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Posted Date: 17th March 2022

Effective Date: 17th March 2022

This Privacy Policy (“Policy”) explains how your information is collected, used and disclosed by ColorTokens, Inc. (including its affiliates, subsidiaries or assignees) (“ColorTokens”, “we”, “us” or “our”) and applies to information we collect when our clients, partners and other individuals (“you” or “your”) use or access our online website at www.colortokens.com (the “Website”).

If you or your organization subscribe to ColorTokens’ products or services (collectively, the “Products/Services”) pursuant to a subscription agreement with ColorTokens or another agreement with a ColorTokens-authorized partner, the terms of that subscription agreement (or other data processing agreement) may contain different or additional privacy-related terms.

ColorTokens adheres with the relevant privacy frameworks and is committed to processing personal data in compliance with applicable laws. “Personal Data” means any information relating to an identified or identifiable individual and/or business data, including company name, business email address and business phone number shared with us or as may otherwise be defined under applicable data protection laws, while taking into consideration the imperative interests of you and our clients.

Please read this Policy carefully to understand our practices regarding your information and how we at ColorTokens handle it. If you do not agree with our policy and practices, you may choose not to use the Website or access the content. By accessing or using the Website, or otherwise providing your information to ColorTokens, you agree to this Policy in entirety.

This Policy does not apply to any third-party websites, Services, or applications, even if they are accessible through our website. Partners are governed under a separate privacy policy (Partner’s Privacy Policy) which is applicable under Partner Program. If your company has engaged ColorTokens to provide Services, your company and ColorTokens have agreed to a separate agreement that, among other things, governs the use of all 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 provisions mentioned in this Policy.

Changes To This Policy

We may, 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 our Website. The date this Policy was last revised is indicated at the top of this Policy. Your use of the Website, the content or the Services after the posting of such changes constitutes your consent to such changes. We encourage you to review our Policy whenever you use or access the Website or our content to stay informed about our information privacy practices and the ways you can help protect your privacy.

California Privacy Rights

For purposes of this section “Personal Information” has the meaning given in the California Consumer Privacy Act (“CCPA”). It describes how we collect, use, and share California consumers’ Personal Information in our role as a business, and the rights applicable to such residents. The California Consumer Privacy Act (“CCPA”) requires businesses to disclose whether they sell Personal Information. ColorTokens does not sell Personal Information. We might share the Personal Information with third parties only for the purpose of providing our Services and restricted to our authorized service providers or business partners who have explicitly agreed to our contractual limitations as to their retention, use, and disclosure of such Personal Information. This Policy also contains terms that reflect ColorTokens commitment to comply with the General Data Protection Regulation (the “GDPR”).

Information Collection & Sharing

What Personal Data we collect and why we collect it

We use your information mainly to interact with you, to provide you with support services, to make it easy to navigate our Website, to improve our Website and our products, and to offer you dynamic Services, content and Services that might interest you. By voluntarily providing us with this information, you represent that you are the owner of such Personal Information or are otherwise authorized to provide it to us.

The following are the types of information we gather:

Information You give Us: We collect any information you provide in relation to our offerings with regards to the Services provided. For e.g. – register for or attend a webinar event by ColorTokens or search for, subscribe to, or purchase ColorTokens Services

Automatic Information: We automatically collect certain information when you interact with our Website. For e.g. – network and connection information, such as the Internet protocol (IP) address or the location of your device or computer

Information from Other Sources: We might collect information about you from other sources, including service providers, partners, and publicly available sources. For e.g.  – marketing, sales generation, and recruitment information, including your name, email address or search results and links, including paid listings (such as sponsored links)

We use your Information as follows, where the processing is necessary to establish or administer our agreement with you:

  • Create a single sign on for access to your online account with ColorTokens, our portals, and our online community.
  • Verify your identity and entitlement to products or services when you contact us or access our Services.
  • Allow you to register opportunities.
  • Provide you with technical and customer support and enable the provisioning of services.
  • Register you for events.
  • Allow you to register products or services purchased on behalf of you or your company.
  • Communicate with you regarding support services and provide you with critical service updates.

We use your information as follows, where the processing is based on our legitimate business interests to communicate with you and improve users’ experience, improve our products and services, protect our security, and defend our legal rights.

We may also use your information where processing is necessary for us to comply with legal obligations, including responding to legal process or lawful requests. Lastly, we may use your information with your consent, where required by applicable law.

We also enable you to contact us by email with questions, comments, or requests. The information collected from these email communications is used to reply to such questions, comments, or requests.

We ask for and collect Personal Information such as your name and “Business Information” i.e., office address, phone number and email address when you register for or attend a sponsored event or other events in which ColorTokens participates.

Automatic Data Collection Technologies

We use cookies and various traffic tracking technologies to monitor use of the Website. A cookie is a small piece of data (text file) that a website, when visited by you, asks your browser to store on your device in order to remember information about you, such as your language preference or login information.

