As used in this Privacy Policy, the terms “Confidence,” “we” and “us” refer to Confidence Systems Inc.

Confidence is committed to protecting and respecting your privacy.

This Privacy Policy describes how we collect, use, protect and share information about you that we obtain when you access and use our Website (defined below), including when you submit questions or feedback. This Privacy Policy also applies to information that we obtain when you communicate or interact with us outside of the Website, including by e-mail, telephone and otherwise.

Please read this Privacy Policy carefully to understand how we will treat your information before you start to use our Website or communicate with us outside the Website. This Privacy Policy also is intended to explain the conditions under which Confidence uses and discloses that information, and your rights in relation to that information. Changes to this Privacy Policy are discussed at the end of this document.

For purposes of this Privacy Policy, the following defined terms mean:

• “User” means any person or entity who accesses or uses the Website in any manner. References to “access” and/or “use” of the Website (and any variations thereof) include the acts of accessing or browsing the Website and accessing or using the Services.
• “Website” means any and all websites or products owned or operated by Confidence (including the websites currently located at https://www.confidence.com/ and https://www.csys.app), through which access to Confidence’s Services are available. References to the “Website” include any and all related features, functionality, tools, and content.

1. How We Collect Information

Information You Provide to Us

We collect information that you provide directly to us, including when you register for an account, use the Services, update your e-mail preferences, respond to a survey or provide other feedback about the Website, attend one of our events, express an interest in Confidence, phone us, contact us by email or use our website chat service, or contact us with questions or comments about the Website. This information includes the following categories of personal information that you may provide:

• Contact Information, such as name, address, email address and telephone number;
• Account information, such as account sign-in information and passwords for the Website;
• Payment Information, such as payment card information and other billing information (e.g., card image, card number, cardholder name, expiration date and card verification code); and

We may also collect information about you if a company or organization authorizes you to manage its account or use our Website on its behalf.

We will not ask for or request sensitive information such as government identifiers, medical information, or financial information (except in connection to payments). Please do not provide this information to us through e-mails, feedback forms or in any other way unless specifically requested.

Information Collected Automatically

We also collect certain technical information automatically when you access, browse, and use our Website, including information that we automatically receive and record from your browser or mobile platform on our server logs. This technical information helps us operate and provide our Website to you, and includes:

• Device Information, including information about the device(s) you use to access our Website, including MAC address, IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device type, device and application identifiers, operating information, mobile carrier, and cookies;
• Service Use Data, including information about your visits to the Website, including the full URL clickstream to, through, and from the Website, dates and times, pages you view, searches you run, length of time browsing search results, specific search results you select to view, length of visits to other pages, page interaction information (such as scrolling, clicks, and mouse-overs), your engagement with certain variable/dynamic elements of a page and methods used to browse away from the page and other information we need and use to facilitate your use of our Website (including to provide access to third party websites and services), such as URL requests, destination IP addresses, or device configuration details;
• Cookies and Beacons, including small data files stored on your device that act as a unique tag to identify your browser and code embedded in a website, video, email, or advertisement that sends information about your use to a server, which is further explained in the Cookies and Beacons below;
• Location Information, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level); and
• Log Files, which include page response times, download errors, and other record events that occur in connection with your use of the Website.

Information from Other Sources

We may receive certain information about you from other sources, including:

• Business Customers, which are our business customers whom we provide our services on behalf of and grant you access to the Website. This information may include contact and credentialling information as necessary for you to use the Service.
• Service Providers, which are third parties that provide services on our behalf including security and fraud analysis and may provide us certain information about how you may be using our Website.

On occasion, we may compare or combine Personally Identifiable Information (defined below) from third party sources to/with other information we have collected. For example, we may obtain contact information from other sources in order to contact you if we think you or the company you represent would be interested in our Website.

2. Information On Behalf Of Our Customers

In the course of providing products and services for our customers, we may collect and process certain information about individuals at the direction of our business customers. Such data has historically included contact data, content, service use data, device connectivity and configuration data, and location data, among other information.

