Privacy Policy

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Welcome to Colleva. We at Colleva, Inc. (the “Company”) know you care about how your personal information is used and shared and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. By using or accessing Colleva, our website or our other services (“Services”) in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

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You may print a copy of this Privacy Policy by clicking Here

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What does this Privacy Policy cover?

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This Privacy Policy covers our treatment of personally identifiable information (“Personal Information”) that we gather when you are accessing or using our Services, but not the practices of companies we don’t own or control, or people that we don’t manage. We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to provide and improve our Services, to contact you and potentially allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. You may choose not to provide us with Personal Information, but in that case you may not be able to experience all or many of the benefits of our Services.

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We do not knowingly collect or solicit Personal Information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us Personal Information, please contact us at support@colleva.com.

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Will the Company ever change this Privacy Policy?

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We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will do our best to alert you to changes by placing a notice on our website, by sending you an email, and/or by some other means. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected.

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Where does the Company collect Personal Information from?

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We collect and store information about you from you when you provide it directly to us and when our Services automatically collect information about you (for example, through the use of Cookies on our website or when you download and install certain applications or software we make available). We also will collect information through other sources, including publicly available data, data available through social media, data licensed from third-party sources, and data acquired by us through other means.

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Tracking Tools, Advertising and Opt-Out

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The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

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Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

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We use the following types of Cookies:

Essential Cookies: Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain feature sand services unavailable.
Functional Cookies: Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Performance/Analytical Cookies: Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and disclose information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
Retargeting/Advertising Cookies: Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as(depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

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To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings by changing your settings at the bottom left of our website. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.

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Session Replay Technology

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We may use session replay technology in order to identify and resolve customer issues, to monitor and analyze how you use our Services, to better understand user behavior, and to improve our Services. By continuing to use the Services, you consent to the use of session replay technology. If you would like to change your settings with respect to session replay technology, you can access your Cookie management settings by changing your settings at the bottom left of our website.

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What Personal Information does the Company collect?

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Wereceive and store any information you knowingly provide to us. Forexample, if you submit content or a query through our Services, we will collectPersonal Information to the extent included in such content or query. We alsomay receive Personal Information through the use of Cookies, as described inth “Tracking Tools, Advertising and Opt-Out” section above

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The chart below details the categories of Personal Information that we collect or have collected over the past 12 months.

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Category of Personal Information (and Examples)	Business or Commercial Purpose(s) for Collection	Categories of Third Parties With Whom We Disclose this Personal Information
Profile or Contact Data such as first and last name, email, username, phone number and mailing address.	Providing, Customizing and Improving the Services Marketing the Services Corresponding with You	Service Providers Business Partners Parties You Authorize, Access or Authenticate
Commercial Data such as purchase history, consumer profiles and records of personal information.	Providing, Customizing and Improving the Services Marketing the Services Corresponding with You	Service Providers Advertising Partners Business Partners Parties You Authorize, Access or Authenticate
Device/IP Data such as IP address, device ID, domain server and type of device/operating system/browser used to access the Services.	Providing, Customizing and Improving the Services Marketing the Services Corresponding with You	Service Providers Advertising Partners Business Partners Parties You Authorize, Access or Authenticate
Web Analytics such as web page interactions, referring webpage/source through which you accessed the Services, non-identifiable request IDs, statistics associated with the interaction between device or browser and the Services and browsing or search history.	Providing, Customizing and Improving the Services Marketing the Services Corresponding with You	Service Providers Advertising Partners Business Partners Parties You Authorize, Access or Authenticate
Professional or Employment-Related Data such as job title, job history, performance evaluations and your professional goals and ambitions.	Providing, Customizing and Improving the Services Marketing the Services Corresponding with You	Service Providers Business Partners Parties You Authorize, Access or Authenticate
Sensory Data such as photos, videos, or recordings of you and/or of your environment.	Providing, Customizing and Improving the Services Marketing the Services Corresponding with You	Service Providers Business Partners Parties You Authorize, Access or Authenticate
Inferences Drawn From Other Personal Information Collected such as attributes, user behavior, and predispositions.	Providing, Customizing and Improving the Services Marketing the Services Corresponding with You	Service Providers Business Partners Parties You Authorize, Access or Authenticate
Other Identifying Information that You Voluntarily Choose to Provide such as emails, letters, and texts you send us or information you provide while using our Services.	Providing, Customizing and Improving the Services Marketing the Services Corresponding with You	Service Providers Business Partners Parties You Authorize, Access or Authenticate

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How does the Company use Personal Information it collects?

