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This Privacy Statement is effective as of March 19, 2019. ColorTokens, Inc. and its subsidiaries around the world (“ColorTokens”, “we”, “us” or “our”) understand that when our clients, partners and other individuals ( “you” or “your”) provide personal data to ColorTokens, they place their trust in us. This Privacy Statement describes ColorTokens’ practices regarding the collection, use and disclosure of personal information of an identified or identifiable natural person (“personal data”) processed through the use of ColorTokens’ website at (the “Site”). This Privacy Policy (“Policy”) provides an overview of how ColorTokens, via our Site, products, and services, handles privacy and data protection. ColorTokens is committed to processing personal data in compliance with applicable laws, while taking into consideration the imperative interests of our you, our clients and different partners. This Privacy Statement does not apply to any third-party websites, services or applications, even if they are accessible through our Site. If your company has engaged ColorTokens to provide ColorTokens products and/or services (collectively, the “Services”), your company and ColorTokens have agreed to a separate agreement that, among other things, governs the use of all of the data collected and maintained by ColorTokens in connection with the operation of the Services. The agreement between your company and ColorTokens takes precedence over the conflicting provision in this Policy.

Information Collection & Sharing

What personal data we collect and why we collect it

ColorTokens primary goals in collecting information are to provide and improve our Site, administer your use of the Site, and to enable you to enjoy and easily navigate our Site.


In an effort to detect any potential spam, we may collect and retain any comments left on the Site along with the visitor’s IP address and browser user agent string. An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service if your email address is the same one used with the service. The Gravatar service privacy policy is available here: After approval of your comment, your profile picture is visible to the public in the context of your comment.


If you upload images to the Site, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the Site can download and extract any location data from images on the Site.

Contact forms

The details or information that you provide in the forms will be used strictly for communication purposes and will not be shared with any third party. The data is safe and secure and we ensure utmost caution in protecting your data.


If you leave a comment on our Site, you may opt-in to saving your name, email address and website in cookies. This feature is for your convenience so that you do not have to fill in your details again when leaving another comment. These cookies will last for one year. If you have an account and you log in to this Site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser. When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
Type of Cookies Description Managing Settings
Required cookies Required cookies enable you to navigate our Site and use its features, such as accessing secure areas of the Site. If you have chosen to identify yourself to us, we may place a cookie on your browser that allows us to uniquely identify you when you are logged into the Site and to process your online transactions and requests. Because required cookies are essential to operate the Site, there is no option to opt out of these cookies.
Functional cookies Functional cookies allow us to remember information you have entered or choices you make (such as your username, language and region) and provide enhanced, personalized features. Functional cookies may also be used to improve how our Site functions and to help us provide you with more relevant communications, including marketing communications. These cookies collect information about how our Site is used, including which pages are viewed most often. We may use our own technology or third-party technology to track and analyze usage information to provide enhanced interactions and more relevant communications, and to track the performance of our advertisements. In particular, we use Google Analytics (“Google Analytics”), a web analytics service provided by Google, Inc. Google Analytics uses cookies to help us analyze how our Site is used, including the number of visitors, the websites from which visitors have navigated to our Site, and the pages on our Site to which visitors navigate. This information is used by us to improve our Site. ColorTokens does not upload any data that would allow Google to personally identify an individual or data that identifies a particular device. ColorTokens may also utilize HTML5 local storage or Flash cookies for the above-mentioned purposes. These technologies differ from browser cookies in the amount and type of data they store, and how they store it. You can manage the placement of functional cookies on your browser via your individual browser settings. Note that opting out of functional cookies may impact the functionality of our Site and degrade your user experience. To opt out from data collection by Google Analytics, you can download and install a browser add-on, which is available here. To learn how to control functional cookies via your individual browser settings, click here. To learn how to manage privacy and storage settings for Flash cookies, click here.
Targeting or Advertising cookies We sometimes use cookies delivered by us or by third parties to show you ads for our products that we think may interest you on devices you use and to track the performance of our advertisements. For example, these cookies collect and remember information such as which browsers have visited our Site. The information provided to third parties does not include personal data, but this information may be re-associated with personal data after the third party receives it. ColorTokens also contracts with third-party advertising networks that collect IP addresses and other information from web beacons on our Site, from emails and on third-party websites. Advertising networks follow your online activities over time and across different websites or other online services by collecting device and usage data through automated means, including through the use of cookies. These technologies may recognize you across the different devices you use, such as a desktop or laptop computer, smartphone or tablet. Third parties use this information to provide advertisements about products and services tailored to your interests. You may see their advertisements on other websites or mobile applications on any of your devices. This process also helps us manage and track the effectiveness of our marketing efforts. See Section 4.3, below, to learn more about these and other advertising networks and your ability to opt out of collection by certain third parties.

Embedded content from other websites

Articles on this Site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behave in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.


