Privacy Policy

This Privacy Policy was last updated on July 30, 2023.

Exadel, Inc., a California corporation (“Exadel”, “we”, or “us”) provides software development services and is headquartered in Walnut Creek, California.

If you are a resident of California and wish to learn more about our privacy practices, you can find the Notice at Collection and learn more about your rights in the California Rights section of this Privacy Policy.

1. WHAT THIS PRIVACY POLICY COVERS

This privacy policy (“Privacy Policy”) describes the Personal Information we collect about you from our website, communications with us or offline when you use our services (“Services”), how we use that Personal Information, and your rights and the choices you have relating to your Personal Information. This Privacy Policy covers individuals who have a business relationship with us, such as business customers, suppliers, or vendors, and it also covers job applicants. By using any of Exadel’s Services and by also consenting to provide your Personal Information, you acknowledge that you accept the practices and policies outlined in this Privacy Policy. If you do not agree with or cannot comply with this Privacy Policy, please do not use our Services.

This Privacy Policy does not apply to the use of your Personal Information that may be collected by third parties that Exadel does not own or control or that do not support Exadel in providing the Services. “Personal Information” is information that identifies, relates to, describes, or is reasonably capable of being associated with you.  

2. WHAT PERSONAL INFORMATION DO WE COLLECT, AND HOW DO WE COLLECT IT?

Personal Information We Collect Directly From You

We may collect the following Personal Information when you voluntarily provide it to us through a number of features available on the Services and consent to this. 

Contact and Account Information: We collect information from you when you communicate with us, order Services, or otherwise provide us with your information. The information we collect from you may include your contact information (name, e-mail address, and telephone number), mailing and billing address. 

Order and Product Information:  When you order or purchase our Services, the information we collect from you may include payment information, purchase history, and other information we request from you or you provide to us, including information used to facilitate the processing of your orders. 

Communications Information: When you communicate with us by email or through our Contact Us submission form, or otherwise communicate with us, we retain the contents of those communications so that we can respond to your questions and comments, and to help us improve our communications.

Education and Employment Information:  When you apply for a job with us, the information we collect from you may include your employment related and voluntary demographic information, such as race and ethnicity, citizenship or immigration status.  

Location Information: Some of our Services may allow you to submit information about your general location, such as your city or state. We may also access this location information using your IP address collected from our website.

This Privacy Policy describes Exadel’s practices with respect to Personal Information that we collect when you use our Services. This Privacy Policy does not apply to the use of your Personal Information that may be collected by third parties that Exadel does not own or control or that do not support Exadel in providing the Services. “Personal Information” is information that is personally identifiable like names, addresses, e-mail addresses, or phone numbers, as well as other non-public information that is associated with the foregoing, as described herein.

Personal Information We Collect Automatically From You

Device and Online Activity Information: Exadel and our third–party service providers may use a variety of technologies that passively or automatically collect information about how our visitors are browsing the website. The information collected through these technologies includes online identifiers such as IP address, device ID and operating system, and online activity, such as the browsers that you are using, websites that you came from, type device that you are using, where you downloaded our app and how often you use it, browsing activity, other app usage, referring websites, web page visits, use of tools on the Services and links clicked and other analytics data.  If you access our Services using a mobile device like a smartphone, we may also collect your phone’s unique device ID and other similar mobile device data.

Cookies: Like many websites, we use “Cookies” for our website, which are small text files placed on your browser to facilitate site navigation and to personalize your experience. The tracking technology is further described in the “Cookies and Similar Technologies” section below.

Personal Information We Collect About You From Third Parties

We also collect the following information from third parties:

• Lead Generators.  We work with third parties that provide us with lists of potential prospects or customers for our Services.  We use that information for marketing purposes. 

Third Party Applications: We also offer and deliver services, content or interactive features through and/or using third party application programming interfaces (API), gadgets, extensions that are hosted on our Services or through other third party websites, or social networking platforms. When you participate in these services, products, applications, or otherwise connect with, or “accept” or “allow” third party applications, networks, platforms or services through our Services and/or one of our services or products, you are authorizing those third parties to receive your information and additionally to potentially share any or all of your information with us, based on your privacy or other settings on the particular third party network or platform. Any personal or other information we receive by these means will be treated and/or processed according to this Privacy Policy.