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We use your information to operate, improve, understand, and personalize the Services, and for the following purposes:

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To meet or fulfill the reason you provided the information to us.
To communicate with you about the Services, including Service announcements, updates or offers.
To provide support and assistance for the Services.
To analyze your performance as requested by you.
To create and manage your account or other user profiles, if applicable.
To personalize website content and communications based on your preferences.
To process orders or other transactions.
To respond to user inquiries and fulfill user requests.
To improve and develop the Services, including testing, research, analysis and product development (including training our artificial intelligence, machine learning and language models).
To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of our Services.
To comply with our legal or contractual obligations and resolve disputes.
To serve advertisements and otherwise for advertising and/or marketing purposes, alone or in conjunction with third-party analytics or advertising partners.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
For any other business purpose stated when collecting your Personal Information or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (the “CCPA”), the Colorado Privacy Act (the “CPA”), the Connecticut Data Privacy Act (the “CTDPA”), the Montana Consumer Data Privacy Act (“MCDPA”), the Oregon Consumer Privacy Act (“OCPA”), the Texas Data Privacy and Security Act (“TDPSA”), the Utah Consumer Privacy Act (the “UCPA”), or the Virginia Consumer Data Protection Act (the “VCDPA”) (together with any other applicable US state privacy laws, the “State Privacy Laws”).

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As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our services. If you do not want to receive communications from us, please indicate your preference by emailing us at privacy@colleva.com. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated or incompatible purposes without providing you notice or obtaining your consent.

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Will the Company share any of my Personal Information?

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We will share your Personal Information as we determine appropriate or beneficial in connection with our legitimate business interests. In addition, we may choose to buy or sell assets, and may share and/or transfer account, contact, and other Personal Information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.

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In some circumstances, we employ other companies and service providers to perform tasks on our behalf and need to share your information with them to provide products or services to you; in such cases, we share Personal Information for the following business purposes:

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Auditing related to a current interaction and concurrent transactions.
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Debugging to identify and repair errors that impair existing intended functionality.
Short-term, transient use of Personal Information that is not used by another party to build a consumer profile or otherwise alter your consumer experience outside the current interaction.
Performing services on our behalf, including maintaining or servicing accounts, providing customer service, providing cloud computing services, advertising or marketing services, providing analytic services, or providing similar services.
Undertaking internal research for technological development and demonstration.
Serving advertisements or analyzing user behavior for marketing, advertising or user analytics purposes.
Undertaking activities to verify or maintain the quality or safety of a service or device that we own, manufacture, was manufactured for us, or control.

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We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply this Privacy Policy and other agreements; or protect the rights, property, or safety of the Company, our employees, our users, or others.

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We may de-identify your Personal Information so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience.

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How long is Personal Information about me Retained?

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We retain your Personal Information for as long as is necessary to provide you with the Services or exercise our rights, including our right to use your Personal Information to develop and improve our Services.

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Is Personal Information about me secure?

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We endeavor to protect the privacy of your Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Although we use physical, technical and administrative controls to protect your Personal Information, none of those measures is completely secure.

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What Personal Information can I access?

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If you have any questions about the information we have on file about you (including any request to delete, correct, or update that information), please contact us at privacy@colleva.com. We do not guarantee that you will be able to view or retrieve any Personal Information or other data you have submitted to us, nor can we commit to being able to delete any such data. Your data may be encrypted through the Services. In such case, we will have limited ability to identify or take any action with respect to such encrypted data. Notwithstanding the foregoing, we do not guarantee that encrypted data is safe or guaranteed against unauthorized access, use or disclosure.

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What choices do I have?

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You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

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You may be able to add, update, or delete information when using the Services. When you update information, however, we may maintain a copy of the unrevised information in our records. Some information may remain in our records even if you request deletion of such information from your account. We may use aggregated data derived from or incorporating your Personal Information after you update or delete it, including in ways that may potentially identify you personally. You also may have choices provided to you under the State Privacy Laws, detailed in the “What are my rights under State Privacy Laws?” section below.

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What are my rights under State Privacy Laws?

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This section details the rights provided to you as residents of certain states under the State Privacy Laws. Please see the “How do I Exercise my rights under State Privacy Laws?” section below for information on how to exercise any of the rights described in this section.

