Services to you.
   
   2. Service Providers
   
   We may enlist the services of third-party companies and individuals to manage and provide services on our behalf. These services may include customer support, hosting, managing, maintaining, and developing our website, applications, and IT systems, as well as assistance in payment processing. While these third parties may use your information for the purposes outlined in the section titled “How and Where We Collect and Use Your Information,” they are bound to follow Cadency’s instructions and adhere to the principles outlined in this Privacy Policy. Importantly, they are prohibited from using or disclosing your information for any other purpose.
   
   3. Participants in the Transaction Processing Chain

   Cadency shares personal data with companies involved in the the transaction processing chain to facilitate payment transactions. This may include merchants, banks, payment providers, card issuers, card associations, debit network operators, and their respective members.
   
   4. Credit Reference, Fraud Protection, Risk Management, and Identity Verification Agencies
   
   Cadency shares personal data with credit reference, fraud protection, risk management, and identity verification agencies. This collaboration is aimed at safeguarding against, detecting and responding to fraud or money laundering, and managing our or our clients’ risk in accordance with applicable laws. It ensures our adherence to contractual, legal, or regulatory requirements.
   
   5. Professional Advisors

   We may disclose your personal data to professional advisors, including lawyers, bankers, auditors, and insurers, as necessary during the course of the professional services they provide to us.
   
   6. Marketing

   As part of our marketing and promotional activities, we may share testimonials or images from events that may include your personal data. These may be disseminated through physical or digital media channels.
   
   7. Compliance with Laws and Law Enforcement; Protection and Safety

   Cadency may disclose information about you to government or law enforcement officials (including tax authorities) or private parties when required by law. We will disclose and use such information as deemed necessary or appropriate to (a) comply with applicable laws and respond to lawful requests and legal process, such as subpoenas or requests from government authorities; (b) enforce the terms and conditions governing our products and services; (d) safeguard our rights, privacy, safety or property, as well as that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activities.
   
   8. Business Transfers

   In the event of a business transaction (or potential business transaction) such as a merger, consolidation, acquisition, reorganization or sale of assets, or in the case of bankruptcy, Cadency may sell or transfer some or all of its business or assets, including your personal data. In such incidences, we will make reasonable efforts to ensure that the recipient honors the terms outlined in this Privacy Policy.
   
   9. To Other Parties with Your Permission or to Fulfill a Contract They Have with You

   Cadency reserves the right to share your personal data with third parties not covered by the aforementioned categories when you have given us your permission to do so. Moreover, such sharing may take place with parties with whom you have a contractual agreement, and the transfer of your personal data is essential to fulfill the obligations outlined in that contract.

2. When We Share Information Generally
   

   We share the information we collect in various ways, including:

   • For marketing purposes as part of joint marketing arrangements. You may opt out of receiving our marketing communications at any time by contacting us at [email protected] or by using the unsubscribe link in our communications. If you wish to opt out of receiving marketing communications from our joint marketing partners, you must do so directly with those partners. 
   • With certain third-party vendors that help us administer the Sites and/or Services, including by:
     • Storing and hosting our content or your data.
     • Performing analytics on our Sites and Services.
     • Providing operations and marketing assistance to us.
   • When you request us to share specific information with third parties, such as through your use of social media widgets or login integrations.
   • With marketing-related business partners to gain insights about your interactions with our products and Services enabling us to better advertise to you and customize our offerings.
   • With corporate affiliates, including any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
   • With counterparties during corporate events like sales, mergers, reorganizations, sale of assets, dissolutions, or similar occurrences, where some or all personal information may become part of the transferred assets.
   • To the extent permitted by law, when required by law, in connection with a court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of us or others.
   
   1. Social Features
   

   Certain features of the Services allow you to initiate interactions between the Services and third-party services or platforms, known as “Social Features”. These features allow you to click and access our pages on specific third-party platforms, such as Twitter and Facebook, and engage with our content on those platforms (i.e., “like” or “share” content). Utilizing Social Features may involve the collection and/or use of your information by third parties, which will be subject to the privacy policies of those platforms. Information you post or make accessible through Social Features or similar third-party services may be publicly displayed by the third-party service you are using. Both we and the third party may have access to details about you and your usage of both our Services and the third-party service.

