I. APPLICATION OF THIS PRIVACY POLICY

This Privacy Policy explains the data collection practices that apply to (i) our Customers, including publishers, advertisers, or other business partners, and (ii) visitors to the Site and our Customers’ websites or other online products where our Services are displayed. For clarity, "Users" refers to both Customers and End Users.

Additionally, this Privacy Policy outlines general provisions that apply to all Users. Any capitalized terms will have the meanings ascribed to them in the CondorX Terms or herein. When we mention "Personal Information", we refer to data that may be used, either alone or in combination with other information, to personally identify an individual (natural person), such as a name, email address, phone number, physical address, or other contact information. Certain types of data, such as your device's IP address, cookies, or other web tracking technologies, may also be considered Personal Information in specific contexts. While we do not use this data to personally identify you, we take measures to protect it from such use and handle it with the utmost care.

II. CUSTOMERS

As a Customer of our Services, in addition to the information about End Users (as detailed below), you may be asked to provide Personal Information when creating an account to establish a business relationship or integrate our Services into your website or other properties. Our data collection practices in these cases are as follows:

• INFORMATION WE COLLECT ABOUT CUSTOMERS

  If you are a Customer and you decide to open an account with us, you will need to provide certain Personally Identifiable Information such as your name, email address, the name of the entity you represent, a password to access your account, and details about the website you wish to register. We may also collect other information that you choose to share with us, including communications you submit via our Services (collectively referred to as "Customer Information").

• THE PURPOSES FOR COLLECTING CUSTOMER INFORMATION AND THE LEGAL BASIS

  We collect and use Customer Information for the following purposes:

  • To deliver our Services and to contact Customers who wish to engage with us or our Services;
  • To respond to Customer inquiries or communications;
  • To provide Customers with newsletters, promotional offers, updates, and other relevant information via email.

  The legal basis for processing this information is contract-based, as Customers agree to our business terms and conditions when they enter into a partnership with us.

• SHARING CUSTOMER INFORMATION

  Except in the following instances, we do not share Customer Information:
  We may disclose Customer Information to (i) our affiliates, parent companies, or subsidiaries to help us facilitate the Services; (ii) third-party processors, service providers, contractors, and vendors who need access to Customer Information to perform their functions; (iii) other Customers, where required for the provision of Services and with the Customer’s consent.

• CUSTOMER CHOICES REGARDING THEIR INFORMATION

  As a Customer, you have certain rights regarding your Customer Information, including the ability to edit, correct, update, or delete it. To exercise these rights, please contact us directly at privacy@condorx.com or reach out to your business contact at CondorX. Any emails we send to you that contain general or promotional information will include an option to opt-out or unsubscribe. However, even if you unsubscribe from marketing communications, we may retain your account and Customer Information and may contact you regarding updates to the Services or other relevant account matters.

Here’s a rephrased version of the document with the same legal terms and policies, changing the language while retaining the original meaning, and also updating Engageya to CondorX and using Roman numerals:

III. END USERS

For those who access the Services as End Users, the following data privacy practices will apply:

• INFORMATION WE COLLECT ABOUT END USERS

  When you access or interact with the Site or any Services, we may gather data related to your usage, based on the particular service or technology in question. The data we collect may include, but is not limited to, the following categories: device details (such as the device type, operating system, browser type, version, and language settings, all sourced from your ‘user agent’), the domain or URL of the website you're browsing that integrates our Services, and where you consume the Services. Additionally, we may retrieve the IP address from the device that accessed the Services, primarily for user authentication and fraud detection purposes. In these cases, the IP address is separated from other data to avoid identifying individuals, as we do not link it to other data points. Such data, in conjunction with other collected information, is referred to as "User Information." We also use the IP address to derive general, non-personally identifiable information, such as the End User's country or region, which helps us serve content in a manner that is both relevant and localized for you. Together, "User Information" and "Customer Information" are referred to as "Information."

• HOW WE COLLECT END USER INFORMATION

  As is typical with most online services, we employ technologies like Cookies (also known as web beacons), pixel tags, and other similar web technologies to collect User Information. The following provides an overview of how cookie collection works, and we have also drafted a Cookie Policy that explains in more detail the types of cookies we use, as well as the reasons behind their usage.

• COOKIES

  A cookie is a small text file placed on your browser’s hard drive by the websites you visit. Many websites and online services use cookies. These cookies, in combination with web beacons, help the website or service function effectively, and also provide the website operator with useful insights. Cookies enhance your experience with the Services, making them more efficient. Certain Services or Platforms that we offer rely on cookies to function properly. While most browsers are configured to accept cookies by default, you can adjust your browser settings to disable cookies or delete them. Should you choose to disable cookies, you can still access the Website and use our Services, but certain features or services may not work as expected.

