Privacy Policy

Privacy Policy

Our Privacy Policy was last updated in January, 2024. 

OUR COMMITMENT TO YOUR PRIVACY

Cilio Technologies, LLC (“Cilio,” “we,” “us,” or “our”) has created this privacy statement (“Privacy Policy”) for the users of our Application or Services (“you” or “your”) and to demonstrate our firm commitment to your privacy.

This Privacy Policy is based on applicable privacy and data protection principles in the countries in which we operate. This Privacy Policy describes the information collected, used, and disclosed by Cilio.  While this Privacy Policy describes how we treat Personal Data we collect, please be aware that additional terms and conditions may apply to the use of the Application and other services. Cilio will take reasonable steps to protect user privacy consistent with the guidelines set forth in this Privacy Policy and the applicable laws. Cilio is the Controller for the personal information we process, unless otherwise stated.

ACCEPTANCE OF THIS PRIVACY POLICY

BY USING THE APPLICATIONAPPLICATION AND CONTENT THEREIN AND OUR OTHER SERVICES , YOU CONSENT TO THE COLLECTION AND USE OF INFORMATION BY US IN ACCORDANCE WITH THIS PRIVACY POLICY, AND YOUR CONTINUED USE INDICATES ACCEPTANCE OF ANY MODIFIED OR UPDATED TERMS. 

Any terminologies not expressly defined in this Privacy Policy will carry the definitions as outlined in the Terms of Use.

If you are a California resident, please also see Appendix A “Privacy Information for California Residents” for supplemental California-specific privacy information.

DEFINITIONS

For the purposes of this Privacy Policy:

  • “Account” means a unique account created for You to access our Service or parts of our Service.
  • “Affiliates” means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority
  • “Application” refers to refers to the software or platform provided by Cilio Technologies, LLC, which includes the Cilio Platform used to access our Service or parts of our Service.
  • "Cookies" are small files that are placed on your computer, mobile device, or any other device by an Application, containing the details of your browsing history on that Application among its many uses.
  • “Company” (referred to as either "the Company", "We", "Us" or "Our" in this Policy) refers to Cilio Technologies, LLC.
  • "Country” means United States of America
  • "Data Controller", for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • "Device" means any device that can access our Service such as a computer, a cell phone, or a digital tablet.
  • “GDPR” means the General Data Protection Regulation enacted by the European Parliament and Council of the European Union.
  • "Personal Data" means any information relating to an identified or identifiable natural person (‘Data Subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
  • “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction. In processing your Personal Data, we pledge to fully comply with recognized standards of privacy protection. We will ensure that all Personal Data is processed in compliance with this Privacy Policy and the following guiding principles (“Principles”):
  1. Lawfulness, transparency, and fairness
  2. Purpose limitation
  3. Data minimization
  4. Accuracy
  5. Storage limitation
  6. Confidentiality and integrity
  • “Processor” means a natural or legal person, public authority, agency, or other body which processes Personal Data on behalf of the Controller;
  • "Usage Data” refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • “You” means the individual accessing or using the Service, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. 

CONSENT 

Our Services and Application are made for use by Data Subjects over the age of 18.  By using our Application, you hereby consent to our Privacy Policy and agree to its terms.

COLLECTION OF YOUR PERSONAL DATA

Information you provide to us. We may collect Personal Data about you when you provide it to us while registering for an Account or using or interacting with the Application or using our Services. You may  be required to register in order to be granted access to certain information, services, and/or products on the Application. For example, you will need to register if you sign up for our support site. 

We may collect the following Personal Data when you provide it to us (which may include but is not limited to):

  • Your name;
  • Your title;
  • Your company name;
  • Your e-mail address;
  • Your mailing address;
  • Your telephone number; 
  • Account/payment information.

Further, while using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

  • Information regarding your location
  • Information from your device's phone book (contacts list)
  • Pictures and other information from your device's camera and photo library

You can enable or disable access to this information at any time, through Your Device settings.

AUTOMATIC DATA COLLECTION AND TRACKING

Information Collected while Using the Application

We may also receive messages or content you submit that contain Personal Data, as well as other information that may personally identify you that you submit to us. If you choose to respond to a survey we conduct, we will collect your responses. 

The information that we collect and use may include profile information, interactions on webpages, marketing preferences, information to investigate malicious activities, recordings, or transcripts of your conversations with us for support purposes, and more. We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to our servers and/or a Processor's server or it may be simply stored on your Device.

You can enable or disable access to this information at any time, through your Device settings. 

