Privacy Policy

Introduction

This privacy policy (“Privacy Policy”) describes the information collection practices that Candorly (“Candorly,” “we,” “us,” or “our,” if not explicitly referring to one company) follow when handling Personal Information (defined below) that we collect or receive in conducting our business, including through our products, services, content, websites, and user applications (the “Sites”), as further explained below.

EU Users. If you are a resident of the European Union (“EU”), you may have additional rights under the EU General Data Protection Regulation(the “GDPR”) with respect to your personal information, as outlined below. For the purposes of this Privacy Policy, references to the EU also include the United Kingdom, Switzerland, and the European Economic Area countries Iceland, Liechtenstein, and Norway.

California Users. If your Personal Information is subject to the California Consumer Privacy Act, California Civil Code §1798.100 et seq. (with any implementing regulations and as may be amended from time to time, “CCPA”), please review this Privacy Policy and see the section below regarding California Users for a description of your rights under, and other information related to, the CCPA.

Nevada Users. If the information we collect from or about you is subject to Nevada’s data privacy law, Nevada Revised Statutes § 603A.300 et seq. (with any implementing regulations and as may be amended from time to time, “Nevada Privacy Law”), please review this Privacy Policy and see the section below regarding Nevada Residents for a description of rights under and other information related to the Nevada Privacy Law.

Definitions

“Personal Information” means any information relating to an identified individual, or to an individual who can be identified, directly or indirectly, by reference to such information, which may include, one or more factors specific to their cultural or social identity. Without limiting the foregoing, Personal Information does not include information that is de-identified or corporate information that relates to an organization but not to an individual, such as a corporate name, corporate address, or general corporate phone number.

Information We Collect From Or About You

Personal Information You Provide To Us:

We collect Personal Information that you provide to us through our Sites, and in connection with other business dealings we may have with you. Such information may include:

First and last name
Company name
Title
Email address
Demographic Data (such as but not limited to employer, office location, department, race, and gender)

Note: The sharing of demographic data is optional.

Information We Automatically Collect When You Use Our Sites:

Some Personal Information is automatically collected through use of our Sites, such as the following:

Computer name
Hostname
External IP
IP address
Location
Login user name and password (admins only)
OS type
OS version

Website Usage Information We Collect:

In addition to the Personal Information submitted to us, whenever you visit or interact with our Sites, we may collect or store information about your interaction with our Sites (“Usage Information”). This Usage Information may include:

Your IP address or any other unique identifier assigned to the device that you use to access our Sites.
The functionality and characteristics of your device, including the type of browser, operating system and hardware, mobile network information, and in some cases location information.
The URL that referred you to our Sites, if any.
The time of day that you visited our Sites and how long your visit lasted.

Usage Information is typically anonymous information; however, if it is combined with your Personal Information in a manner that reasonably allows it to be associated with your identity, or is otherwise considered personal information under applicable law, it will be treated as Personal Information under this Privacy Policy, and, if you are an EU resident, it may be considered Personal Data and be subject to the section applicable to EU users below.

We use certain common methods and technologies to collect and store Usage Information about your interaction with our Sites (“Analytic Technologies”). These Analytic Technologies may be downloaded to the personal computer, laptop, tablet, or mobile phone that you use to access the Sites (“Your Device”). The specific Analytic Technologies that we use are as follows:

Cookies.

A cookie is a data file placed on Your Device when you visit our Sites. We use cookies only to facilitate the use and navigation of our Sites and to remember you and your preferences in case you revisit our Sites in the future and to conduct range measurement. Information collected relates to technical information (e.g. your browser, a timestamp, and a unique identifier). Almost all browsers allow blocking of cookies in their entirety, removal of existing cookies, or warning to prevent the placing of a cookie. You can find more information on this functionality in the documentation or in the help file of your browser. Please note that the blocking of cookies might impede your use of our Sites. If you are a resident of the EU or other jurisdiction that requires us to obtain your consent to use cookies on our Sites, then you will have an opportunity to manage your cookie preferences on such Sites; except that certain cookies are essential to enable core site functionality, and you cannot choose to disable those cookies.

Do Not Track Policy.

Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Sites. Just like any other usage information we collect, this information allows us to improve the Sites and customize your online experience, and otherwise as described in this Privacy Policy. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Sites do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Sites and after you leave our Sites.

Embedded Scripts.

An embedded script is a programming code that is designed to collect information about your interactions with our Sites, such as which links within our Sites you click on, which type of browser or device you use (e.g. mobile or desktop version). We use such information to enhance the user experience. This code is downloaded onto Your Device when you access our Sites and is deactivated or deleted when you leave our Sites. Identification of the user does not take place.

How We Use Your Information

Business Use

We use your Personal Information primarily to facilitate our ongoing and proposed business dealings with you (“Business Use”). This includes to: (1) process business transactions with us that you initiate, including without limitation orders of services and the creation of user profiles; (2) establish and maintain customer accounts so that we may provide services of ours requested by you or your company; (3) register you as a user of these services so that you may access them through our Sites or otherwise; (4) communicate with you about updates, maintenance, outages, or other technical matters concerning these services; (5) provide you with training and support regarding usage of these services; (6) notify you about changes to any of the policies and procedures for use of these services; (7) verify the accuracy of account and technical contact information we have on file for you and your company in relation to these services; and (8) respond to questions or inquiries that you or your company may have about our services.

We also may use your Personal Information as required for us to comply with laws and regulations relating to the services that we provide in any of the jurisdictions in which we or our affiliated companies operate, including the United States, and we may use Usage Information internally within Candorly to help us improve our services, or to develop new services. We may also use your Personal Information to personalize the content of the Sites and communications based on your preferences, and comply with our legal or contractual obligations, and resolve disputes. Additionally, we may use your Personal Information to protect against or deter fraudulent, illegal, or harmful actions and to enforce our terms and conditions of use (depending on which product or service you are. using).