3. HOW DO WE USE THE PERSONAL INFORMATION WE COLLECT?

In general, we use the information (including Personal Information) you submit to us or third parties who work on behalf of or with us to respond to requests you make or to improve our Services and better meet the needs of our consumers Examples of how we might use this information include:

• To present our website and its contents to you.
• To identify you or your browser or device 
• To complete online transactions you have made or to fulfill orders you have placed;
• Respond to or follow-up on your inquiries, comments, questions or other requests;
• Deliver our own marketing e-mails or updates;
• Conduct research or analysis surrounding our products, business or Services;
• Communicate with you about programs, if any, in which you elected to participate; and
• Publish your reviews, comments, photos, videos and other content you have posted to one of our interactive or user-generated features.
• To determine your eligibility for jobs or certain products and services.
• For marketing and advertising purposes, including prospecting and targeted advertising.
• For security purposes.
• For internal business purposes.
• To comply with applicable laws and regulations.
• To notify you about changes to our website or applications or any of our Services

4. WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?

Personal Information will be disclosed for the purposes set forth herein or in accordance with applicable laws.  We may disclose aggregated or deidentified information about our users, and information that does not identify or allow for the reidentification of any individual, without restriction. 

We may also disclose Personal Information to third parties under the following limited circumstances

• To contractors, service providers, and other processors we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for specific purposes for which we disclose it to them.
• To a buyer or other successor in interest in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding in which Personal Information held by us about our website users is among the assets transferred.
• When necessary to protect against, and detect a fraud. 
• To cooperate with law enforcement officials, comply with any court order, law or legal process, including to respond to any government or regulatory request.
• To third parties and business partners for business, marketing or advertising purposes, such as with social media sites when you respond to an ad there or advertising networks, agencies or analytics partners. 
• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to the rights, property or safety of Exadel, our customers or others or to comply with applicable laws and regulations.  
• For any other purpose we may describe to you and as where necessary to which you consent.

When you direct or authorize to share Personal Information for any other purpose, we will do so.

5. HOW DO WE PROTECT YOUR PERSONAL INFORMATION

Exadel has put in place commercially reasonable and appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. However, no company, including Exadel, can fully eliminate security risks associated with Personal Information. 

6. WHAT CHOICES DO YOU HAVE REGARDING YOUR PERSONAL INFORMATION, AND HOW TO CORRECT INFORMATION.

You have choices when it comes to the technology you use and the Personal Information you share.  When we ask you to provide Personal Information, you can decline.

You can opt out of our emails. We will include unsubscribe instructions in each newsletter or promotional communication you receive from us.

You can make certain requests. You can send us requests to access, correct, delete, or update personal information. When we delete information that we have collected from or about you, it will be deleted from our active databases, but may remain in our archives. You can make any of these requests by contacting us at [email protected].

7. ONLINE ADVERTISING AND THIRD PARTY TRACKING

Cookies and Similar Technologies

Like many websites, we use “Cookies” for our website, which are small text files placed on your browser to facilitate site navigation and to personalize your experience. Cookies allow us to select which ads or offers are most likely to appeal to you, based on your interests, preferences, location, or demographic information. 

There are a couple different types of cookies. A “session” cookie is stored only in your computer’s working memory (RAM) and only lasts for your browsing session. When you close all your browser’s windows, or when you shut down your computer, the session cookie disappears forever. A “persistent” cookie is stored on your computer’s hard drive until a specified date, which could be tomorrow, next week, or 10 years from now. Persistent cookies stay on your computer until either a) they expire, b) they are overwritten with newer cookies, or c) you manually remove them.  You may learn more about cookies by visiting https://www.allaboutcookies.org. For more detail on the cookies we use and your choices, please visit our cookie settings page.

You can also change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; or set your browser to automatically not accept any cookies. While you will still be able to use the Services if you disable Cookies in your browser, certain parts of the Services may not function as effectively.

