OCKAM PRIVACY NOTICE

Last Updated: February 22 2024

Welcome! This Privacy Notice explains how Ockam, Inc. (“Ockam”, “Company”, “we”, “us” or “our”) collects, uses, discloses, and otherwise processes personal information (as defined below) in connection with our websites (the “Sites”) and other websites we own and operate that link to this Privacy Notice, and the related content, platform, services, products, and other functionality offered on or through our services (collectively, the “Services”). It does not address our privacy practices relating to Ockam job applicants, employees and other personnel.

Ockam is the controller of the personal information we hold about you in connection with your use of the Services. This means that we determine and are responsible for how your personal information is used.

When our customers use our Services to submit, manage, or otherwise use content relating to our customers’ data (“Customer Data”), we have contractually committed ourselves to only process such information on behalf of and under the instruction of the respective customer, who is the “data controller”. This Privacy Notice does not apply to such processing and we recommend you read the privacy notice of the respective customer if their processing involves your personal information.

WHAT IS PERSONAL INFORMATION?

When we use the term “personal information” in this Privacy Notice, we mean any data or information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or household or any other data or information that constitutes “personal data”, “personal information,” or “personally identifiable information.”

OUR COLLECTION AND USE OF PERSONAL INFORMATION

We collect personal information in a variety of ways. For example, you may provide us your personal information when you place an order, register for an account, make an online purchase, post a review, send us messages, subscribe to our mailing lists, newsletters or other forms of marketing communications, submit a job application, participate in a survey, contest or sweepstakes, redeem a promotion, or use some other feature of our Services.

We may link or combine your activities and information collected from you on our Services with information we receive from third parties, as well as information we collect automatically through tracking technologies (defined below). This allows us to provide you with a personalized experience regardless of how you interact with us.

Personal Information Collected from You

We may collect the following categories of personal information submitted to us by individuals through the Services:

Account Information, including first and last name, company name, employer, job title, business email address, user ID and password, profile information, affiliations, account balances, payment and purchase history information, and any other information you provide to us. We use this information to administer your account, provide you with the relevant service and information, send you marketing communications in accordance with your preferences, communicate with you regarding your account and your use of the Services, and for customer support purposes.
Inquiry and Communications Information, including information provided in custom messages sent through the forms, in chat messages, to one of our email addresses, or via phone. This also includes contact information provided on our Services. We use this information to investigate and respond to your inquiries, to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.
Newsletter, Marketing Emails and Blog Information, including email address, applicable interests and communication preferences. We use this information to manage our communications with you and send you information about products and services we think may be of interest to you. If you wish to stop receiving email messages from us, simply click the “unsubscribe” link provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
Event, Contest, Promotion, and Survey Information, including information provided when you sign up for an event, enter a contest or promotion, complete a survey or submit a testimonial. We use this information primarily to administer and facilitate our products and services, respond to your submission, communicate with you, conduct market research, inform our marketing and advertising activities, improve and grow our business and facilitate the related event, content, promotion or survey.
Information Collected Through the Use of the Service, including any files, documents, videos, images, data or information you choose to upload or transmit through your communications with us or your use of the Site (collectively, “User Content”). User Content and any information contained in the User Content, including personal information you may have included, is stored and collected as part of the Services. We use the User Content to provide you with the Services.
Employment Application Information, including your contact and demographic information, educational and work history, employment interests, information obtained during interviews and any other information you choose to provide, if you apply for employment.
Feedback Information. We may also collect feedback and ratings you provide relating to our services or products. We use this information to communicate with you, to conduct market research, inform our marketing and advertising activities and improve and grow our business.
Business Representative Contact Information. If you are a business representative, we collect your information in connection with the performance of the agreement or potential agreement with us. This information may include your first name, last name, company contact information (e.g., email, phone, address), job title, and any other information related to the performance of the agreement with us.
Payment Information. Please note that we use third-party payment processors to process credit card payments made to us. As such, we do not retain any personally identifiable financial information in connection with credit card payments, such as credit card numbers. Rather, all such information is provided directly by you to our third-party processor. The payment processor’s use of your personal information is governed by their privacy notice.
Other Information that you provide to us online, by phone or in person. We use this information to respond to your request, provide you the requested services, and to inform our marketing and advertising campaigns.