3. How Information May Be Used

Personally Identifiable Information

We may use the Personally Identifiable Information we collect, to:

• create and manage your account;
• provide the Website to you;
• operate our Website, including access management, payment processing, Website administration, internal operations, troubleshooting, data analysis, testing, research, statistical and survey purposes;
• send you information that enables you to use our Website;
• contact you about activity on your account;
• generate reporting regarding the use of our Website by Users;
• respond to your requests, feedback or inquiries;
• notify you about updates, information, or alerts regarding our Website;
• comply with laws, regulations, and other legal requirements;
• comply with relevant industry standards and our policies;
• protect and enforce our rights and the rights of other Users against unlawful activity, including identify theft and fraud, and other such violations;
• protect and enforce our rights arising under any agreements entered into between you and us, including billing and collection;
• protect the integrity and maintain the security of our Website, including secured areas of the Website;
• operate, evaluate and improve our business, including but not limited to conducting surveys and market research, developing new products, services, and promotions (such as, for example, special events, programs, offers, contests), analyzing and enhancing existing products, services, and promotions, managing our communications; performing accounting, auditing, and other internal functions;
• provide you with information and advertisements about products, services, and promotions from us or third parties, which may interest you; and
• administer your participation in such products, services, and promotions.

Non-Personally Identifiable Information

Other data derived from your use of the Website that does not identify you is treated as “Non-Personally Identifiable Information,” unless it is combined with Personally Identifiable Information, or unless otherwise required by applicable law.

In addition to the uses described above, we may also use Non-Personally Identifiable Information to present content in a manner that is optimized for your device.

We may also combine technical information, or Non-Personally Identifiable Information, about your use of our Website with information that we obtain from other Users to use in an aggregate or anonymous manner for similar purposes.

4. How Information May Be Shared

Personally Identifiable Information

We will not sell or share your Personally Identifiable Information with third parties for the third party’s own direct marketing purposes without your express consent.

We may share Personally Identifiable Information with:

• Business Customers. Where we are providing this Website to you on behalf of our business customers, we may share limited information about your use of the Website with such business customers in accordance with our agreements with such business customer;
• Business Customer Authorized Service Providers. Where required by our business customers, we may provide certain information to other companies as instructed by such business customers for purposes such as to enable their systems to operate with the Website;
• Affiliates. We may share information with our subsidiaries and affiliates;
• Service Providers of Confidence. We may share information with our service providers to the extent reasonably necessary to enable us to operate our business and provide our Website described in this Privacy Policy (e.g., to an e-mail service provider in order to enable us to e-mail you);
• Authorized Individuals. We may share information with the designated administrator of your account, if you have an individual corporate subaccount, regarding use of the Services by individual subaccounts;
• Parties to Transactions involving Our Business. We may share information with a buyer or other successor and related entities involved in the transaction, in the event of a merger, divestiture, restructuring, reorganization, dissolution, liquidation, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personally Identifiable Information held by us about our Users is among the assets transferred;
• Consent. We may share your information with other third parties with your express consent for any purpose disclosed by us when you provide the information; and you may request such disclosure in writing, upon which we will comply as required by applicable law.

We may also disclose Personally Identifiable Information with law enforcement agencies, government officials, or other third parties as necessary for the purpose of:

• complying with any court order, law, or legal process, including to respond to any government or regulatory request;
• preventing fraud and providing credit risk reduction;
• investigating potential unauthorized access or misuse of our Website or other breach of our Terms of Use, Supplemental Terms (as defined below), Website Rules (as defined below) other agreements;
• protecting the assets or property, and enforcing the rights of Confidence, including for billing and collection purposes; and
• protecting the rights, property, or safety of our Users or others.

Non-Personally Identifiable Information

In addition, we may share Non-Personally Identifiable Information, including aggregated or anonymized data:

• with analytics, search engine, or other service providers that help us improve our Website;
• to report to our affiliates, licensors, and service providers about the use of various aspects of the Website; and
• with other Users or prospective Users of the Website.

5. Cookies and Beacons

We may use cookies, beacons, and similar technologies, now or in the future, to support the functionality of our Website. This provides a better experience when you visit our Website and allows us to improve our Website. Our service providers may use cookies and beacons to collect and share Non-Personally Identifiable Information about your activities both on our Website and on other websites. In addition, third parties that are unaffiliated with us may also collect information about you, including tracking your browsing history, when you use our Website. We do not have control over these third-party collection practices. If you wish to minimize these third-party collections, and you can adjust the settings of your browsers or install plug-ins and add-ins.