Changing cookies on your browser will not change the way you are tracked on a mobile device. You can adjust your tracking preferences on your mobile device through your device settings.

We may contract with third-party service providers to assist us in analyzing cookies and similar technologies. For example, we use Google Analytics to understand how our website performs and how you use it. These third parties can use cookies and other technologies to collect information, such as the browsers you use to access our site, websites viewed, time spent on websites, and links clicked.

To learn more about how Google processes your data, please visit https://www.google.com/policies/privacy/

To opt out of Google Analytics please visit https://tools.google.com/dlpage/gaoptout.

Interest Based Advertising

To provide you a more relevant and interesting experience, we may work with third party companies to display ads elsewhere on the Internet. These companies may use cookies (a small text file), pixels, or similar technologies that are placed in browsers to gather information about your visits to the Exadel website, your use of the Services, and your visits elsewhere on the Internet. These companies use this information to provide you more relevant advertising known as interest-based advertising. Some of these companies may be participants in the Digital Advertising Alliance (“DAA”). The DAA offers a choice mechanism with respect to certain types of data collection and use. Visit www.aboutads.info to exercise choice with respect to participants of the DAA. If you change computers or browsers, use multiple computers or browsers, or delete your cookies, you may need to repeat this process for each computer and each browser.

8. PRIVACY OF MINORS

Our Terms of Use prohibit individuals under age 18 from using our Services. We do not intentionally collect or maintain information from persons under the age of 18. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian’s consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 18, we will make reasonable efforts to delete such information from our records.

9. INTERNATIONAL

Please be aware that Exadel and some of the third-party service providers with whom we may share your information are located in the United States and other countries. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers. Some of these countries may not have data protection laws as comprehensive or protective as those in your country of residence. For example, Personal Information may be subject to access requests from governments, courts, or law enforcement agencies in those jurisdictions according to the laws in those jurisdictions. Personal Information may also be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. To the extent required by applicable law, we ensure that international transfers of your information are subject to appropriate protections, and we ensure such transfers are legal by using valid legal methods such as standard data protection clauses approved by the European Commission or the United Kingdom, or if we have your express consent to the transfer.

10. FOR OUR EU/UK USERS 

Lawful Basis 

• Legitimate Interests. We collect your contact and account information, communications information, location and education and employment information for our legitimate business purposes, as described in Section 2    
• Consent. We collect use cookies and collect device and online activity information from you when we have your consent to do so. We rely on consent whenever we ask for your consent to use your Personal Information.
• Compliance with a Contractual Obligation. We use your order and purchase information, as well as your contact and payment information to comply with our contractual obligations to you when you have signed an agreement to use our Services.

Privacy Rights 

If you are an EU or UK resident, you have the following right with respect to the Personal Information with have about you. 

• Access. With some exceptions designed to protect the rights of others, you have the right to a copy of the Personal Information  that we hold about you. 
• Correction. You have the right to request that we correct any Personal Information we have about you that is incorrect. 
• Deletion. You have the right to request that we delete your Personal Information. This right is not generally available where we still have a valid legal reason to keep the data (for example, because we are obliged to do so by law).
• Objection. You have the right to object to our processing of your Personal Information  where we rely on “legitimate interests” as our legal basis for processing, but we may be able to continue processing if our interest outweighs your objection.
• Withdrawing consent. If we are processing your Personal Information on the basis of your consent, you have the right to withdraw that consent at any time, in which case we will stop that processing unless we have another legal basis on which to continue.

11. EXADEL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This Privacy Notice for California Residents supplements the information contained in Exadel Privacy Policy. Any terms defined in the CCPA have the same meaning when used in this Privacy Policy.

Categories of Personal Information Collected and Disclosed

The following chart details which categories of Personal Information about California residents we collect, as well as which categories of Personal Information we have disclosed within the last twelve (12) months:

We collect this information from you and from third parties as described above in Section 2. 

We collect this information for our business purposes a described in above in Section 3. 

What share this information with the service providers and contractors described above in Section 4. 

We also share your personal information for targeted advertising purposes with online advertising technology providers that help us market and advertise you.