USAGE DATA

Usage Data is collected automatically when using the Service. As you use our Application or services, we may use technologies that collect certain information about you automatically. We may collect, among other things, your IP address, location, device type, date and time of visit, operating system, browser type and version, activities on the Application or services, and information about how you use the Application or services. If you are visiting the Application or using the services via a mobile device, we may also collect your mobile device’s unique device ID and information about how you use the Application or services. Mobile application privacy notices may provide details about the information that is collected by the Application, such as geo-location information or the unique User-ID of a device. Unique User-IDs are used to connect to servers and to connect the use of the device across applications. Depending on the functions of the Application, you can tailor your privacy settings by using the settings menu or in your user profile.

We may also collect information about what you download and upload to the Application or services. We may also collect information about the use of these Services, such as pages you view or your interactions on that page, to improve and develop our services and to generate technical and market insights. For more information on how the Application or services use cookies, please see the below section titled “Use of Cookies.” 

Information we receive from other sources. From time to time, we may also receive information about you from our third-party service providers, affiliates, customers, and partners, including our marketing, conference, and advertising partners and social media networks. We may also receive information from third-party analytics that allows us to improve our Application and Services.

We may also collect information about you from publicly available sources.

We accept no responsibility for the content provided on, or privacy practices, of third-party websites or applications.

USE OF YOUR PERSONAL DATA

The Personal Data that you provide to Cilio may be stored, processed, and used by Cilio and its Affiliates for the following purposes: 

  • To provide and maintain our Services and to otherwise operate our business, including to monitor the usage of our Service;
  • To manage your Account: to manage your registration as a user of the Service. The Personal Data you provide can give you access to different functionalities of the Service that are available to you as a registered user.
  • To manage Your requests: To attend and manage your requests to us.
  • To provide you with information about our company, products, and/or services, including updates, notifications, and details of any offers or promotions unless you have opted not to receive such information; 
  • To assist us in improving our products, services, or the content of this Application; 
  • for our own internal marketing and research purposes;
  • To make the Application easier to use by eliminating the need for you to repeatedly enter the same information or by customizing the Application to your particular interests or preferences;
  • To analyze information for trends and statistics; 
  • To facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements;
  • To administer, operate, facilitate, and manage your relationship and/or account with us. This may include sharing such information internally, as well as disclosing it to our Affiliates or other third parties
  • To comply with our legal obligations or requests from law enforcement and government agencies; 
  • To audit downloads of information from the Site and also make follow-up contact with you by email in relation to the material you have accessed
  • For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Service users is among the assets transferred.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation. Further to contact you to participate in a market research survey so that we can gauge customer satisfaction.
  • For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing, and your experience.

We may also disclose or process de-identified information for commercially legitimate and lawful business purposes. Where we have de-identified data, we will maintain and use it without attempting to re-identify the data other than as permitted under law.

We do not use sensitive Personal Data to infer characteristics about our business contacts

Legal Basis for Processing Personal Data

We may process the Personal Data under the following conditions: 

  • Consent: You have given your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which we are subject.
  • Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

Sharing Your Information with Third Parties

We may share your information with third parties as follows:

  • With Service Providers that assist us in providing Services offered through the Application, including, but not limited to, Services related to technical maintenance, database management, or advertising and marketing research; 
  • Data analytics and advertising providers. We may use third-party Application providers to monitor and analyze the use of our Site;
  • With Affiliates: We may share your information with our Affiliates, in which case we will require those Affiliates to honor this Privacy Policy.
  • Law Enforcement: To comply with our legal obligations or requests from law enforcement and government agencies; 
  • to enforce or protect the terms of our services, rights, property, safety, or that of our users or third parties;
  • With business partners: We may share your information with our business partners to offer you certain products, Services, or promotions.
  • With other users: When you share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  • For business transfers: as part of due diligence for, or the consummation of, a transaction involving the merger, sale, divestiture, or other transaction involving the equity or assets of Cilio; or
  • With your consent: In accordance with consent you’ve provided, we may disclose the Personal Data.

We may share aggregate, de-identified information with others, including affiliated and non-affiliated companies, for any legal purpose.

USE OF COOKIES

To help us to constantly improve our services and understand the needs of our Data Subject, we may implement software on the Application that enables us to track information about the nature of usage and navigation through the Application.  Information may also be collected through small data pieces known as cookies, stored on the Cilio’s servers, which may also be written to your computer system.  There are technologies allow the us to access and store information (for example by using a Cookie) or use resources (for example by running a script) on your device as they interact with this Application. For simplicity, all such technologies are defined as "Trackers" herein – unless there is a reason to differentiate.