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We will not discriminate against you for exercising your rights under the State Privacy Laws. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the State Privacy Laws. However, we may offer different tiers of our Services as allowed by applicable data privacy laws with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Information that we receive from you.

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If there are any conflicts between this section and any other provision of this Privacy Policy and you are a resident of California, Colorado, Connecticut, Montana, Nevada, Oregon, Texas, Utah or any other state with privacy laws applicable to this Privacy Policy, the portion that is more protective of Personal Information shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@colleva.com. We will not process your Personal Information in violation of state and federal laws that prohibit unlawful discrimination against consumers.

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Please note that we may process Personal Information of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Information as a service provider, you should contact the entity that collected your Personal Information in the first instance to address your rights with respect to such data. Please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request. Additionally, we cannot guarantee that you will be able to view or retrieve any Personal Information or other data you have submitted to us, nor can we commit to being able to delete any such data. Your data may be encrypted through the Services. In such case, we will have limited ability to identify or take any action with respect to such encrypted data.

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California Resident Rights

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If you are a California resident, you have the rights set forth in this section.

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Access

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You have the right to request certain information about our collection and use of your Personal Data. In response, we will provide you with the following information in the past 12 months:

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The categories of Personal Information that we have collected about you.
The categories of sources from which that Personal Information was collected.
The business or commercial purpose for collecting or selling your Personal Information.
The categories of third parties with whom we have shared your Personal Information.
The specific pieces of Personal Information that we have collected about you.

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If we have disclosed your Personal Information to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Information shared with each category of third party recipient. If we have sold your Personal Information over the past 12 months, we will identify the categories of Personal Information sold to each category of third party recipient.

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You may request the above information beyond the 12-month period, but no earlier than January1, 2022. If you do make such a request, we are required to provide that information unless doing so proves impossible or would involve disproportionate effort.

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Deletion

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You have the right to request that we delete the Personal Information that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Information to provide you with the Services or complete a transaction or other action you have requested, or if deletion of your Personal Information involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

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Correction

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You have the right to request that we correct any inaccurate Personal Information we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide ,based on the totality of circumstances related to your Personal Information, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.

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Personal Information Sales and Shares Opt-Out

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In this section, we use the term ‘sell’ and ‘share’ as it is defined in the CCPA. We sell and/or share your Personal Information, subject to your right to opt-out as described in this section. For clarity, when we use the term ‘sell,’ we mean for valuable consideration and not for any monetary value. We do not sell or share your Personal Information in any other way than through the use of Cookies.

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As described in the “Where does the Company collect Personal Information from?” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CCPA, disclosing your data through third party Cookies for online advertising may be considered “selling” or “sharing” of information. You can opt out by following the instructions in this section.

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We sell or share your Personal Information to the following categories of third parties:

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Ad Networks
Marketing providers

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Over the past 12 months, we have sold or shared the following categories of your Personal Information to categories of third parties listed above. Please see the “What Personal Information does the Company collect and disclose?” section for more detail:

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Commercial Data
Device/IP Data
Web Analytics
Consumer Demographic Data

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We have sold or shared the foregoing categories of Personal Information for the following business or commercial purposes:

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Improving the Services, including testing, research, internal analytics and product development.
Personalizing the Services, website content and communications based on your preferences.
Doing fraud protection, security and debugging.
Marketing and selling the Services.
Showing you advertisements, including interest-based or online behavioral advertising.

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You have the right to opt-out of the sale or share of your Personal Information by following the instructions in the “How do I Exercise my rights under State Privacy Laws?” section. Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Information for at least 12 months.

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To our knowledge, we do not sell or share the Personal Information of minors under 16 years of age.

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Limit the Use of Sensitive Personal Information

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The Right to Limit allows California residents to direct a business that collects Sensitive Personal Information to limit its use of this information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services, to perform the services set forth in paragraphs (2), (4), (5), and (8) of subdivision (e)of Section 1798.140, and as authorized in the CCPA regulations.]

