Privacy Policy - EX Squared

EX Squared Solutions, Inc. and its affiliates want you to be familiar with how we collect, use, and disclose information. This Privacy Policy describes our practices in connection with information that we collect through:

Websites operated by us from which you are accessing this Privacy Policy, including exsquared.com, digital-examiner.com, outcoding.com, rocksauce.com, exsquaredindia.com;
Our social media pages that we control from which you are accessing this Privacy Policy;
HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications we have with you; and
Offline business interactions you have with us.

Collectively, we refer to the websites, social media pages, communications, and offline business interactions as the “Services.”

If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, please see “Additional Information for Residents of California, Colorado, Connecticut, Utah, and Virginia,” below, for more information about our privacy practices and your rights.

Personal Information

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. We collect Personal Information through or in connection with the Services, such as:

Name, job title, and company
Contact information, such as address, email address, and phone number
IP address (we may also derive your approximate location from your IP address)

Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways, including:

Through the Services.
From Other Sources.
- We receive your Personal Information from other sources, such as publicly available databases and joint marketing partners.

If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

We and our service providers use Personal Information for the following purposes:

Providing you with our marketing materials and facilitating social sharing.
- To send you marketing related emails and other information, such as informational newsletters, updates, new features, and other information about us.
- To facilitate social sharing functionality that you choose to use.
Analyzing Personal Information for business reporting and providing personalized services.
- To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
- To better understand your interests and preferences, so we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
- To better understand your preferences so we can deliver content we believe will be relevant and interesting to you.
Aggregating and/or anonymizing Personal Information.
- We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
Accomplishing our business purposes.
- For data analysis, such as to improve the efficiency of the Services.
- For audits, to verify that our internal processes function as intended, and to address legal, regulatory, or contractual requirements.
- For fraud prevention and security monitoring purposes, including to detect and prevent cyberattacks or attempts to commit identity theft.
- For developing new products and services.
- For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures.
- For identifying usage trends, such as understanding which parts of our Services are of most interest to users.
- For determining the effectiveness of our promotional campaigns, so we can adapt our campaigns to the needs and interests of our users.
- For operating and expanding our business activities.

Disclosure of Personal Information

We disclose Personal Information:

To our affiliates, for the purposes described in this Privacy Policy.
To our third-party service providers, to facilitate services they provide to us.
- These can include providers of such services as website hosting, data analysis, fraud prevention, information technology and related infrastructure provision, customer service, email delivery, and auditing.
To third parties who have products, services, and opportunities that may be useful to you, to permit them to send you marketing communications, consistent with your choices.
- If you give your permission to allow third parties to contact you, your Personal Information may be shared with individual users and other third parties you have identified, such as builders, product manufacturers, data aggregators, and marketers.

Other Uses and Disclosures

We may also use and disclose Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, to respond to requests from public and government authorities, to cooperate with law enforcement, and for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety, or property, and/or that of you or others. We may use, disclose, or transfer Personal Information to a third party in connection with any proposed or actual reorganization, bankruptcy, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our assets or stock

Other Information

Cookies, pixel tags, and similar technologies.

“Other Information” is information that does not reveal your specific identity or directly relate to an identifiable individual. We and our service providers may collect and use Other Information in a variety of ways, including:

Your browser or device.

Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version. We use this information to ensure that the Services function properly.
Please read our Cookie Policy for details on how we use cookies, pixel tags, and similar technologies. In addition to the details set forth in our Cookie Policy, we may use such technologies to track the actions of our email recipients, measure the success of our marketing campaigns, and compile statistics about use of the Services and response rates.
We use third-party advertising companies to serve ads regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services. You may receive ads based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/. We also occasionally engage third-party companies to serve location-targeted ads on our behalf, though we do not collect precise location data ourselves.

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information, as detailed in this Privacy Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

Security

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below

Retention Period

We retain Personal Information for as long as needed or permitted to fulfill the purpose(s) for which it was obtained, including to satisfy any legal, compliance, accounting, or reporting requirements, and consistent with applicable law. The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with you;
Whether there is a legal obligation to which we are subject, such as to keep transaction records for a certain period of time; or
Whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation, or regulatory investigations.

Third-Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating a website or service to which the Services link. The inclusion of a link on the Services does not imply our endorsement of the linked site or service. In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Twitter, Instagram, YouTube,

Pinterest, LinkedIn, Apple, Google, Microsoft, RIM, or any other social media platform, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our Social Media Pages.

Your Choices

If you no longer want to receive marketing related emails from us, you may opt out by using the unsubscribe link provided at the bottom of each such email. If you opt out, we may still send you important administrative messages, from which you cannot opt out.

For California, Colorado, Connecticut, Utah, and Virginia residents: Please see “Additional Information for Residents of California, Colorado, Connecticut, Utah, and Virginia,” below, for additional information about your rights.