For example, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker.

Some of the purposes for which Trackers are used may also require your consent. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document.

In general, our purposes for using Trackers are:

  • Analytical. We use cookies to analyze user activity in order to improve the Application. For example, we can use cookies to look at aggregate patterns like the average number of views on a specific Application page. We can use such analyses to gain insights about how to improve the functionality and user experience of the Application.
  • Your Preferences and User Experience. We use cookies to gather certain information about users, such as browser type, server, language preference, and country setting, in order to store user preferences on our Application and to make your user experience more consistent and convenient. We may also use your IP address to determine your geographic location in order to provide you with the most relevant search results. We may use persistent cookies to remember your preferences and various settings.
  • Referral Tracking. We use cookies to associate user activity with the third party Application that referred you to our Site, or to associate user activity that we referred to a third party Application. We do not share any Personal Data or information about individual user activities with these partner entities. We also use cookies to associate user activity with the email campaign that referred the user to our Site.
  • Security. We use cookies to limit certain types of cyber-attacks and other data security incidents.
  • Testing, Usability, and Performance. We use cookies to ensure users receive a consistent user experience while we conduct A/B testing on certain aspects of our Site in order to improve our product offerings. We also use cookies to improve the performance and reliability of our Site.
  • Fraud/Spam Prevention. We use cookies during fraud reviews and investigations. Some of our cookie/device tracking happens via third party vendors. Other times, we use our own indexes to identify activity related to specific cookies.

 

By way of an example, wherever applicable, our Application includes cookies used by Google Analytics Advertising Features. You may disable the use of cookies, but this will limit the functionality available to you on future visits. For more information on how Google Analytics collects and processes data, please see http://www.google.com/intl/en/policies/technologies/ads/.  

YOUR CHOICES

You have the ability to accept or decline cookies. However, if you choose to decline cookies, you may not be able to fully experience the features of the Application or services you visit. Information on deleting or controlling cookies can be found at www.aboutcookies.org.

You can opt out of Google Analytics by, wherever applicable:

  • Changing your settings at Google’s Ad Settings at: http://www.google.com/settings/ads
  • Installing an opt-out browser add-on available at: https://tools.google.com/dlpage/gaoptout/
  • Adjusting the settings on your web browser: See http://www.google.com/intl/en/policies/technologies/managing

Our Application does not respond to “Do Not Track” requests. 

Opt-Out. You may opt out of receiving future marketing communications from us at any time. You can opt out by using the unsubscribe process in our marketing communications or by contacting us using the below listed methods. We will use commercially reasonable efforts to process such request in a timely manner. Depending on where you live, you may have other rights related to your Personal Data. If you have a question regarding such rights, please contact us at the below-provided information.

INTERNATIONAL TRANSFERS OF PERSONAL DATA

 

For Personal Data, which may be collected or transferred outside the US, specifically to the European Union (EU) will be subject to the applicability of the General Data Protection Regulation (GDPR)

 

  1. Cilio is located in the United States. Please note that by using our Application, you give Cilio your express and informed consent to transfer the Personal Data that you provide to Cilio out of your country of residence to the United States, and to process it in the United States.
  2. We may transfer the Personal Data we collect about customers and users to countries other than the country in which the Personal Data was originally collected. These countries may not have the same data protection laws as the country in which you provided the Personal Data. When we transfer Personal Data to other countries, we will protect the Personal Data as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for the transfer of Personal Data to countries outside the originating country.
  3. By providing us with your Personal Data, you consent to this transfer to the U.S. which your country may not consider providing for adequate privacy protections. You may withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent prior to its withdrawal.

YOUR RIGHTS (AS PER GDPR)

Cilio undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights. You have the right under this Privacy Policy, and by law if you are within the EU, to:

    • Request access to Your Personal Data. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the Personal Data we hold about you.
    • Request correction of the Personal Data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
    • Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our Processing and there is something about your particular situation, which makes you want to object to our Processing of your Personal Data on this ground. You also have the right to object where we are Processing your Personal Data for direct marketing purposes.
    • Request erasure of your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it.
    • Request the transfer of your Personal Data. We will provide to you, or to a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw your consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service. You may withdraw your consent by contacting us at 1-262-320-0480. 
  • Submit a complaint to Cilio if you are not satisfied with how Cilio is processing your Personal Information. 

SECURITY OF INFORMATION

To protect the privacy of Personal Data provided by you, Cilio has implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. 