We use cookies or tags, including third party cookies and query string parameters in URLs, for different purposes, including presenting you with information based on your browsing preferences, such as language and geographical region; collecting statistics regarding your Website usage; allowing automated login; providing us with business and market information. We link cookies only to IP addresses and not to any other personally identifiable information about you to the Website.  We use third party services to analyze traffic to the Website. These third-party services use cookies to track non-personally identifiable information, link cookies only to IP addresses, and aggregate data about traffic to the Website. We also use cookies and pixels to collect information about our email campaigns, including whether you’ve clicked or opened an email we’ve sent you. However, we do not track your activities on other sites. If you click on our ads, we will know only the domain you came from.

Type of Cookies Description Managing Settings
Required cookies Required cookies enable you to navigate our Website and use its features, such as accessing secure areas of the Website.

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 Website and to process your online transactions and requests.

Because required cookies are essential to help with basic functionality. 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 Website functions and to help us provide you with more relevant communications, including marketing communications. These cookies collect information about how our Website 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.

ColorTokens may also utilize 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 Website 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 Website. 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 Website, 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 named Manage cookie preferences below, to learn more about these and other advertising networks and your ability to opt out of collection by certain third parties.
Cookies for Analytics Analytical cookies are used to understand how you interact with our website. These cookies help provide information on metrics the number of you, bounce rate, traffic source, etc.
Performance Cookies Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for you.

Manage cookie preferences

Cookie Settings

You can change your cookie preferences any time by clicking the above button. This will let you revisit the cookie consent banner and change your preferences or withdraw your consent right away.

In addition to this, different browsers provide different methods to block and delete cookies used by websites. You can change the settings of your browser to block/delete the cookies. Listed below are the links to the support documents on how to manage and delete cookies from the major web browsers

Chrome: https://support.google.com/accounts/answer/32050

Safari: https://support.apple.com/en-in/guide/safari/sfri11471/mac

Firefox:https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox?redirectslug=delete-cookies-remove-info-websites-stored&redirectlocale=en-US

Internet Explorer: https://support.microsoft.com/en-us/topic/how-to-delete-cookie-files-in-internet-explorer-bca9446f-d873-78de-77ba-d42645fa52fc

If you are using any other web browser, please visit your browser’s official support documents.

Embedded content from other websites

This Website may contain links to other websites. We are not responsible for the privacy practices of any websites other than our own. This Policy applies only to information collected by us on the Website and not to any third-party websites. We encourage you to review the policy of any such websites to understand their information practices.

Analytics

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 Website, then the Website collects your behavior data to recommend, suggest or improve your experience with the Website.

Who we share your data with:

We do not sell, lease, rent or give away Your personal and or business data or Business information. We only share Your Information as described below, with our affiliates, business partners, service providers that process information on our behalf, and law enforcement. If we share your Information, with our affiliates, business partners, service providers, they are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.

We may share Personal Data with the following:

  • Affiliates within our corporate group that process personal and or business 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 and or business data to comply with our legal obligations.

Retention and Disposal of Personal and or business data

For users that register on our Website, 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 their username which they cannot change). Website administrators can also see and edit that information.

We will not retain Personal Information in identifiable form when the purpose(s) for which the Personal Information was collected have been achieved and, there is no legal or business need to retain such personally identifiable information. Thereafter, the data will either be destroyed, deleted, anonymized, and/or removed from our systems.

What rights you have over your data

You can exercise your right to update, correct, revoke, delete, deactivate or update, under applicable data protection laws directly with respective ColorTokens entity by submitting an email request to: [email protected]

If you are a visitor located in the European Economic Area (“EEA”), ColorTokens is the data controller, it affords access, correction, and deletion rights to individuals upon request. If you wish to access, correct, update or request deletion of your Personal Information, you can do so at any time by contacting ColorTokens using our email at [email protected]rtokens.com

Where we send your data

If you are visiting the Website or accessing the content from the EEA or other regions with laws governing personal and or business data collection and use, please note that you are agreeing to the transfer of your Personal Information to the United States and other jurisdictions in which we operate. By providing your Personal Information, you consent to any transfer and processing in accordance with this Policy. This Privacy Policy will apply even if we transfer personal and or business data to other countries. We implement adequate safeguards to ensure an appropriate level of data protection where your personal and or business data is transferred to countries outside the EEA, such as standard contractual clauses for the transfer of personal and or business data as approved by the European Commission (Art. 46 GDPR). Whenever we transfer Personal Information to other jurisdictions, we will ensure that the information is transferred in accordance with this Policy and as permitted by applicable data protection laws and the Personal Information is anonymized, and/or de-identified form that cannot reasonably be used to identify you.

Visitor comments may be checked through an automated spam detection service.

Additional information

How we protect your data

The data that we collect about you is protected, safe and secure within the respective platforms. We secure the Personal Data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Data is protected using appropriate physical, technical and organizational measures.

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.

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 adheres to all applicable data privacy laws that are enforced across regions and territories worldwide.

Protection Of Children’s Information

This Website 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 Website. If you believe that we may have collected Personal Information from someone under the applicable age of consent in your country without proper consent, please let us know using the Contact Us feature and we will take appropriate measures to investigate and address the issue promptly.

Questions?

To exercise your rights relating to your Personal Data, security, or if you have questions regarding our privacy practices, please contact us at [email protected] or [email protected] or at our mailing address below:

To Company: Attn: Office of the General Counsel
ColorTokens, Inc.
3590 N. First Street, Ste 320, San Jose, CA 95134
Email: [email protected]

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