PRIVACY

Website Privacy Policy

VERSION 2

Effective Date: January 25, 2023

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This Privacy Policy describes how Luz Data, Inc. (d/b/a Particl) handles personal information that we collect through our website, application, and any other sites that link to this Privacy Policy (collectively, the “Services”).

This Privacy Policy does not apply to how we handle personal information that we collect about retail consumers in connection with providing our marketing and advertising products to our enterprise clients. To learn how we handle consumer data in this context, please visit our Consumer Privacy Notice.

Please see our Privacy Snapshot for a high-level overview of our privacy practices.

Personal information we collect

Information you provide to us

  • Client account and contact information, such as your name, email address, mailing address, phone number, and other similar information provided with respect to your business or its employees, officers, representatives or affiliates, and certain historical, contact, and demographic information about you.
  • Payment information, that we collect in connection with clients' making, accepting, requesting or recording payments, credits or money transfers through the Services, including: payment card numbers, bank accounts information, when and where the transactions occur, the names of the transacting parties, a description of the transactions, the payment or transfer amounts, billing and shipping information, and the devices and payment methods used to complete the transactions.
  • Purchase information, such as products and services clients have purchased, amounts paid, frequency of purchases, location of purchases, and similar information.
  • Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
  • Usage information, such as information about how you use the Services and interact with us, including information associated with any content you upload to the Services or otherwise submit, and information you provide when you use any interactive features of the Services.
  • Marketing information, such as your preferences for receiving communications about our Services, and details about how you engage with our communications.
  • Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from third parties

  • Social media information. We may maintain pages on social media platforms, such as Facebook, LinkedIn, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider's privacy policy will apply to your interactions and their collection, use, and processing of your personal information. You or the platforms may provide us with information such as your biographical, educational, and professional experience, and we will treat such information in accordance with this Privacy Policy.
  • Other sources. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources, and data providers.

Automatic data collection. We, our service providers, and advertising partners may automatically log information about you, your computer or mobile device, and your interactions over time with our Services, our communications, and other online services, such as:

  • Device data, such as your computer's or mobiledevice's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened our marketing emails or clicked links within them.

We use the following tools for automatic data collection:

  • Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor's browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How we use your personal information

To operate our Services

  • Provide, operate, maintain, secure, and improve our Services.
  • Provide you with customer service.
  • Communicate with you about our Services, including by sending you announcements, updates, security alerts, and support and administrative messages.
  • Understand your needs and interests, and personalize your experience with our Services and our communications.
  • Respond to your requests, questions, and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.

Marketing and advertising. We and our advertising partners may collect and use your personal information for marketing and advertising purposes, including:

  • Direct marketing. We may from time-to-time send you direct marketing communications as permitted by law, including, but not limited to, notifying you of special promotions, offers and events via email and in-app notifications. You may opt out of our marketing communications as described in the “Opt out of marketing communications” section below.
  • Interest-based advertising. We or our advertising partners, including third party advertising companies and social media companies, may use cookies and similar technologies to collect information about your interactions (including the data described in the “Automatic data collection” section above) over time across our Services, our communications and other online services, and use that information to serve online ads that they think will interest you. We may also share information about our users with these companies to facilitate interest-based advertising to them or similar users on other online platforms.

Compliance and protection

  • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
  • Protect our, your or others' rights, privacy, safety, or property (including by making and defending legal claims).
  • Audit our internal processes for compliance with legal and contractual requirements and internal policies.
  • Enforce the terms and conditions that govern our Services.
  • Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

How we share your personal information

Service providers. We may share your personal information with third-party companies and individuals that provide services on our behalf or help us operate our Services (such as lawyers, bankers, auditors, insurers, customer support, hosting, analytics, email delivery, marketing, and database management).

Advertising partners. We may share your personal information with third-party advertising companies. This sharing may qualify as a data “sale” under applicable privacy laws. To opt out of this data sharing, please see the “Your rights and choices” section below.

Authorities and others. We may disclose your personal information to law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.

Your rights and choices

Access or update your account information. Clients may themselves update their personal information in their accounts by logging in and editing their information.

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may continue to receive service-related and other non-marketing emails.

Privacy rights. Depending on your jurisdiction and subject to certain exemptions, you may have the following privacy rights in relation to the personal information we collect:

  • The right to know what personal information we have collected and how we have used and disclosed that personal information. We provide this information within this Privacy Policy.
  • The right to request a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable and readily-usable format.
  • The right to correct personal information that is inaccurate or out of date.
  • The right to request deletion of your personal information.
  • The right to opt out of sale, and the right to opt out of the processing of personal information for targeted advertising.

Exercising your rights. You can exercise their rights by visiting “Your Privacy Choices,” emailing us at legal@particl.com or calling us at 801-891-3112. You are entitled to exercise these rights free from discrimination.

Verification. In order to protect your personal information from unauthorized access or deletion, we may require you to verify your identity and proof of residency before you can submit a request. If we cannot verify your identity, we will not process your request.

Authorized agents. Depending on your jurisdiction, authorized agents may submit requests on your behalf. If you submit a request through an authorized agent you may also be required to independently verify your identity and submit proof of your residency directly to us.

Online tracking opt out

There are a number of ways to limit online tracking, which we have summarized below:

  • Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
  • Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
  • Using privacy plug-ins or browsers. You can block our services from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.
  • Platform opt outs. The following  platforms offer opt out features that let you opt out of use of your information for interest-based advertising:
  • Advertising industry opt out tools. You can also use these opt out options to limit use of your information for interest-based advertising by participating companies:

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.

Other sites, mobile applications, and services

Our Services may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

Security

Please note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Any information you transmit to us you do at your own risk.

International

If you are interacting with the Services from outside of the United States, please be aware that you are sending information to the United States where our servers are located. That information may then be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how it is stored or used by us. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence.

Children

Our Services are not intended for use by children under 13 years of age. If we learn that we have collected personal information through the Services from a child under 13 without the consent of the child's parent or guardian as required by law, we will delete it.

Job applicants

When you apply for a job with us, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics. We may also use this information to provide improved administration of the website, and as otherwise necessary (a) to comply with relevant laws or to respond to subpoenas or warrants served on us; (b) to protect and defend the rights or property of us or others; (c) in connection with a legal investigation; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Service.

Changes to this Privacy Policy

We may modify this Privacy Policy from time to time in which case we will update the effective date at the top of this Privacy Policy. If we make material changes to the way in which we use information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on our website, or by other means consistent with applicable law) and will take additional steps as required by applicable law.

How to contact us

Please direct any questions or comments about this Policy or our privacy practices to:

Attention: Andrew Kenney
11456 S Temple Drive
Suite 100
South Jordan, UT 84095
Telephone: 801-891-3112
Email: legal@particl.com