For Nevada residents: To opt out of the sale of your Personal Information, if applicable, please email us at info@exsquared.com.

Use of the Services by Minors

The Services are not directed to individuals under the age of thirteen (13), and we do not knowingly collect Personal Information from such individuals.

Jurisdiction and Cross-Border Transfer

We are located in the United States. We may store and process your Personal Information in any country where we have facilities or in which we engage service providers. By using the Services, you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules different from those of your country

Sensitive Information

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., Social Security numbers, information related to racial or

ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or criminal background) on or through the Services or otherwise to us

Third-Party Payment Service

The Services may provide functionality allowing you to make payments using a third-party payment service with which you have created your own account. When you use such a service to make a payment to us, your Personal Information will be collected by such third party and not by us and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, any such third party’s collection, use, or disclosure of your Personal Information.

Updates to this Privacy Policy

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.

Contact Us

If you have any questions about this Privacy Policy, please contact us at info@exsquared.com or at:

EX Squared Solutions, Inc. 11900 Ranch Road 620 N Austin, TX 78750-1345

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

Additional Information for Residents of California, Colorado, Connecticut, Utah, and Virginia

This section supplements the above Privacy Policy and provides additional details regarding our collection, use, and disclosure of Personal Information relating to residents of California, Colorado, Connecticut, Utah, and Virginia.

Other Information

The following chart details the categories of Personal Information we collect, as well as the categories we disclose to third parties.

Categories of Personal Information	Disclosed to Which Categories of Third Parties for Operational Business Purposes	Sold to Which Categories of Third Parties	Shared with Which Categories of Third Parties for Cross-Context Behavioral Advertising
Identifiers, such as name, contact information, online identifiers	Our affiliates; service providers; third parties who have products, services, and opportunities that may be useful to you, to permit them to send you marketing communications, consistent with your choices	Ad networks and social media platforms	Ad networks and social media platforms
Personal information as defined in the California customer records law, such as name, contact information	Our affiliates; service providers; third parties who have products, services, and opportunities that may be useful to you, to permit them to send you marketing communications, consistent with your choices	Ad networks and social media platforms	Ad networks and social media platforms
Commercial information, such as transaction information and purchase history	Our affiliates; service providers; third parties who have products, services, and opportunities that may be useful to you, to permit them to send you marketing communications, consistent with your choices	Ad networks and social media platforms	Ad networks and social media platforms
Internet or network activity information, such as browsing history, and interactions with our website	Our affiliates; service providers; third parties who have products, services, and opportunities that may be useful to you, to permit them to send you marketing communications, consistent with your choices	Ad networks and social media platforms	Ad networks and social media platforms
Employment information, such as employer name and job title	Our affiliates; service providers; third parties who have products, services, and opportunities that may be useful to you, to permit them to send you marketing communications, consistent with your choices	None	None
Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	Our affiliates; service providers; third parties who have products, services, and opportunities that may be useful to you, to permit them to send you marketing communications, consistent with your choices	Ad networks and social media platforms	Ad networks and social media platforms

Individual Rights and Requests

Subject to applicable law, you may make the following requests:

You may request to know whether we process your Personal Information and to access such Personal Information.
1. If you are a California resident, you may request the following information:
  1. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
  2. The business or commercial purpose for collecting, selling, or sharing Personal Information about you;
  3. The categories of Personal Information about you that we sold or shared and the categories of third parties to whom we sold or shared such Personal Information; and
  4. The categories of Personal Information about you that we otherwise disclosed and the categories of third parties to whom we disclosed such Personal Information.
You may request to correct inaccuracies in your Personal Information.
You may request to have your Personal Information deleted.
You may request to receive a copy of your Personal Information, including, where applicable, in a portable format.
You may request to opt out of the “sale” of your Personal Information.
You may request to opt out of targeted advertising, including the “sharing” of your Personal Information for purposes of cross-context behavioral advertising.

We will not unlawfully discriminate against you for exercising your rights under applicable privacy law. To make a privacy request, please contact us at info@exsquared.com stating your specific request. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as name, email address, or phone number, in order to verify your identity and protect against fraudulent requests. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information.

To request to opt out of any future “sales” of your Personal Information and/or “sharing” of your Personal Information for purposes of cross-context behavioral advertising or any future processing for purposes of targeted advertising, please contact us at info@exsquared.com.

Appeal Process

If you are a resident of Colorado, Connecticut, or Virginia and we refuse to take action on your request, you may appeal our refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us at info@exsquared.com.

Authorized Agents

If an agent would like to make a request on your behalf as permitted under applicable law, they may use the submission methods outlined above. As part of our verification process, we may request that the agent provide proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described above or confirm that you provided the agent permission to submit the request.

