PRIVACY

Consumer Privacy Notice

VERSION 1

Effective Date: January 25, 2023

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Luz Data, Inc. (d/b/a Particl) provides its enterprise customers (“Clients”) with real-time market research, pricing optimization, and forecasting data. As part of our services, we collect information about individual consumers (“Consumers,” “you,” and “your”) both on Clients’ own websites, other sites and services across the web, and third-party data providers. With this information, we enable clients to understand Consumer journeys and create advertising audiences.

This Privacy Notice describes how we handle Consumers’ personal information that we collect in connection with providing our services to our Clients.

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

Personal information we collect

By integrating their e-commerce websites with our enterprise platform, Clients share their Consumers’ data with Particl. For example:

  • By integrating their order history with Particl, Clients share with us information about their Consumers’ purchases on their sites, as well as Consumers’ names, email addresses, mailing addresses, and other details.
  • By integrating their marketing providers with Particl, Clients may share information about marketing communications with their Consumers and how Consumers interact with those communications.

By installing Particl’s tracking technologies – such as pixels – on their websites, Clients share information about their Consumers’ interaction with those sites including:  

  • Device data, such as Consumers’ computer or mobile device operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, and unique identifiers (including identifiers used for advertising purposes).
  • Online activity data, such as information about how Consumers interact with the website – including whether Consumers make or fail to complete purchases, pages or screens Consumers viewed, how long they spent on a page or screen, browsing history, navigation paths between pages or screens, information about their activity on a page or screen, access times, and duration of access.

We may use the following tracking technologies to collect Consumers’ information from our Clients’ websites:

  • 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.
  • 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.

We may also obtain information about Consumers from publicly-available sources, data providers, and marketing partners.

To provide our services, we combine all Consumer data we collect into a data lake, to create insights for our Clients.

How we use Consumer personal information

To provide our services to Clients. We use the data we collect across our Clients to help Clients understand Consumer journeys and create custom advertising audiences, so that our Clients can more effectively engage with their Consumers. We may also use the information to facilitate Clients’ engagement with advertisers.

For 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.

Compliance and protection. We may use personal information to:

  • 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

Our Clients. As part of the services we offer to our Clients – as described in the “How we use Consumer personal information” section above – we share insights about specific Consumers with those Clients. 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. Please note that our Clients’ use of Consumer personal information they obtain from Particl is governed by those Clients’ own privacy policies, and not by this Privacy Notice.

Advertising companies. We may share Consumers’ personal information with third party advertising companies on behalf of our Clients. 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.

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).

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 Notice.

Your rights and choices

Privacy rights

Depending on your jurisdiction, 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 Notice.
  • 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. When you exercise this right, we will no longer use your information across our Clients or include you in custom audiences. Please note that even if you opt out, you are likely to continue to see our Clients’ advertising across the web. This happens because our Clients’ may participate in a variety of third-party online advertising programs in addition to Particl. To limit advertising by our Clients, please visit the Clients’ websites and exercise the privacy choices that Clients make available to you (also see the “Limiting online tracking” section below).

Exercising your rights. You can exercise your 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.

Limiting online tracking

Here are some tips on how you can limit the collection of your information on our Clients’ websites. Please note that we do not control the privacy choices our Clients’ offer their Consumers, including with respect to online tracking.

  • Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for targeted 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 targeted 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 targeted advertising:
  • Advertising industry opt out tools. You can also use these opt out options to limit use of your information for targeted 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.

Security

Please note that any information you send to us or that we receive electronically 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 our services – including by visiting our Clients’ retail websites – 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.

Changes to this Privacy Notice

We may modify this Notice from time to time in which case we will update the effective date at the top of this Notice. 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 Notice 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

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