Personal Information from Third Parties

We also obtain personal information from third parties, which we often combine with personal information we collect.

We may receive the same categories of personal information as described above from the following third parties:

Ockam Entities: We may receive personal information from other companies and brands owned or controlled by Ockam, and other companies owned by or under common ownership as Ockam. We use this information to provide our products and facilitate our Services.
Your Employer / Company: If you interact with our Services through your employer or company, we may receive your information from your employer or company, including another representative of your employer or company. We use this information to operate, maintain, and provide to you the features and functionality of the Service.
Other Users or Individuals who Interact with our Services: We may receive your information from other users or other individuals who interact with our Services. For example, if you engage in one of our communications hosted on third-party platforms, we will be able to see any public communications made within that platform. We use this information to administer our Services and to operate and grow our business.
Social Media: When you interact with our Services through various social media networks, we may receive some information about you that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.
Service Providers: Our service providers that perform services solely on our behalf, such as survey and marketing providers and payment processors, collect personal information and often share some or all of this information with us. The information may include contact information, demographic information, payment information, information about your communications and related activities, and information about your orders. We may use this information to administer and facilitate our services, your orders, and our marketing activities.
Business Partners: We may receive your information from our business partners, such as companies that offer their products or services on our Services. We may use this information to administer and facilitate our services, your orders, and our marketing activities.
Information we receive from authentication services you connect to our Services: Some parts of our Services may allow you to login through third-party authentication services. These services will authenticate your identity and provide you the option to share certain personal information with us. The data we receive is dependent on that third party’s policies and your privacy settings on that third-party site. We use this information to operate, maintain, and provide you the features and functionality of the Service. We may also use this information to send you service-related emails or messages (e.g., account verification, purchase confirmation, customer support, changes, or updates to features of our products, technical and security notices).
Other Sources: We may also collect personal information about individuals that we do not otherwise have from, for example, publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

Through the provision of our Services, we may also process deidentified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer or household. Ockam commits to maintain and use the information in deidentified form and will not attempt to reidentify the information, except in instances where necessary for determining whether the deidentification process used by Ockam satisfies the requirements under applicable law.

Additional Limits on Use of Your Google Information

Our Service uses certain Google services, such as the Google Gmail API. You can connect your Gmail account using OAuth authentication, a secure mechanism to give Ockam access to your Google account data without letting Ockam know your password. Notwithstanding anything else in this Privacy Notice to the contrary, if you provide Ockam access to your Google Gmail data, Ockam’s use of that Google Gmail data will be subject to the following additional restrictions:

The Services will only use access to read, write, modify, or control email messages, metadata, headers, and settings to provide a web email client that allows users to compose, send, read, and process emails.
The Services will not transfer this Gmail data to others unless doing so is necessary (i) to provide and improve the features of the Services we provide to you, (ii) to comply with applicable law, or (iii) as part of a merger, acquisition, or sale of assets.
We will not use or share this Gmail data for serving advertising, including retargeting, personalized, or interest-based advertising.
We will not allow humans to read this data unless:
- we have your affirmative agreement for specific messages,
- doing so is necessary for security purposes (such as investigating a bug or abuse),
- it is necessary to comply with applicable law, or
- the data has been aggregated and anonymized and is used only for our own internal operations purposes.

Our Services’ use of information received, and the Services’ transfer of information to any other app, from Google APIs will adhere to Google’s Limited Use Requirements.

Personal Information Automatically Collected

We, and our third-party partners, automatically collect information you provide to us and information about how you access and use the Services when you visit our Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, and logging technologies (collectively, “tracking technologies”). We may use third-party partners or technologies to collect this information. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources.