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Consumers have the right to request that we limit the use or sharing disclosure of their Sensitive Personal Information (“Right to Limit”). However, since our use and disclosure of Sensitive Information are limited to the purposes set forth in section 7027(m) of the CCPA regulations, including: 1) performing the services or providing the goods reasonably expected, 2) preventing, detecting, and investigating security incidents, 3) resisting malicious, deceptive, fraudulent, or illegal actions, 4) ensuring physical safety of natural persons, 5) for short-term transient use, 6) performing services on behalf of the business, 7) verifying or maintaining quality or safety of a product or service, and 8) collecting or processing Sensitive Personal Information but not for the purpose of inferring characteristics, we do not offer a way for you to submit such a request.

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Other California Resident Rights

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Under California Civil Code Sections1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Information to third parties for such third parties’ direct marketing purposes. In order to submit such a request, please contact us at privacy@colleva.com.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

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Colorado Resident Rights

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If you are a Colorado resident, you have the rights set forth under the Colorado Privacy Act(“CPA”).

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Access

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You have the right to request confirmation of whether or not we are processing your Personal Information and to access and request a copy of your Personal Information in a machine-readable format, to the extent technically feasible, twice within a calendar year.

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Correction

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You have the right to correct inaccuracies in your Personal Information, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Information.

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Deletion

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You have the right to delete Personal Information concerning you.

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Personal Information Sales and Targeted Advertising Opt-Out

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In this section, we use the term ‘sell’ as it is defined in the CPA. For clarity, when we use the term ‘sell,’ we mean for valuable consideration and not for any monetary value. We do not sell or share your Personal Information in any other way than through the use of Cookies. We sell and process for the purposes of targeted advertising your Personal Information, subject to your right to opt-out of these sales.

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As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CPA, disclosing your data through third party Cookies for online advertising may be considered a “sale” of information. You can opt out of these sales by following the instructions in this section.

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We sell and process for the purposes of targeted advertising your Personal Information to the following categories of third parties:

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Ad Networks
Marketing providers

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We sell and process for the purposes of targeted advertising the following categories of your Personal Information to categories of third parties listed above. Please see the “What Personal Information does the Company collect and disclose?” section for more detail:

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Device/IP Data
Web Analytics

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We have sold the foregoing categories of Personal Information for the following business or commercial purposes:

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Marketing and selling the Services.
Showing you advertisements, including interest-based or online behavioral advertising.

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You have the right to opt-out of the sale or processing for the purposes of targeted advertising of Personal Information by following the instructions in the “How do I Exercise my rights under State Privacy Laws?” section below.

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We do not sell or process for the purposes of targeted advertising the Personal Information of minors under 13 years of age.

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Profiling Opt-Out

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In this section, we use the term‘ Profiling’ as it is defined in the CPA and ‘Decision’ means any ‘Decisions that produce legal or similarly significant effects concerning a Consumer,’ as defined in the CPA, that concern you.

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Consent or “Opt-in” Required and How to Withdraw

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We may seek your consent to collect or process certain Personal Information, including: 1) Sensitive Data, 2) Personal Information from a known child under 13 years of age, 3) to sell, or process Personal Information for Targeted Advertising or Profiling after you exercise your right to opt-out, or 4) Personal Information for Secondary Use.

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However, we currently do not collect or process Personal Information as described above.

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We will not process your Personal Information in violation of state and federal laws that prohibit unlawful discrimination against consumers.

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Connecticut Resident Rights

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If you are a Connecticut resident, you have the rights set forth under the Connecticut Data Privacy Act (“CTDPA”).

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Access

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You have the right to request confirmation of whether or not we are processing your Personal Information and to access your Personal Information.

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Correction

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Deletion

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You have the right to delete Personal Information you have provided to us or we have obtained about you.

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Portability

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You have the right to request a copy of your Personal Information that is processed automatically in a machine-readable format, to the extent technically feasible.

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Personal Information Sales and Targeted Advertising Opt-Out

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In this section, we use the term ‘sell’ as it is defined in the CTDPA. For clarity, when we use the term ‘sell,’ we mean for valuable consideration and not for any monetary value. We do not sell or share your Personal Information in any other way than through the use of Cookies. We sell and process for the purposes of targeted advertising your Personal Information, subject to your right to opt-out of these sales.

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As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CTDPA, disclosing your data through third party Cookies for online advertising may be considered a “sale” of information. You can opt out from these “sales” by following the instructions in the “How do I Exercise my rights under State Privacy Laws?” section.

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We do not sell or process for the purposes of targeted advertising the Personal Information of minors under 13 years of age.