Our Site uses plugins from YouTube, which is operated by Google. The operator of the pages is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established. Here, the YouTube server is informed about which of our pages you have visited. If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account. YouTube is used to help make our Site more appealing. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO. We do not control any third-party websites or their privacy practices. We do not endorse or make any representations about third-party websites. Further information about handling user data, can be found in the data protection declaration of YouTube under

Google Web Fonts

For uniform representation of fonts, this page uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly. For this purpose your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our plugin. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO. If your browser does not support web fonts, a standard font is used by your computer. Further information about handling user data, can be found at and in Google’s privacy policy at


We use web analytics to understand anonymous visitor demographics and behavior data to enhance the experience. In accordance with the tools we use, we do not collect or share any personally identifiable data. If you are a logged in user on the Site, then the Site collects your behavior data to recommend, suggest or improve your experience with the Site.

Who we share your data with

We do not share or otherwise disclose personal data about our Site visitors or others that interact with ColorTokens or our products or services, except as described herein. We may share personal data with various parties, including:
  • Our contracted service providers that process personal data on our behalf for IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment

  • Affiliates within our corporate group that process personal data for customer support, marketing, technical operations and account management

  • Sponsors of events, webinars or contests for which you register

  • Third-party social media and advertising networks, which usually act as separate controllers, so that we can advertise on their platforms

  • In individual instances, professional advisers who provide consultancy, banking, legal, insurance and accounting services, or if we are involved in a merger, reorganization, asset sale or business combination

  • Public and government authorities, to the extent we are compelled to disclose personal data to comply with our legal obligations.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue. For users that register on our Site (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Site administrators can also see and edit that information. We retain your personal data only for as long as is necessary to fulfill the purpose for which the data was collected from you and in consideration of and compliance with applicable legal or regulatory requirements to maintain the data for legitimate purposes. For example, where required by law for audits or accounting requirements, to enforce our agreements or to handle disputes. When personal data is no longer needed for the purpose it was collected or processed or to comply with a legal obligation, we securely destroy it.

What rights you have over your data

  • Request access to your personal data and the processing activities on the personal data

  • Request restriction of the processing of your personal data in certain circumstances

  • Request erasure of your personal data in certain circumstances

  • Request that your personal data is rectified if it is inaccurate or incomplete

  • Receive your personal data provided to us as a controller in a structured, commonly used and machine-readable format in certain circumstances

  • Withdraw your consent provided at any time by contacting us

If you have an account on this Site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

To facilitate our business practices, your personal data may be collected, transferred to and stored by us in the United States and by our affiliates in other countries where we operate, including countries outside the European Economic Area (EEA). We have implemented safeguards to ensure an adequate level of data protection where your personal data is transferred to countries outside the EEA, such as standard contractual clauses for the transfer of personal data as approved by the European Commission (Art. 46 GDPR). Visitor comments may be checked through an automated spam detection service.

Additional information

How we protect your data

The data that we collect about visitors is completely protected, safe and secure within the respective platforms. As each and every platform we use are compliant with security features, the data we collect cannot be used by any third-party services.

What data breach procedures we have in place

The data is protected in a safe and secure platform. We have ensured complete security compliance to protect the data from access for unauthorized usage. Neither our team members or hackers can access the data without the necessary permissions. We user ColorTokens technology to isolate the data or information, and any breach will limit the amount of data being lost to a fraction.

What Data Do We Receive From Third Parties

We collect data from third-party services to enhance your experience or deliver tailored communication. The data collected is limited to advertising, industry and your public profile data.

What Automated Decision Making and/or Profiling We Do With User Data

The profile that we collect from the data you provide are used for profiling, grouping and segmenting. The data is used for communication and advertising. Based on the behavior your exhibit on the Site, it is used to personalize the communication but not limited to website, email, social communication and advertisements.

Industry regulatory disclosure requirements

ColorTokens does not collect any financial information or store any information that we collect through forms in our data center. Information collected through forms is stored with the respective third-party services in compliance with the data and privacy laws in their respective industries. ColorTokens adhere to all data privacy laws that are in enforced across regions and territories worldwide.

Protection Of Children’s Information

This Site is not designed to attract children under the age of consent in their country of residence. We do not knowingly solicit personal information from or market to any children and we request that children under the age of consent not submit personal information to us through our Site. If you believe that we have received information from any children, please notify us immediately, and we will ensure that reasonable efforts will be made by us to delete such information from our database.

Changes To This Policy

Any personal data that we process is subject to this Policy. We may, however, modify and revise this Policy from time to time. If we make any material changes to this Policy, we will notify you of such changes by posting the updated Policy on the Site, along with indication of when such changes will become effective.


To exercise your rights relating to your personal data, or if you have questions regarding our privacy practices, please contact us at [email protected] or at our mailing address below: ColorTokens, Inc. 3590 North First St, Ste 320, San Jose, CA 95134 Attn: Legal

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