We, and our third-party partners, use tracking technologies to automatically collect usage and device information, such as:

Information about the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
Information about the way you access and use our Services, such as the site from which you came and the site to which you are going when you leave our Services, how frequently you access the Services, whether you open emails or click the links contained in emails, whether you access the services from multiple devices, and other browsing behavior and actions you take on the Sites.
Information about how you use the Services, such as the pages you visit, the links you click, the ads you view and click on, videos you watch, and other similar actions. We may also use third-party tools to collect information you provide to us or information about how you use the Services and may record your mouse movements, scrolling, clicks and keystroke activity on the Services and other browsing, search or purchasing behavior. These tools may also record information you enter when you interact with our Services or engage in chat features through our Services.
Analytics information. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the Services and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its opt-out options at https://tools.google.com/dlpage/gaoptout. All the information collected automatically through these tools allows us to improve your customer experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our Sites and Services, and to improve the effectiveness of our Services, offers, advertising, communications and customer service. We may also use the information collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our services.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies; however, doing so may negatively impact your experience using the Services, as some features and services may not work properly. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

We and our third-party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see Third-Party Data Collection and Online Advertising below.

Additional Uses of Personal Information

We may use personal information we collect to:

Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested and to process transactions, including providing you with a white paper you have requested or an online product demonstration;
Manage our organization and its day-to-day operations;
Verify your identity and entitlement to products or Services, when you contact us or access our Services;
Register you for and provide you access to events and webcasts;
Communicate with individuals, including via email, text message, social media or telephone calls;
Request individuals to complete surveys about our organization, organizations we partner with, and Services;
Advertise, including to market to you or offer you through email, direct mail, phone or text message information and updates on products or services we think that you may be interested in (where applicable, we may send you marketing messages if you have given us your consent to do so or where we have relied on the soft opt-in rule);
Administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Services;
Facilitate customer benefits and services;
Identify and analyze how individuals use our Services;
Conduct research and analytics on our customer and user base and our Services;
Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
Help maintain the safety, security and integrity of our property and Services, technology assets and business;
To enforce our Terms of Use, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
Comply with contractual and legal obligations and requirements;
To fulfill any other purpose for which you provide personal information; and
For any other lawful purpose, or other purpose that you consent to.

Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the personal information we require falls outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.

OUR DISCLOSURE OF PERSONAL INFORMATION

We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:

Ockam Entities: We may share personal information with other companies owned or controlled by Ockam, and other companies owned by or under common ownership as Ockam, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
Your Employer / Company: If you interact with our Services through your employer or company, we may disclose your information to your employer or company, including another representative of your employer or company.
Marketing Providers: We coordinate and share personal information with our marketing providers to communicate with individuals about the Services we make available.
Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer services and facilitate our communications with individuals that submit inquiries.
Other Users: If you participate in any of our online communities or purchase any of our Services, we may disclose your public profile information to other online community members, as well as any other information you choose to provide or make public.
Contests, Sweepstakes, and Survey Providers: We share personal information with third parties who assist us in delivering our contests, sweepstakes, or survey offerings and in processing the responses.
Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other websites and services, and across other devices. These parties may collect information directly from a browser or device when an individual visits our Services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Please see the Third-Party Data Collection and Online Advertising section.
Business Partners: From time to time, we may share personal information with our business partners or we may allow our business partners to collect your personal information. Our business partners will use your information for their own business and commercial purposes, including to send you any information about their products or services that we believe will be of interest to you.
Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, employment application-related services, payment processing services, and administrative services.
*Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
- to detect, suppress, or prevent fraud;
- to protect the health and safety of us and others; or
- as otherwise required by applicable law.
With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Sites or service-related publications.

THIRD-PARTY DATA COLLECTION AND ONLINE ADVERTISING

We may participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your browsing history. We permit third-party online advertising networks, social media companies and other third-party services to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the Sites, AdID, and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.

We may engage in the following:

Social Media Widgets. Our Services may include social media features. Social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy notices of those companies.
Social Media Platforms. We may display targeted advertising to you through social media platforms. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.
Third Party Partners. We work with a variety of third-party partners to provide advertising services. For example, we use Google Analytics to recognize you and link the devices you use when you visit our Services on your browser or mobile device, log-in to your account on our Services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's website, “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here: https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://safety.google/privacy/ads-and-data/, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.