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Profiling Opt-Out

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In this section, we use the term‘ Profiling’ as it is defined in the CTDPA and ‘Decision’ means any decisions that produce legal or similarly significant effects that concerns you.

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You have the right to opt-out of solely automated Profiling for Decisions using the instructions in the “How do I Exercise my rights under State Privacy Laws?” section.

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Consent or “Opt-in” Required and How to Withdraw

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We may seek your consent to collect or process certain Personal Information, including: 1) Sensitive Data, 2) Sensitive Data from a known child under 13 years of age, or 3) to sell, or process Personal Information for Targeted Advertising, if you are at least 13 years old but younger than 16 years old.

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However, we currently do not collect or process Personal Information as described above.

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Montana Resident Rights

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If you are a Montana resident, you have the rights set forth under the Montana Consumer Data Privacy Act (“MCDPA”).

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Access

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You have the right to request confirmation of whether or not we are processing your Personal Information and to access your Personal Information.

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Correction

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Portability

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You have the right to request a copy of your Personal Information in a machine-readable format, to the extent technically feasible.

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Deletion

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You have the right to delete Personal Information you have provided to us or we have obtained about you.

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Personal Information Sales and Targeted Advertising Opt-Out

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In this section, we use the term ‘sell’ as it is defined in the MCDPA. For clarity, when we use the term‘ sell,’ we mean for valuable consideration and not for any monetary value. We do not sell or share your Personal Information in any other way than through the use of Cookies. We sell and process for the purposes of targeted advertising your Personal Information, subject to your right to opt-out of these sales.

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As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the MCDPA, disclosing your data through third party Cookies for online advertising may be considered a “sale” of information. You have the right to opt-out of the sale or processing for the purposes of targeted advertising of Personal Information by following the instructions in the “How do I Exercise my rights under State Privacy Laws?” section.

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We do not sell or process for the purposes of targeted advertising the Personal Information of minors under 13 years of age.

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Profiling Opt-Out

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We do not process your Personal Information for ‘Profiling’ to make ‘Decisions’ under the MCDPA. ‘Profiling’ means any form of automated processing performed on Personal Information to evaluate, analyze or predict personal aspects related to an identified or identifiable individual's economic circumstances, health, personal preferences, interests, reliability, behavior, location or movements.‘ Decision’ means any ‘Decisions that produce legal or similarly significant effects concerning a Consumer,’ as defined in the MCDPA that concern you.

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Consent or “Opt-in” Required and How to Withdraw

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However, we currently do not collect or process Personal Information as described above.

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Oregon Resident Rights

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If you are an Oregon resident, you have the rights set forth under the Oregon Consumer Privacy Act (“OCPA”).

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Access

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You have the right to request confirmation of whether or not we are processing your Personal Information and to access and request a copy of your Personal Information, including a list of specific third parties, other than natural persons, to which we have disclosed your Personal Information or any Personal Information, in a machine-readable format, to the extent technically feasible, twice within a calendar year.

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Correction

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Portability

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You have the right to request a copy of your Personal Information in a machine-readable format, to the extent technically feasible.

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Deletion

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You have the right to delete Personal Information you have provided to us or we have obtained about you.

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Personal Information Sales and Targeted Advertising Opt-Out

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In this section, we use the term ‘sell’ as it is defined in the OCPA. For clarity, when we use the term‘ sell,’ we mean for valuable consideration and not for any monetary value. We do not sell or share your Personal Information in any other way than through the use of Cookies. We sell and process for the purposes of targeted advertising your Personal Information, subject to your right to opt-out of these sales.

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As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the OCPA, disclosing your data through third party Cookies for online advertising may be considered a “sale” of information. You have the right to opt-out of the sale or processing for the purposes of targeted advertising of Personal Information by following the instructions in the “How do I Exercise my rights under State Privacy Laws?” section.

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We do not sell or process for the purposes of targeted advertising the Personal Information of minors under 13 years of age.

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Profiling Opt-Out

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We do not process your Personal Information for ‘Profiling’ to make ‘Decisions’ under the OCPA. ‘Profiling’ means any form of automated processing performed on Personal Information to evaluate, analyze or predict personal aspects related to an identified or identifiable individual's economic circumstances, health, personal preferences, interests, reliability, behavior, location or movements.‘ Decision’ means any ‘Decisions that produce legal or similarly significant effects concerning a Consumer,’ as defined in the OCPA that concern you.