• WEB BEACONS

  In collaboration with our advertising partners, we may use standard internet technologies such as web beacons (also known as clear gifs), tracking pixels, and similar tools to collect analytical and anonymous data about the End Users who interact with the Services or its content. These technologies help us gain insights into user preferences and behaviors, allowing us to improve content offerings and refine our technology.

• LOG FILES

  Whenever you visit our Site or use our Services, technical information from your browser is automatically collected and stored in log files. This information may include your device’s IP address, browser type, operating system, access times, the content of any cookies previously accepted by your browser, and the referring website address. For further details about cookies and how we utilize them on our Site and Services, please refer to our Cookie Policy.

IV. REASONS FOR COLLECTING AND PROCESSING END USER INFORMATION AND THE LEGAL BASIS

It is important to note that we gather and process User Information to facilitate the provision of our Services, continually enhance them, and improve the overall Platform. The majority of our data processing activities are conducted based on our legitimate interests, which are critical for the operation, maintenance, and development of the Services and Platform. In other instances, we process data to personalize and enhance content suggestions (i.e., the End User experience), which is based on your consent, either provided directly or indirectly.

Below is an outline of data processing activities, their objectives, and their respective legal bases:

• LEGITIMATE INTEREST-BASED DATA PROCESSING

  We process Personal Information under our legitimate interest for the following purposes: (a) Operating and continuously developing and improving the Services, Platform, and underlying technology, including our content selection, filtering, verification, and monitoring capabilities; (b) Processing specific IP addresses to prevent fraud and to verify if the interacting End User is a human or a bot; (c) Analyzing and generating statistics about visits, interactions, and engagement with the content we offer.

• CONSENT-BASED DATA PROCESSING

  With your consent, which is granted by you to the websites on which our Services are integrated, we process Personal Information for the following purposes: (a) Enhancing the Services by delivering personalized content and advertisements tailored to the End User’s interests; (b) Processing web browsing activity for the purpose of retargeting.

• AD-HOC DATA PROCESSING

  In other cases, we may process Personal Information for specific, ad-hoc purposes, such as: (a) Responding to inquiries or communications, including any form submissions or other contact made with us. If you have provided us with your email address, for example, we will use your contact information and the content of your inquiry to process and respond to it, along with any subsequent communications; (b) For business Customers, we may process Personal Information to verify or authenticate your access to and use of your account; (c) For any legally permissible purposes at our discretion, including compliance with law enforcement requests or legal obligations.

V. SHARING AND DISCLOSURE OF USER INFORMATION

We do not share Personal Information with third parties except under the following circumstances:

• ANTI-FRAUD MEASURES

  For anti-fraud purposes, we may need to involve third-party monitoring services or certifiers who maintain and audit blacklists of IP addresses.

• DATA STORAGE AND PROCESSING

  We utilize third-party cloud services, data centers, and storage solutions to house and protect your Information. This means that your data may be transferred to and stored with entities located within the EU or outside it (including the US and Israel), for storage and other processing functions. These entities include Amazon Web Services (AWS), which is governed by their privacy policy found here, and EvoSwitch, which adheres to its own privacy policy available here. Our data processors may operate outside the EU or the European Economic Area (EEA). In such cases, we require that they follow strict data protection and privacy measures in compliance with applicable laws. Please note that the data protection practices of these third parties are governed by their own privacy policies.

• COMPLIANCE AND ENFORCEMENT

  We may share your Information with third parties if we deem it necessary or appropriate for the following purposes: (a) To comply with applicable laws, regulations, legal processes, or governmental requests; (b) To enforce our terms and conditions, including investigating potential violations thereof; (c) To detect, prevent, or address fraud or security concerns; (d) To safeguard the rights, property, and safety of our Services, systems, networks, technology, affiliated entities, users, or the public.

• THIRD-PARTY PARTNERS

  Under the basis of our legitimate interest, we share anonymized cookie-based data with advertisers and content providers to supply them with activity reports, market research, and insights about End Users' general trends and interests ("Content Selection Purpose"). Where we have received your consent from our publisher partner, we may also share additional information, such as content consumption preferences, to serve more relevant and personalized content. This data will not be shared if you have opted out of personalized content or have not provided consent during your initial visit to the website.

• MERGER, ACQUISITION, OR BANKRUPTCY

  In the event that we, or one of our affiliated entities, are acquired by, merged with, or sold to a third party, we reserve the right to transfer or assign the Personal Information and any other data we have collected. In such cases, the acquiring entity will be required to adopt its own data practices and uphold your rights under the jurisdiction in which you reside.

• OTHER THIRD PARTIES

  As necessary and based on our legitimate interests and your consent, we may share End User Information with third-party entities that assist us with business operations, product and service improvement, or technical development. These third parties may operate under their own privacy policies, which we require them to make available to you. We recommend reviewing the privacy policies of these third parties when their services are offered directly to you. These third parties may operate globally, with servers located in various regions.