Personal Information of Children Under Age 16

We do not collect, sell or share Personal Information of users we know to be less than 16 years of age.

Retention of Your Personal Information.

For each of these categories of Personal Information, We retain your Personal Information only for as long as we need it to fulfill the purposes for which it was collected and to comply with our legal obligations. We will generally store Personal Information associated with your account until it is no longer necessary to provide services to you, until you ask us to delete it, or until your account is deleted, whichever comes first; but there are some exceptions to this general rule. We will retain information from deleted accounts to comply with the law, prevent fraud, resolve disputes, troubleshoot problems, assist with investigations, enforce our agreements, and take other actions permitted by law. For more information, contact us at [email protected]. 

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know. You have the right to ask us to disclose the Personal Information we have collected, shared, or sold about you in the past 12 months. If we are able to verify your identity, we will provide the categories of Personal Information we have collected about you, the categories of sources from which we collect it, our business or commercial purpose for collecting the Personal Information, and the specific pieces of Personal Information we collected. If we have disclosed your Personal Information to any third party for any reason, we will also tell you the categories of Personal Information we disclosed, the categories of third parties with whom we shared it, and the purpose for which we shared it.  You also have the right to request that we provide you the specific pieces of Personal Information that we collected and retained about you.  

Right to Opt Out of Sale or Sharing of Your Personal Information and/or /Cross Contextual Advertising.  You have the right to tell us “Do Not Sell or Share My Personal Information” or to the right to direct us not to sell or share Personal Information we have collected about you to third parties, including without limitation for cross-contextual advertising. 

Right to Deletion. You have the right to request that we delete any Personal Information we have collected about you. We will only do this if we can confirm your identity, and in some cases, we are required or permitted by law to retain all or some of your information for specific purposes.

Right to Correct.  You have right to request that we correct your inaccurate Personal Information maintained by us.  

Authorized Agent.  You have the right to appoint an authorized agent to exercise these rights for you.  We have the right to verify that the authorized agent acts on your behalf. 

We will not discriminate against you, for example by receiving a different quality of services, if you exercise any of these rights.

Response Timing and Format

You can make any of these requests by contacting us at [email protected]. We endeavor to respond to a verifiable consumer request within forty-five (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. We will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 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.

Browser-Based Opt-Outs 

Some browsers offer you the ability to opt out of cookie-based “sales” and sharing of personal information for targeted or other cross-contextual behavioral advertising.  The Global Privacy Control (https://globalprivacycontrol.org/) is currently the most recognized signal.  

The Services are not currently configured to recognize “do not track” or other browser-based signals. However, other settings within your browser may permit you to block Cookies or other technology that enable websites to collect information that can be used to tailor advertisements to your interest. Please check your browser’s settings or consult your browser’s help information for more details. To learn more about browser tracking signals and Do Not Track please visit www.allaboutdnt.org.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. We do not share Personal Information with third parties for their direct marketing purposes.

12. THIRD PARTY SITES AND PLATFORMS

Our platform may contain links to other third-party sites, platform, services, plugins, and applications (collectively “Third-Party Site(s)”)  When you click that link you will be taken to a Third-Party Site, and we do not control that Third-Party Site, and any Personal Information your provide to that Third-Party Site is not governed by this Privacy Policy. We are not responsible for the privacy practices of such Third-Party Sites.  We suggest that you read that privacy policies of these Third-Party Sites carefully.

13. MODIFICATIONS TO THE PRIVACY POLICY

This Privacy Policy may change from time to time, and minor changes will take effect when posted. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates. If we make any material or key changes to the Privacy Policy, we will notify you as required by law. 

14. HOW TO CONTACT US

If you have any questions or suggestions regarding our Privacy Policy, or would like to do any of the following:

• see your personal information that you have already sent us so that you can correct, update or delete it from our files;
• if your child under the age of majority has used the site or our Services and sent us Personal Information, or delete that Personal Information from our files;
• ask that we not send you electronic communications or otherwise contact you; or
• report any violation of this Privacy Policy,

 please contact us by sending us an e-mail to [email protected].

Before submitting your request, please read the Procedure for the exercise of rights by personal data subjects.