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Consent or “Opt-in” Required and How to Withdraw

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However, we currently do not collect or process Personal Information as described above.

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Texas Resident Rights

If you are a Texas resident, you have the rights set forth under the Texas Data Privacy and Security Act (“TDPSA”).

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Access

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You have the right to request confirmation of whether or not we are processing your Personal Information and to access your Personal Information.

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Correction

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Portability

You have the right to request a copy of your Personal Information in a machine-readable format, to the extent technically feasible.

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Deletion

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You have the right to delete Personal Information you have provided to us or we have obtained about you.

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Personal Information Sales and Targeted Advertising Opt-Out

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In this section, we use the term ‘sell’ as it is defined in the TDPSA. We sell and process your Personal Information for the purposes of targeted advertising, subject to your right to opt-out of these sales. For clarity, when we use the term ‘sell,’ we mean for valuable consideration and not for any monetary value. We do not sell or share your Personal Information in any other way than through the use of Cookies.

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As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the TDPSA, disclosing your data through third party Cookies for online advertising may be considered a “sale” of information. You can opt out from these “sales” by following the instructions in the “How do I Exercise my rights under State Privacy Laws?” section.

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We do not sell or process for the purposes of targeted advertising the Personal Information of minors under 13 years of age.

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Profiling Opt-Out

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We do not process your Personal Information for ‘Profiling’ as defined under the TDPSA.‘ Profiling’ means any form of solely automated processing performed on Personal Information to evaluate, analyze, or predict personal aspects related to an identified or identifiable individual ’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

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Consent or “Opt-in” Required and How to Withdraw

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We may seek your consent to collect or process certain Personal Information, including: 1) Sensitive Data, or 2) Sensitive Data from a known child under 13 years of age.

However, we currently do not collect or process Personal Information as described above.

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Utah Resident Rights

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If you are a Utah resident, you have the rights set forth under the Utah Consumer Privacy Act(“UCPA”).

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Access

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You have the right to request confirmation of whether or not we are processing your Personal Information and to access your Personal Information.

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Portability

You have the right to request a copy of your Personal Information in a machine-readable format, to the extent technically feasible.

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Deletion

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You have the right to delete Personal Information that you have provided to us.

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Opt-Out of Certain Processing Activities

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Targeted Advertising: You have the right to opt-out of the processing of your Personal Information for targeted advertising purposes. We process your Personal Information for targeted advertising purposes. You can opt out this processing of your Personal Information by following the instructions under the “How do I Exercise my rights under State Privacy Laws?” section.
Sale of Personal Information: We do not currently sell your Personal Information as defined under the UCPA.
Processing of Sensitive Personal Information: We do not process Sensitive Personal Information.

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Virginia Resident Rights

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If you are a Virginia resident, you have the rights set forth under the Virginia Consumer Data Protection Act (“VCDPA”).

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Access

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You have the right to request confirmation of whether or not we are processing your Personal Information and to access your Personal Information.

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Correction

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Portability

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You have the right to request a copy of your Personal Information in a machine-readable format, to the extent technically feasible.

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Deletion

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You have the right to delete Personal Information you have provided to us or we have obtained about you.

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Consent or “Opt-in” Required and How to Withdraw

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We may seek your consent to collect or process certain Personal Information, including: 1) Sensitive Data, or 2) Sensitive Data from a known child under 13 years of age.

However, we currently do not collect or process Personal Information as described above.

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Opt-Out of Certain Processing Activities

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Targeted Advertising: You have the right to opt-out of the processing of your Personal Information for targeted advertising purposes. We process your Personal Information for targeted advertising purposes.
Sale of Personal Information: We do not currently sell your Personal Information as defined under the VDCPA.
Processing for Profiling Purposes: We do not currently process your Personal Information for the purposes of profiling.

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How do I Exercise my rights under State Privacy Laws?

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To exercise the rights described in this Privacy Policy, you or, if you are a California, Colorado, Connecticut, Montana, Oregon or Texas resident, your Authorized Agent(defined below) must send us a request that (1)provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Information (which, for users of our Services, will be your login credentials and subsequent verification), and (2)describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Information provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

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We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

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Request to Opt-Out of Share and/or Targeted Advertising

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You may opt-out from any “shares” or targeted advertising, by using the following methods:

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Email us at privacy@colleva.com
By accessing your cookie consent mechanism by at the bottom left of our website.