Unfortunately, the transmission of information via the internet is not completely secure. We urge you to take every precaution to protect your Personal Data when you are on the internet. Although we will take reasonable efforts to protect your personal information, we cannot guarantee the security of such information transmitted to our Application or services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Application or services.

MOBILE DEVICES

 

We may send you push notifications through our Application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. With your consent, we may also collect location-based information if you use our Applications. You may opt-out of this collection by changing the settings on your mobile device.

CHILDREN UNDER THE AGE OF 13

We do not knowingly collect Personal Data from children under 13. In the event that we learn that we have collected Personal Data from a child under the age of 13 without parental consent, we will delete that information and otherwise comply with the requirements of any applicable law including the Children’s Online Privacy Protection Act. If you believe someone under the age of 13 has provided us with Personal Data, we ask that you contact us through the methods described below.

We request you to please provide the following information in your complaint: -

  • Your contact details
  • Personal Data provided to Cilio by you.
  • A statement that you have a good-faith belief that your Personal Data has been processed or disclosed by Cilio in a manner that is contrary to this Privacy Policy or has breached the applicable laws.
  • Any other relevant information pertinent to your complaint.

We may contact you to confirm or discuss specific details related to your complaint and the issues raised. We are committed to resolving such complaints and/or issues promptly and will make every effort to do so as soon as possible.

CHANGES TO PRIVACY POLICY

Cilio reserves the right to change this Privacy Policy at any time without notice to you, and Cilio will post any changes to this Privacy Policy on the Application as soon as they go into effect. We encourage you to review the Privacy Policy regularly for any changes.

Changes to this Privacy Policy shall be effective when they are posed on this page. Your continued use of any of this Application means that you have read, understood, and accepted the changes

CONTACT US

Should you have any questions regarding this Privacy Policy or feel that we do not comply with this policy in any way, please contact us at Privacy@ciliotech.net    or at our Contact Us Form.

 

Appendix A

Privacy Information for California Residents

Effective Date: January 1, 2024

This Appendix applies solely to individuals who reside in the State of California (“consumers” or “you”).  This Appendix complies with the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Acts of 2020 (CPRA) and any terms defined in the CCPA have the same meaning when used in this Appendix.  This Appendix supplements the Cilio Privacy Policy and does not apply to Personal Information outside the scope of the CCPA.

We may provide additional data privacy information by using a supplementary privacy notice with activity-specific or offering-specific information.

  1. Cilio as a Service Provider

When we act as a service provider for our customers, we collect personal information on behalf of our customers subject to our contractual obligations.  When we act as a service provider, we follow the instructions of our customer on how to process personal information on our customer’s behalf.  The provisions of this Appendix do not apply to the personal information that we process on behalf of our business customers.

  • What Personal Information We Collect and How We Share it

The below chart lists the categories of personal information that we may collect and have collected in the past 12 months and how we share such information. 

Categories of Personal Information Categories of  Services Providers and Third Parties with whom Personal Information is Shared
Identifiers. This may include a real name, alias, address, email address, phone number, online identifier, IP address, [account username and password], job title, or other similar identifiers. Entities that we are required to share with pursuant to law or for legal proceedings; service providers; ad networks; data analytics providers; prospective purchasers of our business; outside auditors and lawyers; and social networks.
Internet and network information. This may include information on your interaction with an Application, application, or advertisement, such as browsing history and how you use your account. Entities that we are required to share with pursuant to law or for legal proceedings; service providers; ad networks; data analytics providers; and social networks.
Device information. This may include the operating system of your device, device identifier, the type of device you are using, or your geolocation information. Entities that we are required to share with pursuant to law or for legal proceedings; service providers; ad networks; data analytics providers; and social networks.
Other information you submit to us. This may include requests or communications you submit to us, including emails, ratings, or customer service call recording. Entities that we are required to share with pursuant to law or for legal proceedings; service providers; ad networks; data analytics providers; prospective purchasers of our business; outside auditors and lawyers; and social networks.
Research or survey information. This may include survey results, social media data, and other information about your participation in consumer research. Entities that we are required to share with pursuant to law or for legal proceedings; service providers; ad networks; data analytics providers; prospective purchasers of our business; outside auditors and lawyers; and social networks.
Inferences we draw about you. This may include information about your preferences, characteristics, predispositions, behavior, or other trends that help us identify which products you may be interested in. Entities that we are required to share with pursuant to law or for legal proceedings; service providers; ad networks; data analytics providers; prospective purchasers of our business; outside auditors and lawyers; and social networks.

 

Sensitive Personal Information:

  • State or Government issued identification such as a consumer’s social security, driver’s license, state identification card, or passport number.
  • Financial Information such as a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.