VI. END USER CHOICES AND OPT-OUT

We believe in empowering our Customers and End Users with control over their engagement with our Services, in accordance with the terms of this Privacy Policy. Some Information is collected as it is essential for the provision of our Services. However, you have the right to exercise the following choices regarding your Information, depending on your place of residence:

• PROMOTIONS, SURVEYS, AND NEWSLETTERS

  You may choose to stop receiving promotional or advertising emails from us by clicking the unsubscribe link found in the footer of our emails. Please note that even if you opt out of promotional communications, you may still receive administrative emails related to your use of the Site or Services unless you request complete deletion of your contact information.

• COOKIES AND TRACKING TECHNOLOGIES

  You may configure your browser to block or refuse cookies from us or third-party services. You can also delete cookies manually. However, please be aware that blocking or removing cookies may hinder the functionality of some Services.

• OPTING OUT OF PERSONALIZED CONTENT

  If you prefer not to have your Personal Information processed, shared, or used for personalized content purposes, you may opt out by selecting your preferred settings below.

  Before opting out, please consider that doing so may impact your experience on websites you visit, such as receiving repetitive ads or general content, and you may encounter advertisements that are less relevant to your interests.

  Non-Personalized Recommendations (Opt-out)

  End Users have the option to opt-out from the collection and use of their Personal Information through mobile applications by adjusting their device settings as outlined below:

  • For iOS Devices: Navigate to Settings > Privacy > Advertising > Limit Ad Tracking.
  • For Android Devices: Navigate to Settings > Google > Ads > Opt Out of Interest-based Advertising.

  Please be aware that opting out will not prevent you from seeing content on websites or mobile applications where our Services are integrated. It will only stop personalized content from being displayed to you, either from us or our advertising partners, until you choose to opt-in again.

• CALIFORNIA PRIVACY RIGHTS

  Under the California Civil Code Section 1798.83, our California-based Customers are entitled to request certain information regarding our disclosure of Personal Information to third parties for direct marketing purposes. As an End User, if you have not provided Personal Information that can identify you, there would be no request to make. For Customers seeking more information, please contact us at privacy@condorx.com.

• EU DATA SUBJECT RIGHTS

  We process Personal Information in full compliance with the EU’s General Data Protection Regulation (GDPR).

• CANADIAN RESIDENTS

  Canadian residents may request information regarding our disclosure of Personal Information to third parties for their direct marketing purposes, if applicable. To make such a request or if you have questions about your Personal Information, please contact our compliance team at privacy@condorx.com.

VII. RIGHTS OF END USERS

You are entitled to request access to any Personal Information we hold about you, as well as to correct, delete, or request the suspension or limitation of the processing of your Personal Information.

To submit such a request, please reach out to us at privacy@condorx.com, specifying your request.

VIII. LINKS TO THIRD-PARTY WEBSITES

Our Services may feature third-party content, tools, and features that are not directly controlled by us ("Third-Party Content"). This content may include articles, graphics, videos, advertisements, offers, and interactive elements. Any interaction you have with such content is subject to the respective provider’s policies, terms, and conditions. We recommend reviewing the privacy policies of these third-party services whenever you engage with their content.

IX. DATA & INFORMATION SECURITY

We, along with our affiliated partners and third-party service providers, implement various security measures to safeguard information stored, processed, and transmitted within our systems. For instance, our site and data transmissions are encrypted using SSL protocols, ensuring secure handling of data both in transit and at rest. We periodically assess our data collection and security protocols to ensure they align with best practices, and work with third-party services that adhere to recognized security standards. Despite these measures, we cannot guarantee that unauthorized access or security breaches will never occur. Should you have any inquiries regarding our security practices, please contact us at privacy@condorx.com.

X. DATA RETENTION & DESTRUCTION

We will retain your information only as long as necessary to deliver and maintain the Services, comply with legal obligations, resolve disputes, and enforce agreements unless otherwise dictated by applicable laws.

XI. CROSS-BORDER DATA TRANSFERS

As part of our operations outlined in this Privacy Policy, your data (including Personal Information) may be transferred to countries outside of your country of residence or the country in which it was initially collected. In such cases, we take appropriate steps to ensure compliance with applicable legal requirements, including using contractual safeguards to ensure your data is handled with a suitable level of protection when shared with or processed by third-party vendors. By continuing to use our Services, and providing your consent as detailed in this Privacy Policy, you acknowledge and consent to the transfer of your data to these countries.

XII. CHILDREN’S PRIVACY

Our Services are not intended for individuals under the age of 16. We do not knowingly collect Personal Information from anyone under 16. If we discover that we have inadvertently collected data from a child under 16, we will take reasonable steps to delete that information promptly. If you suspect we may have collected such information, please contact us using the details provided below.