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Cistera Privacy Policy (“Privacy Notice”) describes the privacy practices of Cistera Inc. and its subsidiaries and affiliates (collectively, “Cistera” or “us” or “we”).

Cistera provides technology services to other businesses – our clients. To take advantage of our services, our clients share with us information about their individual consumers, including contact details and shopping histories. We analyze that information and develop and send communications to the consumers only at the direction of the client who provided the information, and only on that client’s behalf. We may also collect personal data for our own business purposes in connection with our business, such as business contact details of potential customers or job applicants’ resumes.

The Cistera Privacy Policy applies to:

Our website and online services are designed for businesses and are not intended for personal, family or household use. Accordingly, we treat all personal information covered by this Privacy Policy. This includes information about any visitors to our website, as pertaining to individuals acting as business representatives, rather than in their personal capacity.

INFORMATION WE COLLECT

Information We Collect for Cistera’s Own Business Purposes

We may collect information about individuals who interact with Cistera when using our website or services (such as employees of our clients), job applicants, and other individuals.

How we collect the information

We may collect information:

Types of information we collect

The types of information we collect include:

Information We Collect from or on Behalf of Our Clients

We may collect information about individual consumers from our clients or – at clients’ request– from their service providers. Our clients determine the scope of the information transferred to us, and the information we receive may vary by client. Typically, we may collect clients’ consumers’ contact details and demographic data, shopping histories, and details about consumers’ interactions with marketing communications.

COOKIES AND OTHER INFORMATION COLLECTED BY AUTOMATED MEANS

We, our service providers, and our business partners, may collect certain information about the use of our websites by automated means, such as cookies, web beacons and other technologies.

OUR USE OF PERSONAL INFORMATION

Our Use of Personal Information for Cistera’s Own Business Purposes

Cistera may use personal information to:

We may aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. Cistera may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.

CAREERS

If you submit your information in connection with job opportunities at Cistera, we will use and disclose the information to process your application (including to contact you and/or your references and former employers if appropriate), to monitor recruitment statistics, and to comply with government reporting requirements. We also retain statistical information about applicants to help inform our recruitment activities. We will process this information based on our legitimate interest of evaluating job candidates or, when you provide us with sensitive information, based on your consent.

PRIVACY PREFERENCES, RIGHTS, AND CHOICES

Individuals have certain rights and choices regarding Cistera’s processing of their personal information. Please note, however, that if the exercise of these rights limits our ability to process personal information, we may be precluded from providing our products or services to individuals who exercise these rights, or from otherwise engaging with such individuals going forward.

Individuals whose personal information Cistera processes on behalf of a client should contact that client to exercise the rights and choices described in this section.

We reserve the right to verify the identity of the individual in connection with any requests regarding personal information to help ensure that we provide the information to individuals to whom the information pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information.

For information about the rights and choices users have with respect to cookies and online tracking, please see the “Cookies and Other Information Collected by Automated Means” section of this Privacy Notice.

General Objections to the Processing of Personal Information

To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your personal information. We will apply your preferences going forward. In some circumstances, withdrawing your consent to Cistera’s use or disclosure of your personal information will mean that Cistera will not be able to provide products or services to you or to otherwise engage with you.

Access to Personal Information

You may request access to correct, amend, or delete the personal information that we maintain about you. If we grant your request, we will provide you with a copy of the personal information we maintain about you in the ordinary course of business, in a commonly used format. You may request to correct any errors in your personal information. We may reject your request to access or correct your information, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection. If you wish to exercise this right please contact us here at privacy@Cistera.com

To limit the use and disclosure of your personal information, please submit a written request to privacy@Cistera.com.

Portability of Personal Information

You may request that we transfer your personal information to another data controller. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection.

Deletion of Personal Information

You may request that we delete your personal information. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection.

Marketing Emails

You may unsubscribe from receiving marketing or other commercial emails from Cistera by following the instructions included in the email. However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as information about changes to our website terms).

As further explained in the Privacy Shield Principles more fully described here, you may be entitled to invoke binding arbitration pertaining to certain residual complaints that have not been resolved by any other means.

HOW WE PROTECT INFORMATION

We maintain reasonable administrative, technical, and physical safeguards designed to protect the personal information we maintain against accidental, unlawful, or unauthorized access, disclosure, alteration, use, loss, or destruction. However, we cannot guarantee that the safeguards we maintain will ensure the security of the personal information.

LINKS TO OTHER WEBSITES AND THIRD-PARTY CONTENT

We may provide links to websites and other third-party content that is not owned or operated by Cistera. The websites and third-party content to which we link may have separate privacy notices or policies. Cistera is not responsible for the privacy practices of any entity that it does not own or control.

CHANGES TO OUR PRIVACY NOTICE

Cistera reserves the right to change this Privacy Notice at any time. When we update this Privacy Notice, we will notify you of changes that are deemed material under applicable legal requirements by updating the date of this Privacy Notice and providing other notification as required by applicable law. We may also notify you of changes to the Privacy Notice in other ways, such as via email or other contact information you have provided.

DATA RETENTION

We will retain personal information only for as long as necessary to fulfill the purpose(s) for which the information was collected, depending on the purpose(s) for which the information was collected, the nature of the information, any contractual relationship that may govern the retention of the data, and our legal or regulatory obligations. We will then destroy the personal information or anonymize the information, in accordance with applicable law.

HOW TO CONTACT US

You may contact us with questions, comments, or complaints about this Privacy Notice or our privacy practices, or if you wish to access, delete or correct you information, by emailing support@cistera.com

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