We implement commercially reasonable administrative, physical, and technical safeguards to prevent any unauthorized use, access, destruction, loss, alteration, or disclosure of your data. 

While we take commercially reasonable measures to protect your data, it’s essential to note that perfect security is not guaranteed for any internet-based service. No security system is entirely impenetrable. Despite our security measures, we cannot ensure the absolute security of our databases, and we cannot guarantee that the information you provide will not be intercepted while being transmitted to and from us over the Internet. 

1. Data Protection Officer

    

   We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice or any privacy related queries, please contact the DPO using the details set out below:

   Data Protection Officer, Cadency
   Email address: [email protected]
   Postal address:
   2750 14^th Avenue, Suite 305
   Markham, Ontario, L3R0B6 Canada

2. Legal Basis for Processing (EU and UK)

    

   Processing Purpose	Legal Basis
   Providing our Services	Processing is necessary in the performance of contractual obligations related to delivering Services or necessary steps we must undertake prior to providing Services.
   · For compliance, fraud prevention and safety · To create anonymous data	These processing activities constitute our legitimate interests to securely operate in a secure and (regulatory) compliant manner.
   To comply with law	Processing is necessary to comply with legal obligations.
   With your consent	Processing is based on your consent. Where we rely on your consent, you have the right to withdraw it at anytime in the manner indicated at the time we collect your information or by contacting us via the following link here.

3. Use for New Purposes

    

   We may use your personal data for reasons not described in this Privacy Policy, provided that such usage is permitted by law and aligns with the original purpose for which the data was collected.
4. Automated Decisions, Credit Reference Agencies and Fraud Prevention Agencies

    

   At times, we employ automated decisions based on your personal data, sourced either directly from you or obtained from third parties like credit reference and fraud prevention agencies. We will only do this where it is required in connection with a contract, authorized by law, or based on your explicit consent. You can contact us for more information on automated decision making. Refer below to the section titled “Your Individual Legal Rights” for more information.

    

5. How Long Will You Use My Personal Data?

    

   The duration for which we use your personal data will be determined by the purpose for collection and utilization. This may include our need to satisfy a legal, regulatory, accounting, or reporting requirement.
    

   To determine the appropriate retention period for personal data, we evaluate factors such as the amount, nature, and sensitivity of the personal data, potential risks associated with unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
    

   In general, we retain your personal data for the duration of your involvement with us and for as long as reasonably necessary afterwards. However, different retention periods may apply depending on the nature of the Service you are using. Legal requirements may also mandate specific retention periods for certain types of information.

    

6. Your Individual Legal Rights

    

   Under specific circumstances, individuals in Europe or the United Kingdom have rights under data protection laws concerning their personal data. If you are located in Europe or the United Kingdom, you can request the following actions regarding your personal data that we hold:
   • Access: You may ask us if we are processing your personal data and, if so, for a copy of the personal data we hold about you, along with certain other information about our processing activities.
   • Correction: If any personal data we hold about you is incomplete or inaccurate, you have the right to request corrections, though we may need to verify the accuracy of the new data you provide.
   • Erasure: This allows you to ask us to remove or delete personal data when there is no valid reason for us to continuing process it. You also have the right to ask us to delete your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
   • Object: If we process your personal data based on legitimate interest, you may object if you believe it impacts on your fundamental rights and freedoms. You also have the right to object when we process your personal data for direct marketing purposes.
   • Restriction: You may ask us to suspend our use of your personal data in the following scenarios:
     • If you want us to establish accuracy of the data.
     • Where our use of your personal data is unlawful, but you do not want us to erase it.
     • Where you need us to hold your data for a longer period than required, because you need it to establish, exercise or defend legal claims.
     • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
   • Transfer / Portability: Where possible, we will provide you, or a third party you chose, with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to personal data you initially provided consent for us to use or where we used the information to perform a contract with you.
   • Withdraw Consent: Where our processing is based on your consent, you may withdraw that consent at any time. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
   • Automated Decision Making. You have the right not to be subject to automated decision making (e.g., profiling) that significantly affects you. The exercise of this right is not available to you in the following cases:
     • The automated decision is required to enter into, or perform, a contract with you.
     • We have your explicit consent to make such a decision.
     • The automated decision is authorised by local law of an EU member state.