Retention:

For each category of personal information, Cilio retains your personal information only for as long as necessary, based retention criteria including:

  1. the time required to fulfil the business or commercial purposes for which personal information is processed,
  2. the time required to comply with legal and regulatory retention requirements, and
  3. the time required to maintain contractual and customer relationships.
  1. Where We Collect Personal Information From

We may collect personal information from the following sources: you, your agent, our other customers, service providers, ad networks, data analytics providers, social media networks, and online third party marketplaces. 

  1. How We Use Personal Information

We may use personal information in the following ways:

  • To provide you with information, products, or services; 
  • To advertise or market to you; 
  • To improve our services and products;
  • To secure and monitor our Applications and services;
  • For consumer research and conducting surveys;
  • To conduct giveaways or contests; or
  • For our own legal obligations and business needs.

 

  1. Sale and Share

CCPA defines a “sale” of personal information broadly to include more than exchanges for monetary purposes. A sale can include personal information shared with a third party for “valuable consideration,” or information shared with a third party (even if they are performing services on our behalf) if they are permitted to use the information for their own purposes.

We do not sell your personal information (as the term sell is commonly understood) for monetary payment, whatsoever.  To ensure we can share our products with you and tailor our advertisements, we do allow some of our advertising partners to use cookies, pixels, and other technologies to collect personal information on our website or services, and this may constitute a “sale” of personal information under CCPA. Cilio may have shared certain personal information with third parties, such as advertising technology partners, data analytics providers, and social networks for the purpose of targeted advertising, which may qualify as sharing under the CCPA.

California Residents’ Rights and Choices

As a California resident, you have the right to:

  • Access to Specific Information and Data Portability Rights (“Right to Know”)

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.  You could request:

  • The categories of personal information we collected about you;
  • The categories of sources of the personal information we collected about you;
  • Our business or commercial purpose for collecting that personal information;
  • The categories of third parties with whom we share that personal information; or
  • The specific pieces of personal information we collected about you.

 

Keep in mind that CCPA does not apply to information you have provided to us or that we have collected from you that is subject to the federal Gramm-Leach-Bliley Act (GLBA), or the Fair Credit Reporting Act (FCRA), so we will deny any Right to Know concerning personal information subject to GLBA or FCRA.  Our employees and employees of our business partners and service providers also do not have a Right to Know.

 

  • Deletion Request Rights 

You have the right to request that we delete some or all of the personal information that we have collected from you and retained, subject to a number of exceptions.  We are not required to delete personal information that is: (a) necessary to complete a transaction with you or for warranty or product recalls; (b) used for security purposes, to prevent fraud, to fix errors, or to comply with law; (c) reasonable for us to use for internal purposes given our relationship with you; or (d) compatible with the context in which you provided the information.  The list of exceptions above is not exhaustive, and we may also deny a deletion request as otherwise permitted by law.

The same limitations described above with respect to the Right to Know, apply to the Right to Deletion.

  • Exercising Your Rights

To exercise your rights described above, please submit a verifiable consumer request to us by either: 

Only you, or a person or entity that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.  You may also make a verifiable consumer request on behalf of your minor child.  If you are making a request on behalf of another person, you must provide written legal documentation that you are authorized to act on behalf of that individual. 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.  The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We may not be able to fulfill your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  To verify your identity, we may request up to three pieces of personal information about you, and we reserve the right to take additional steps as necessary to verify your identity if we have reason to believe a request is fraudulent.

  1. Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the date we receive your verifiable consumer request.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

  • Non-Discrimination

You have the right to not be discriminated against for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services; or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels.  Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program's material aspects.  Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.  

  • Authorised Agent

You may use an authorized agent to submit a request about your personal information. To use an authorized agent, you must provide the agent with written authorization. In addition, you may be required to verify your own identity with Cilio.

  • Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83 – 1798.84) permits users of our Application that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. That notice will identify the categories of personal information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. To make such a request, please contact us through the information provided above.

 

  1. Changes to this Appendix

We reserve the right to amend this Appendix at our discretion and at any time.  When we make changes to this Appendix, we will post the updated notice on our Application and update the effective date on this Appendix.  Your continued use of our Application, products, or services following the posting of changes constitutes your acceptance of such changes.

  • Contact Information

If you have any questions or comments about this Appendix the ways in which we collect and use your information, your choices, and rights regarding such use, or if you wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: https://www.ciliocio.com

Email: Privacy@ciliotech.net   

Postal Address: 200 South Executive Drive, Suite 101, Brookfield, WI 53005