• Browser Cookies. A browser cookie is a small file placed on the hard drive of your computer. That cookie then communicates with servers, ours or those of other companies that we authorize to collect data for us and allows recognition of your personal computer. We associate cookies with Personally Identifiable Information only if you use the automatic recognition capabilities on restricted areas of the Website, order a Service, use the personalization services available as part of the Website, or ask us to contact you with additional marketing information. We do not otherwise collect Personally Identifiable Information from browser cookies, and we do not associate browser cookies with your Personally Identifiable Information.You may use the tools available on your computer or other device to set your browser to refuse or disable all or some browser cookies, or to alert you when cookies are being set. However, if you refuse or disable all browser cookies, you may be unable to access certain parts or use certain features or functionality of our Website.You may choose whether to activate automatic recognition when you register for an account. After registration, you may disable the persistent cookie that supports recognition using the tools in your browser. If you choose to disable the cookies that support automatic recognition, you will need to re-enter your [User ID/username/email] and password each time you access a gated portion of the Website.Unless you have adjusted your browser settings so that it refuses all cookies, we may use cookies when you direct your browser to our Website.To learn more about cookies, you can visit https://www.allaboutcookies.org.

• Flash Cookies. Certain features of our Website may use local stored objects called flash cookies to collect and store information about your preferences and navigation to, from and on our Website. We also include cookies in our third party hosted video players to count the number of unique viewers who see a customer’s video press release and to provide aggregate reporting. The cookies do not identify you as an individual or track your online behavior. We do not collect Personally Identifiable Information from flash cookies, and we will not associate them with your Personally Identifiable Information.Flash cookies are not managed by the same browser settings as are used for browser cookies. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse Flash cookies, please note that some parts of our Website may be inaccessible or may not function properly.

• Beacons. Our Website and e-mails may contain small electronic files known as beacons (also referred to as web beacons, clear GIFs, pixel tags and single-pixel GIFs) that permit us to, for example, count Users who have visited those pages or opened an e-mail and for other website-related statistics. Beacons in e-mail marketing campaigns allow us to track your responses and your interests in our content, offerings, and web pages. You may use the tools in your device to disable these technologies as well.

Google Inc. (“Google“) is one example of a service provider that uses cookies or similar technologies to collect information about your browsing activities over time and across different websites following your visit to our Website. Google Analytics is a web analytics service provided by Google that uses first-party cookies to track Users’ interactions and collect other information about how you use our Website. Google Analytics collects information anonymously. We then use the information to compile reports, including usage trends, to help us improve our Website. You can opt out of Google Analytics without affecting how you visit our site. For more information on how Google uses this data, go to https://www.google.com/policies/privacy/partners/, or review the Google Analytics Terms of Service at https://www.google.com/analytics/terms/us.html. For more information about opting out of being tracked by Google Analytics across all websites you use, please visit https://tools.google.com/dlpage/gaoptout/.

6. Your Choices

We offer you certain choices in connection with the information we collect from you.

Email Communications

You may have the opportunity to receive certain communications from us related to our Website. If you provide us with your e-mail address in order to receive communications, you can opt out of marketing e-mails at any time by following the instructions at the bottom of our e-mails and adjusting your e-mail preferences. Please note that certain e-mails may be necessary for the operation of our Website. You will continue to receive these e-mails, if appropriate, even if you unsubscribe from our optional communications.

Cookies/ Beacons

If you wish to minimize information collected by cookie or beacon, you can adjust the settings of your browsers to notify you when you receive a cookie, which lets you choose whether or not to accept it. You can also set your browser to automatically reject any cookies. You may also be able to install plug-ins and add-ins that serve similar functions. However, please be aware that some features and services on our Website may not work properly. In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests.

Network Advertising Initiative

Certain websites you visit may provide options regarding advertisements you receive. If you wish to minimize the amount of targeted advertising you receive, you can opt out of certain network advertising programs through the Network Advertising Initiative (NAI) Opt-Out Page. Please note that even if you choose to remove your information (opt out) you will still see advertisements while you are browsing online. However, the advertisements you see may be less relevant to you. For more information or to opt out of certain online behavioral advertising, please visit https://www.aboutads.info.