   However, in the first two cases outlined above, you retain the right to seek human intervention regarding the decision, to express your viewpoint and to challenge the decision.

   You can initiate requests to exercise these rights by contacting Cadency using the provided link here. To confirm your identity and validate your entitlement to exercise a right regarding your personal data, we might request specific information from you, such as a merchant identification number or account number. This is a security measure to prevent the disclosure of personal data to unauthorized individuals. We may contact you to ask you for further information in relation to your request to speed up our response.

   There may be legal or other grounds that prevent us from fulfilling a request to exercise your rights. We will apply lawful exemptions to individual rights where appropriate. If we decline your request, we will tell you why, subject to legal restrictions.

   You will not have to pay a fee to exercise any of your rights relating to your personal data. However, in cases where requests are clearly unfounded, repetitive or excessive, we may charge a reasonable fee, or refuse to comply. We commit to promptly addressing all legitimate requests within the timeframes stipulated by applicable law. Typically, responses must be provided within one month from the receipt of the request. It is important that requests are identified and submitted using the provided link here as soon as possible. Response times may vary, especially for complex requests, in which case, we will notify you and provide updates. Any transmission of your personal data will be handled in a secure manner.

   If you are situated in Europe, you have the right to file a complaint with a supervisory authority at any time. For more information go to https://edpb.europa.eu/about-edpb/board/members_en. If you are located in the UK, you also have a right to make a complaint to the ICO https://ico.org.uk/.

We do not intentionally collect personal information from individuals under the age of 13. If you are under 13, please do not give us any personal information and do not use the Sites or Services. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us immediately, and we will delete that information from our databases.

When you visit the careers section of our Sites and submit a job application, we collect the information you provide in connection with your application. This includes business and personal contact information, professional credentials and skills, education and work history, and other information typically found on a resume. If you voluntarily share diversity information, we will also include that in our records. We use this information to facilitate our recruitment activities, handle employment applications, evaluate candidates for job opportunities, and monitor recruitment statistics. We may also use this information to operate and improve the Services, and as otherwise necessary for compliance, fraud prevention, and safety purposes.

The Sites may contain links to third-party websites, including those of the Companies involved in the transaction processing chain (such as banks, liquidity providers and settlement providers) participating in the offering of third-party account services, foreign exchange, and payment products made available to you through the Services (“External Sites”). However, it’s important to note that we neither endorse nor take responsibility for the content found on any linked External Sites or for the privacy practices of the third parties operating such sites. Before using any External Site, please refer to the terms of use and privacy policies of the External Sites for detailed information, as those terms and policies govern your use of such External Sites.

If you prefer to opt out of the use of your personal information by our Services, we are here to assist you. Please email us at [email protected] and specify the details of your opt-out preferences. Please be advised that certain uses and sharing of your information may be required to continue providing certain Services to you, and opting out may result in the unavailability of certain prepaid Services without eligibility for a refund.

Please note that under certain federal regulations, including the GLBA, you may not be able to opt out of the use and sharing of your personal information, in connection with seeking, applying for, or obtaining account services, foreign exchange, and payment Services from us. For more information on such financial products, and our data practices, please review our GLBA Privacy Notice.

For residents of California, state law requires us to provide you with additional information about how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act of 2018, as amended (the “CCPA”)).

Certain federal and state financial regulations, including the GLBA, the California Financial Information Privacy Act (“FIPA”), and specific federal and California health privacy laws, govern the information you provide when seeking, applying for, and/or obtaining our Services. Consequently, this information is not subject to the CCPA. In this section of our Privacy Policy, we provide disclosures and information for California residents regarding the limited personal information we collect that is subject to the CCPA.