De-Identified Information

If we maintain or use de-identified information, we will continue to maintain and use it only in a de-identified fashion and will not attempt to re-identify the information.

Text Message Service Privacy Policy

We respect your privacy. We only use information you provide through this service to transmit your mobile messages and respond to you. This includes, but isn’t limited to, sharing information with platform providers, phone companies, and other vendors who assist us in the delivery of mobile messages. Mobile information will not be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. Nonetheless, we reserve the right always to disclose any information as necessary to satisfy any law, regulation or governmental request, to avoid liability, or to protect our rights or property. This Text Message Service Privacy Policy applies to your use of the Text Message Service and isn’t intended to modify our general Privacy Policy which may govern the relationship between you and us in other contexts.

DMCA Notice

Reporting Claims of Copyright Infringement

We take claims of copyright infringement seriously. We will respond to notices of alleged copyright infringement that comply with applicable law. If you believe any materials accessible on or from this site owned and operated by Ex2 Solutions, Inc. (the “Website”) infringe your copyright, you may request removal of those materials (or access to them) from the Website by submitting written notification to our copyright agent designated below. In accordance with the Online Copyright Infringement Liability Limitation Act of the Digital Millennium Copyright Act (17 U.S.C. § 512) (“DMCA”), the written notice (the “DMCA Notice”) must include substantially the following:

Your physical or electronic signature.
Identification of the copyrighted work you believe to have been infringed or, if the claim involves multiple works on the Website, a representative list of such works.
Identification of the material you believe to be infringing in a sufficiently precise manner to allow us to locate that material.
Adequate information by which we can contact you (including your name, postal address, telephone number, and, if available, email address).
A statement that you have a good faith belief that use of the copyrighted material is not authorized by the copyright owner, its agent, or the law.
A statement that the information in the written notice is accurate.
A statement, under penalty of perjury, that you are authorized to act on behalf of the copyright owner.

Our designated copyright agent to receive DMCA Notices is:

Ex2 Solutions, Inc. 11900 Ranch Road 620 N Austin, TX 78750-1345
Attn: Kamal Kantawala
Email: info@exsquared.com

If you fail to comply with all of the requirements of Section 512(c)(3) of the DMCA, your DMCA Notice may not be effective.

Please be aware that if you knowingly materially misrepresent that material or activity on the Website is infringing your copyright, you may be held liable for damages (including costs and attorneys’ fees) under Section 512(f) of the DMCA.

Counter Notification Procedures

If you believe that material you posted on the Website was removed or access to it was disabled by mistake or misidentification, you may file a counter notification with us (a “Counter Notice”) by submitting written notification to our copyright agent designated herein. Pursuant to the DMCA, the Counter Notice must include substantially the following:

Your physical or electronic signature.
An identification of the material that has been removed or to which access has been disabled and the location at which the material appeared before it was removed or access disabled.
Adequate information by which we can contact you (including your name, postal address, telephone number, and, if available, email address).
A statement under penalty of perjury by you that you have a good faith belief that the material identified above was removed or disabled as a result of a mistake or misidentification of the material to be removed or disabled.
A statement that you will consent to the jurisdiction of the Federal District Court for the judicial district in which your address is located (or if you reside outside the United States for any judicial district in which the Website may be found) and that you will accept service from the person (or an agent of that person) who provided the Website with the complaint at issue.

Our designated agent to receive Counter Notices is:

Ex2 Solutions, Inc. 11900 Ranch Road 620 N Austin, TX 78750-1345
Attn: Kamal Kantawala
Email: info@exsquared.com

The DMCA allows us to restore the removed content if the party filing the original DMCA Notice does not file a court action against you within ten business days of receiving the copy of your Counter Notice.

Please be aware that if you knowingly materially misrepresent that material or activity on the Website was removed or disabled by mistake or misidentification, you may be held liable for damages (including costs and attorneys’ fees) under Section 512(f) of the DMCA.

Repeat Infringers

It is our policy in appropriate circumstances to disable and/or terminate the accounts of users who are repeat infringers.

Accessibility Statement

Ex2 Solutions, Inc. (“Ex2”) is committed to ensuring that our websites are accessible to users with disabilities. Our efforts to ensure digital usability and accessibility are guided by relevant portions of the Web Content Accessibility Guidelines 2.2, Level AA and other applicable recommendations. We have made substantial efforts to meet these standards and we will continue to do so in order to make our websites more accessible. If you have specific concerns, we would be happy to pass them on to the Ex2 team that manages our websites

Contact Us

For more information, or for help with other questions, you can:

Email us at info@exsquared.com.
Write to us at EX Squared Solutions, Inc., 11900 Ranch Road 620 North, Austin, Texas 78750.