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Request to Access, Delete, or Correct

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You may submit a Valid Request for any other rights afforded to you in this Privacy Policy by using the following methods:

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Email us at: privacy@colleva.com
By accessing your cookie consent mechanism at the bottom of our website.

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If you are a California, Colorado, Connecticut, Montana, Oregon or Texas resident, you may also authorize an agent(an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

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Appealing a Denial

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If you are a Colorado, Connecticut, Montana, Oregon, Texas or Virginia resident and we refuse to take action on your request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the State Privacy Laws (as applicable). We will respond to your appeal within the time period required under the applicable law. You can submit a Verified Request to appeal by the following methods:

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Email us at: privacy@colleva.com (title must include “[STATE OF RESIDENCE]Appeal”)

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If we deny your appeal, you have the right to contact the Attorney General of your State, including by the following links: Colorado, Connecticut, Montana, Oregon, Texas and Virginia.

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What are my rights as a European Union and United Kingdom Data Subject?

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If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation(the “GDPR”) with respect to your Personal Information, as outlined below.

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For this section, we use the terms “processing” as it is defined in the GDPR, but “Personal Information” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.

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If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Information shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@colleva.com.Note that we may also process Personal Information of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Information. If we are the processor of your Personal Information (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

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Personal Information We Collect

The “What Personal Information does the Company collect and disclose?” section above details the Personal Information that we collect from you.

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Personal Information Use and Processing Grounds

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The “Our Commercial or Business Purposes for Collecting Personal Information” section above explains how we use your Personal Information.

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We will only process your Personal Information if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

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Contractual Necessity: We process the following categories of Personal Information as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Information will result in your inability to use some or all portions of the Services that require such data.
- List all categories of Personal Information processed for contractual necessity
Legitimate Interest: We process the following categories of Personal Information when we believe it furthers the legitimate interest of us or third parties:
- List all categories of Personal Information processed for legitimate interest
  - We may also de-identify or anonymize Personal Information to further our legitimate interests.
- Examples of these legitimate interests include (as described in more detail above):
  - Providing, customizing and improving the Services.
  - Marketing the Services.
  - Corresponding with you.
  - Meeting legal requirements and enforcing legal terms.
  - Completing corporate transactions.
Consent: In some cases, we process Personal Information based on the consent you expressly grant to us at the time we collect such data. When we process Personal Information based on your consent, it will be expressly indicated to you at the point and time of collection.
Other Processing Grounds: From time to time we may also need to process Personal Information to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

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Disclosing Personal Information

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The “What Personal Information does the Company collect and disclose?” section above detail show we disclose your Personal Information with third parties.

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EU, UK and Swiss Data Subject Rights

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You have certain rights with respect to your Personal Information, including those set forth below. For more information about these rights, or to submit a request, please email us at privacy@colleva.com.Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Information, if necessary to verify your identity and the nature of your request.

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Access: You can request more information about the Personal Information we hold about you and request a copy of such Personal Information. You can also access certain of your Personal Information by logging on to your account.
Rectification: If you believe that any Personal Information we are holding about you is in corrector incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging on to your account.
Erasure: You can request that we erase some or all of your Personal Information from our systems.
Withdrawal of Consent: If we are processing your Personal Information based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Information, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
Portability: You can ask for a copy of your Personal Information in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Information for certain purposes, such as for direct marketing purposes.
Restriction of Processing: You can ask us to restrict further processing of your Personal Information.
Right to File Complaint: You have the right to lodge a complaint about Colleva's practices with respect to your Personal Information with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

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Transfers of Personal Information

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The Services are hosted and operated in the United States (“U.S.”) through Colleva and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Information about you, regardless of whether provided by you or obtained from a third party, is being provided to Colleva in the U.S. and will be hosted on U.S. servers, and you authorize Colleva to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Information may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses.

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What if I have questions about this Privacy Policy?

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If you have any questions or concerns regarding our privacy policies, please send us a detailed message to privacy@colleva.com, and we will try to resolve your concerns.

If you are located in the EU or UK, you may use the following information to contact our EU-Based Member Representative:

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EU Member Representative:
- Osano International Compliance Services Limited
- 3 Dublin Landings
- North Wall Quay
- Dublin 1
UK Representative
- Osano UK Compliance LTD
- 42-46 Fountain Street
- Belfast
- Antrim
- BT1 - 5EF