To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some—but not all—interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

Please note that when you opt-out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

CONTROL OVER YOUR INFORMATION

You may control your information in the following ways:

Access to Your Device Information. You may control the Services’ access to your device information through your “Settings” on your device. For instance, you can withdraw permission for the Services to access your network devices and to integrate with your other applications.
Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
SMS Text Messaging. You may opt-out of receiving promotional SMS text messages at any time. Please note that unsubscribing from promotional text messages will not prevent you from SMS texts from Ockam directly relating to your use of the Services, such as for account login (e.g., we may send you a security verification code). To unsubscribe from promotional SMS texts, you can reply STOP to any one of our promotional text messages. For more information, see our Terms of Use.
Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at privacy@ockam.io. We may not be able to modify or delete your information in all circumstances.

DATA RETENTION

We will usually store the personal information we collect about you for no longer than necessary to fulfill the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Once retention of the personal information is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal information or, if this is not possible (for example, because personal information has been stored in backup archives), then we will securely store the personal information and isolate it from further processing until deletion or deidentification is possible.

CHILDREN’S PERSONAL INFORMATION

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.

LINKS TO THIRD-PARTY WEBSITES OR SERVICES

Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

CONTACT US

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy@ockam.io.

REGION-SPECIFIC DISCLOSURES

We may choose or be required by law to provide different or additional information relating to the processing of personal information (as defined below) about residents of certain countries, regions or states. Please refer below for additional information that may be applicable to you:

Depending on your state of residency, you may be able to exercise additional rights granted by applicable law in relation to the personal information about you that we have collected (subject to certain limitations). For additional information concerning these rights, please review our California Privacy Notice.

CALIFORNIA PRIVACY NOTICE

This California Privacy Notice (the “CA Notice”) supplements the information contained in our Privacy Notice above and applies solely to individual residents of the State of California (“consumers” or “you”).

This CA Notice describes how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights Act of 2023 (CPRA).

Unless otherwise expressly stated, all terms in this CA Notice have the same meaning as defined in our Privacy Notice or as otherwise defined in the CPRA.

Collection and Use of Personal Information

We collect personal information from and about consumers for a variety of purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use this information, please refer to the Our Collection and Use of Personal Information section of our Privacy Notice.

In the last 12 months, we have collected the following categories of personal information:

Identifiers, such as your username and email address;
California Customer Records (Cal. Civ. Code § 1798.80(e)), such as your log-in credentials and phone number;
Commercial Information, such as products and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
Internet/Network Information, such as device information, logs, and analytics data;
Sensory Information, such as recordings of any phone calls between you and Ockam;
Professional/Employment Information, such as job title and company;
Other Personal Information, including information you submit into the feedback forms and any communications between you and Ockam, as well as information we receive from social networking sites; and
Inferences, such as information generated from your use of the Services reflecting predictions about your interests and preferences.

We collect this information from a variety of sources, including directly from you, from your employer or organization, from our customers and other users, from our business partners and affiliates, from your browser or device when you use our Services, or from third parties that you permit to share information with us.

Disclosure of Personal Information

In the last 12 months, we may have disclosed all the categories of information we collect with third parties for a business purpose, as described in the Our Disclosure of Personal Information section of the Privacy Notice. The categories of third parties to whom we sell or disclose your personal information for a business purpose include:

Service providers and advisors that perform services for us, on our behalf, which may include providing marketing and advertising services, providing mailing or email services, tax and accounting services, data enhancement services, fraud prevention, web hosting, or similar services;
Select marketing and strategic partners who use this information to market to you, to perform analytics and conduct research, or for other purposes;
Ad networks and advertising partners, including social networks, to deliver advertising and personalized content to you on our services, on other sites and services you may use, and across other devices you may use, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research;
Social networks for advertising or personalization purposes, or to engage with you;
Analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve our Services; and
Other third parties at your direction or upon your request, or to comply with legal process or contractual obligations, as described in our Privacy Notice.