California residents who have established business relationships with us may choose to opt out of us sharing their personal information with third parties for direct marketing purposes. If you are a California resident and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your personal information to third parties for their direct marketing purposes, please send an email to [email protected]

In the preceding twelve (12) months, we collected and disclosed the following categories of personal information about Visitors or Cadency Subscribers who are California residents:

Purposes for Collection, Use, and Sharing. We use and disclose the personal information we collect for our commercial purposes, as further described in this Privacy Policy, including for our business purposes:

• Auditing related to our interactions with you.
• Legal compliance.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and necessary prosecution.
• Debugging.
• Performing services (for us or our service provider).
• Internal research for technological improvement.
• Internal operations.
• Activities to maintain and improve our services.
• Other one-time or short-term uses.

California Residents’ Privacy Rights. Except as excluded above or limited below, the CCPA grants California residents the following rights to Request:

• Information: You can request information about how we have collected, used and shared your personal data during the past 12 months. We have made this information available to California residents without having to request it by including it in this Privacy Policy.
• Access: You can request a copy of the personal information that we maintain about you.
• Deletion: You can ask us to delete the personal information that we collected or maintain about you.

Please note that there are various lawful reasons why we may not be able to delete your data or may be required to hold certain personal information — for instance, (i) where we must comply with legal, regulatory, or other requirements, (ii) in case of exercising or defending legal claims, and/or (iii) where regulatory or contractual retention periods apply.

Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.

Timing: We will respond to requests within 45 days of receiving them. If additional time is needed, we will notify you and may take up to a total of 90 days to respond to your request.

Non-Discrimination: Exercising your rights under the CCPA will not result in any discriminatory actions against you.

How to Submit a Request: To request access to or deletion of personal information, you can either use this link or email us at [email protected].

Identity Verification: Compliance with the CCPA requires us to verify the identity of the individual submitting a request to access or delete personal information before providing a substantive response.

Authorized Agents: California residents can designate an “authorized agent” to submit requests on their behalf. The authorized agent must provide a written authorization confirming their authority, and we are required to verify their identity.

No Sale of Personal Information: We do not sell personal information.

Cookies & Tracking Technologies: As outlined in this Privacy Policy, we use cookies and other tracking technologies to analyze traffic on our Sites and facilitate advertising. To understand how you can opt out of our (and our third-party advertising partners’) use of cookies and other tracking technologies, please review the instructions provided below.

As part of our online operations, we utilize services from companies like Google and Facebook that employ tracking technologies. These technologies, including cookies and web beacons, collect information directly from your device about your browsing activities, website interactions, and device details. Below are concise ways to opt out of having your online activity and device data collected through these services:

• Blocking Cookies in Your Browser: Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. Many browsers accept cookies by default until you change your settings. To adjust your browser settings, refer to your browser’s instructions for more details. Alternatively, visit  www.allaboutcookies.org for comprehensive information on managing and deleting cookies.
• Blocking Advertising ID Use in Your Mobile Settings: Your mobile device settings may provide functionality to limit the use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Using Privacy Plug-Ins or Browsers: You can block our Sites from setting cookies used for interest-based ads by using privacy-focused browsers like Brave, or installing plugins like Privacy Badger, Ghostery or uBlock Origin. Configure them to block third party cookies and trackers.
• Platform Opt-Outs: Certain advertising partners offer opt-out features allowing you to opt out of use of your information for interest-based advertising:
  • Google: https://adssettings.google.com
  • Facebook: https://www.facebook.com/about/ads
  • Twitter: https://twitter.com/personalization
• Advertising Industry Opt-Out Tools: Limit use of your information for interest-based advertising through these opt-out options:
  • Digital Advertising Alliance: http://optout.aboutads.info
  • Network Advertising Initiative: http://optout.networkadvertising.org/?c=1

Google Analytics Opt-Out: To opt out of tracking by Google Analytics, click here.

For additional inquiries or more information about our information collection, usage, or disclosure practices, please contact us at [email protected].