Data Integrity. You are responsible for the accuracy of all Personal Information that you provide to us. We will use reasonable efforts to maintain the accuracy and integrity of your Personal Information and to update that information as appropriate. We will take reasonable steps to ensure that the Personal Information we collect from you is relevant to its intended use and that it is used only in ways that are compatible with the purposes for which it was collected or otherwise authorized by you.

With Whom We May Share Information

Within CANDORLY:

From time to time and subject to the provisions of this Privacy Policy governing “CHOICE AND UPDATING YOUR INFORMATION AND PREFERENCES” (see below), we may share your Personal Information and Usage Information within CANDORLY. Such information may be used by CANDORLY for internal business and operational purposes, as well as for purposes consistent with the purpose for which the information was originally collected or subsequently authorized by you.

Outside of CANDORLY:

We may share your Personal Information with Data Processors and Partners, as described below, and with other third parties for purposes disclosed to you at the time you provided the information, or as subsequently authorized by you.

Data Processors: We may, from time to time, employ Data Processors to perform services on our behalf, such as (1) hosting our Sites, products, and other applications; (2) designing and/or operating certain features available through our Sites; (3) sending emails and other communications relating to our services; (4) fulfilling and processing orders for our services; (5) assisting with promotions and conferences relating to our services, or those of our business partners; (6) providing analytic services, such as in relation to the tracking of usage of our Sites; or (7) performing other administrative services for us. Data Processors may have access to your Personal Information in order for them to complete a requested transaction or otherwise perform services for us or for you on our behalf. Prior to allowing our Data Processors to access your Personal Information, we will enter into a data protection agreement or addendum (“DPA”) with them to ensure that they handle and process the information in accordance with this Privacy Policy and applicable law as instructed by us.
Partners: We may also share your contact information with the following partner so that we can better serve you
Links to Other Websites and Applications: The Sites may contain various links to, as well as plug-ins or widgets from, social media and other third party websites or applications, which may provide additional information, goods, services, and/or promotions. These third-party websites or applications are owned and operated independently of CANDORLY, and may have their own separate privacy and data collection practices. We are not responsible for the privacy practices of any third party; therefore, you should review their privacy policies and practices prior to interacting with their websites or applications, using any of their tools, or sharing any of your personal information with them.
Legal Protections and Law Enforcement: We may access, use, preserve, transfer, and disclose to third parties your Personal Information to (1) satisfy any applicable law, regulation, subpoena, governmental request, or legal process if, in our good faith opinion, such is required or permitted by law;(2) protect and/or defend this Privacy Policy or other policies or terms of use applicable to our Sites, including investigations of potential violations thereof; (3) protect the safety, rights, property, or security of CANDORLY or any third party; and/or (4) detect, prevent, or otherwise address fraud, security issues or breaches, or technical issues. This may include allowing third parties, such as copyright owners, Internet service providers, wireless service providers, and/or law enforcement agencies, to access and use your Usage Information in order to identify you. We may take any of these steps without notice to you to the extent permitted by law.

Choice And Updating Your Information And Preferences

Upon your request, we will grant you access to your personal information that we hold, as well as other related rights as are provided by applicable law. If you are a California or Nevada resident, please review the sections below entitled “California residents” and “Nevada Residents,” respectively, for further description of your rights. We reserve the right to take reasonable steps to authenticate the identity of any individual seeking access to Personal Information. We may provide web pages or other mechanisms on our Sites through which you can update subscription preferences. You can also contact us to update your Personal Information or change your preferences. Our contact information for these purposes is by email at support@fringepd.com. If you receive marketing communication from us by email, you may also opt-out of receiving future email marketing communications by following the opt-out instructions provided in that email. Please note that we reserve the right to send you certain communications relating to transactions you initiate, your customer account, your use of our Sites, or other business matters and that these communications may be unaffected if you choose to opt-out from marketing communications.

In accordance with our routine record keeping and applicable law, we may delete certain records that contain your Personal Information. We are under no obligation to store such information indefinitely, and we disclaim any liability arising out of or related to, the destruction of that information. In addition, you should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons.

Information Security

We will take reasonable precautions to protect your Personal Information in our possession from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We will make reasonable efforts to keep your personal information reliable for its intended use, accurate, current, and complete. As necessary, we will take additional precautions regarding the security of particularly sensitive information, such as credit card information. While we strive to secure your Personal Information, we cannot warrant or guarantee that this information will be protected under all circumstances, including those beyond our reasonable control.

Enforcement

We will conduct periodic internal compliance audits of our relevant privacy practices to verify adherence to this Privacy Policy. We encourage you to raise any questions or concerns that you may have about the way we process your Personal Information by contacting us at the address set forth below. We commit to resolve questions and complaints about your privacy and our collection or processing of Personal Information about you. If you believe that we are not complying with the terms of this Privacy Policy or other legal requirements, you should first contact us by email at support@fringepd.com. We will investigate and will do our best to internally resolve any complaints and disputes you bring to our attention regarding the use and disclosure of your Personal Information.

Children

The Sites are intended for business use. We do not knowingly collect or solicit Personal Information from anyone under the age of 18. If you are under 18, please do not attempt to register for the Sites or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us Personal Information, please contact us at support@fringepd.com.

How to Contact Us:

If you have any questions or concerns about this Privacy Policy, or its implementation, contact us at support@fringepd.com or by writing to:

Candorly
1380 Monroe Street NW
Box 420
Washington, DC 20010
Last updated on February 9, 2023