Sensitive Personal Information

In the last 12 months, we have collected the following categories of sensitive personal information:

Account log-in, in combination with any required security or access code, password, or credentials allowing access to an account.

We use and disclose this sensitive personal information for the purposes described in the Collection and Use of Personal Information and Disclosure of Personal Information sections of this CA Notice. For more information, please see the Our Collection and Use of Personal Information and Our Disclosure of Personal Information sections of our Privacy Notice.

Your California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the personal information that we have collected about you (subject to certain limitations at law):

The Right to Know. The right to confirm whether we are processing personal data about you, including:
- The categories of personal data collected;
- The categories of sources of the personal data;
- The purposes for which the personal data were collected;
- The categories of personal data disclosed to third parties (if any), and the categories of recipients to whom the personal data were disclosed;
- The categories of personal data shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for those purposes; and
- The categories of personal data sold (if any), and the categories of third parties to whom the personal data were sold.
The Right to Access and Portability. The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
The Right to Request Deletion. You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
The Right to Correction. You have the right to request that any inaccuracies in your personal information be corrected, taking into account the nature of the personal information and the purposes of the processing of your personal information.
The Right to Control Over Automated Decision-Making / Profiling. You have the right to direct us not to use automated decision-making or profiling for certain purposes.
Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to direct us to limit the use of your sensitive personal information to certain purposes, including to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
The Right to Opt Out of Sales or Sharing for Targeted Advertising. You have the right to direct us not to “sell” personal information we have collected about you to third parties for monetary or other valuable consideration, or “share” your personal information to third parties for cross-context behavioral advertising purposes. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
“Shine the Light”. California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code §1798.83).

You may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship, or is otherwise permitted by law.

How to Exercise Your Privacy Rights

Please submit a request by either:

Emailing us at privacy@ockam.io with the subject line, “Consumer Rights Request,” or
Completing our Individual Rights Form.

Before processing your request, we will need to verify your identity and confirm you are a resident of a state that offers the requested right(s). To verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email address, phone number, and/or date of last transaction on our Services.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

Submitting Authorized Agent Requests

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. To verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

To Exercise Your Opt-Out Rights

Unless you have exercised your Right to Opt-Out, and as described in the Our Disclosure of Personal Information section of the Privacy Notice, we may disclose or “sell” your personal information to third parties for monetary or other valuable consideration in relation to online tracking technologies, or “share” your personal information to third parties for cross-context behavioral advertising purposes (“targeted advertising”). The third parties to whom we sell or share personal information may use such information for their own purposes, in accordance with their own privacy notices, which may include reselling or sharing this information with additional third parties.

You do not need to create an account with us to exercise your Right to Opt-Out. However, we may ask you to provide additional personal information so that we can properly identify you in our dataset and to track compliance with your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.

For Cookie-Based Sales & Targeted Advertising Opt-Outs: To exercise your right to opt-out as it relates to the use of cookies and other tracking technologies for analytics and targeted ads, click here.
For Non-Cookie-Based Opt-Outs: You may submit a request by filling out our online form [https://www.ockam.io/contact/form].

Appealing Privacy Rights Decisions

You may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by emailing us at privacy@ockam.io with the subject line, “Privacy Request Appeal.”

If we decline to act on a request exercising one of your rights set forth above, you have the right to appeal our decision.

Minors

We do not sell the personal information and do not have actual knowledge that we sell the personal information of minors under 16 years of age. If we wish to do so in the future, we will first seek affirmative authorization from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at privacy@ockam.io to inform us if you, or your minor child, are under the age of 16.

If you are under the age of 18 and you want to remove your name or comments from our website or publicly displayed content, please contact us directly at privacy@ockam.io. We may not be able to modify or delete your information in all circumstances.

If you wish to submit a privacy request on behalf of your minor child in accordance with applicable jurisdictional laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child’s behalf (i.e., you are the child’s legal guardian or authorized representative).

Shine the Light Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the way we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. To opt-out of this type of sharing, please click on the Do Not Share or Sell My Personal Information link above.