Additionally, many advertising network programs allow you to view and manage the interest categories that they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.

Do Not Track

Some browsers support a “Do Not Track” (or, DNT) feature, a privacy preference that Users can set in certain web browsers, which is intended to be a signal to websites and services that you do not wish to be tracked across different websites or online services you visit. Our Website does not currently recognize or respond to DNT signals, so DNT settings do not change the way the Website operates.

Please note that we cannot control how third-party websites or online services you visit through our Website respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices.

Updating or Deleting Information

The accuracy of the information we have about you is important. Users may update their information at any time by contacting us at privacy@confidence.com.

7. Securing Your Information

The security of your information is important to Confidence, and we have established administrative, technical, and physical safeguards designed to protect your Personally Identifiable Information against unauthorized alteration, access, loss, theft, use or disclosure. Unfortunately, no system can guarantee complete security of your information. As a result, Confidence cannot ensure or warrant that your information, including your Personally Identifiable Information, is secure from unauthorized third parties. Thus, your use of the Website and communication with us about them is at your own risk.

8. Children

Our Website is directed to and is intended to be used only by persons who are 18 years of age or older. We do not knowingly collect information from children under 18. If you are under 18 years of age, you are not permitted to [register for an account or otherwise] submit any personally identifiable information to us, including your name, address, or e-mail address. If we discover that we have collected any personally identifiable information from a child under the age of 18, we will remove that information from our database as soon as possible. By submitting any personally identifiable information to us, you represent and warrant that you are 18 years of age or older.

9. Links To Third Party Websites

Our Website may contain links to third party websites and services, including those of our partner networks. Please note that these links are provided your convenience and information, and the websites and services may operate independently from us and have their own privacy policies or notices, which we strongly suggest you review. This Privacy Policy applies to Confidence and our Website only. We do not accept any responsibility or liability for the policies or practices of any third parties. If you chose to access any websites or services linked from our Website, please check the applicable policies before you use or submit any personal data to such website or service.

10. International Jurisdictions

The Website is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing our Website from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, which may not have laws as stringent with respect to the protection of personal information as those in your home country. Please do not use our Website if you do not wish for your information to be processed in the United States of America.

11. Changes To Our Privacy Policy

Confidence may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to this Privacy Policy will be reflected on this page and the effective date will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you. Users should regularly check this page for any changes to this Privacy Policy. Confidence will always post new versions of the Privacy Policy on the Website. However, Confidence may, as determined in its discretion, decide to notify Users of material changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that you always maintain and update your contact information.

Please note that we may condition your continued access to our Website on your consent to changes to this Privacy Policy.

12. Contact Us

If you have questions or comments relating to this Privacy Policy, or if you would like us to update information we have about you or your preferences, please contact us by email at privacy@confidence.com, or write to us at:

Confidence Systems Inc.
51 Cervantes Blvd, San Francisco, CA 94123

13. European Resident Disclosure

Roles of Parties

Data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”).

Confidence is not a controller and does not actively target the collection of any personal information from any individuals in Europe. However, in some circumstances, Business Customers of Confidence may provide data related to a person in Europe, in which case, Confidence acts a processor on behalf of the respective Business Customer, and the Business Customer is the controller. Any questions that you may have relating to the processing of personal data by Confidence on behalf of a Business Customer and your rights under data protection law should be directed to the Business Customer as the controller, not to Confidence.

Lawful Basis

Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers, partners, or customers; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.

Your Rights as a Data Subject

If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask not to have your personal data processed for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time.

If your personal data has been processed by us on behalf of a Business Customer and you wish to exercise any rights you have with such personal data, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of our Business Customer on whose behalf we processed your personal data. We will refer your request to that Business Customer, and will support them to the extent required by applicable law in responding to your request.

Complaints

If you have a complaint about our use of your personal data or response to your requests regarding your personal data, you may submit a complaint to the data protection regulator in your jurisdiction. We would, however, appreciate the opportunity to address your concerns before you approach a data protection regulator, and would welcome you directing an inquiry first to us. In addition to the contact information above, please contact in accordance with Contact Us above.