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Privacy Policy

Sibros Technologies, Inc. Privacy Policy 

Updated and Effective as of: May 13, 2020
 

This Privacy Policy explains how Sibros Technologies, Inc. (“Sibros, we, us, our”) collects, uses, and shares information and the options available to you. If you have any questions, you may contact us. See the “Contacting Us” section below. We may change this Privacy Policy from time to time. Please consult this Privacy Policy regularly for updates. See “Modifications to this Privacy Policy” below for more information. You acknowledge that you accept the practices described in this Privacy Policy by visiting Sibros and/or using our Services.

User Consent: You consent to the practices described in this Privacy Policy by visiting Sibros and/or using our web site or our Services and you represent that you are at least 18 years old.

California Users: If you are a resident of the State of California, see the California Privacy Notice for additional information about your rights and our disclosures. The California Privacy Notice is in addition to this privacy policy.

California Employees, Job Applicants, Owners, Directors, Officers, and Contractors: If you are a resident of California and you are an employee, job applicant, controlling owner, director, officer, independent contractor, or medical staff of ours, see the Privacy Notice for California Company Workforce.

WHAT DOES THIS PRIVACY POLICY COVER? This Privacy Policy covers the information that we may collect or receive through all digital formats from users who: visit www.sibros.tech and other websites owned and operated by us (including our client and user interfaces) or use our social media pages such as Facebook, LinkedIn and Twitter, and receive email messages from us (collectively, the “Sibros Pages” or the “Services”).This Privacy Policy does not cover, and we are not responsible for, the privacy, data or other practices of any third parties (except as required by applicable law), such as our business customers and any service providers. See “Third Parties” below for more information.Choice and Opting Out: see “Choices” below for information about your choices regarding opting out of email marketing communications, opting out of Sibros’ cookies, opting out of interest-based advertising by third parties from cookies, and opting out of the use of precise location. For information on deactivating your Sibros account, please see “Access and Rights regarding Personal Information.Access and Rights: see “Access and Rights regarding Personal Information” below for information about how to review, correct, update, suppress, or delete the personal information that Sibros maintains about you and to exercise other data subject rights.International Transfers: see “International Information Transfers” below for information on the transfer of your personal data.

COLLECTION OF INFORMATION We and our third-party service providers may collect personal information from you from the Services, including the following:

• Name
• Email address
• Phone number
• Physical address

For example, we collect your personal information when you request information about Sibros or our products and Services. Please see “Access and Rights regarding Personal Information” to see more information about your rights regarding your personal information.

We and our third party service providers may also collect other information that is linked or reasonably linked to a particular computer or device. This information includes the following: Time spent on the Services and your activities on the Services, including pages visited, requested URL and referring URL, date and time on the Services, information about interactions with our emails, and other anonymous traffic-related data; Transaction-related data such as: date, time and location a transaction took place (e.g., when and where a class was attended), description and/or classification of the transaction, unique identification numbers, including IP address and your location derived from IP address, demographic information (e.g., date of birth, gender) as provided by you; Information provided by you; Information to enable and authorize your logging in to the Services; Browser information, including browser type and language; Device information, including screen dimensions, device brand and model, and mobile device identifier, and aggregated information.

We and our third party service providers may collect this information in a variety of ways, including through: your browser or device; your mobile device identifier; your use of our Services; your IP address; the aggregation of information; and the use of cookies and other similar technologies (see “Cookies and Similar Technologies” below).

USE OF INFORMATION We and our third-party service providers may use personal information (including, without limitation, name, phone number, email address, social media IDs and posts) collected from the Services: To respond to your inquiries and fulfill your requests and process users’ accounts; To send administrative information to you; To send you communications that we believe may be of interest to you, including any communications for marketing purposes related to the Services for our business purposes, such as tracking conversion of prospective customers into actual customers, data analysis, fraud monitoring and prevention and security, developing new products, enhancing, improving or modifying our Services, identifying usage trends, and determining the effectiveness of our Services, and; As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations and the security of our Services; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

We and our third party service providers may use other information from the Services that is linked or reasonably linked to a particular computer or device:to operate, improve, analyze and manage the Services, to ensure the Services function properly, to track your use of the Services to improve the design and functionality of the Services, to diagnose server problems and administer the Services via your IP Address (a number automatically assigned to the computer or device that you are using by your internet service provider), and as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations and the security of our Services; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.We may partner with certain third parties to collect other information to engage in analysis, research, and reporting of Service usage patterns. These third parties may also deliver advertising to you on other websites and applications, based on your activity on our website and other websites over time. These third parties may set and access cookies on your computer or other devices and may also use web logs or web beacons. See “Cookies and Similar Technologies” and see “Choices” to opt out of interest-based advertising by third parties from cookies.We may combine information from the Services that is linked or reasonably linked to a particular computer or device with personal information. If we combine such information with personal information, the combined information will be treated by us as personal information as long as it is combined.

INFORMATION SHARING Your personal information (including, without limitation, name, phone number, email address, social media IDs and posts) collected from the Services may be shared:among our affiliates for the purposes described in this Privacy Policy (Sibros is the party responsible for the management of the information jointly used by it and its affiliates),with our services providers to use our Services and to analyze the effectiveness and performance of our Services, with our third-party service providers who provide services such as email management, transaction management, campaign measurement, hosting and storage, web serving, performance tracking and reporting, technical services, marketing analytics and other services, directly by you in your account and other services to which you are able to post information and materials yourself (including, without limitation, our and your social media pages),with a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), and as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations and the security of our Services; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.We and our third party service providers may share other information from the Services that is linked or reasonably linked to a particular computer or device:among our affiliates for the purposes described in this Privacy Policy (Sibros is the party responsible for the management of the information jointly used by it and its affiliates),with our services providers to use our Services and to analyze the effectiveness and performance of our Services, with our third-party service providers who provide services such as email management, transaction management, campaign measurement, hosting and storage, web serving, performance tracking and reporting, technical services, marketing analytics and other services, with a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), and as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations and the security of our Services; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.We may also share and disclose other information that we collect, including aggregate information such as total number of Sibros users, as we consider necessary to develop, grow, and provide our Services.We ask our service providers to confirm that their privacy and security practices are consistent with ours, we provide our service providers with only the information necessary for them to perform the services we request, and we ask our service providers not to use such information for any purpose other than as specified by Sibros.Our third party service providers who provide usage analytics for our Services may also use your information to provide you with more personalized advertising content on other websites and applications. To opt out of interest-based advertising by third parties, see “Choices.”Sibros may offer online resources that facilitate communications among the Sibros community and others. Whenever you voluntarily post information to any public forum offered by Sibros, such information along with your username can be accessed by other users of the forum, including members of the public if the forum is open to the public.

COOKIES AND SIMILAR TECHNOLOGIES We and our service providers use cookies in connection with our Services. A cookie is a small data file that is stored on your computer’s or mobile device’s memory. Some cookies help you navigate our Services, including setting a cookie to remember your login details. Our cookies are linked to your login information so that you can use the Services on your device throughout the day without logging in each time you visit the Services. Cookies also help us better understand the effectiveness of our Services (for example, by tracking the way in which you respond to, select and interact with our Services and tracking the conversion of our prospective customers into actual customers). Other cookies collect information about how you use our Services, which highlights areas we can improve, including navigation. If you submit an inquiry through our Service and provide your name and email and similar information, that personal information will not be tied back to you for interest-based advertising purposes across websites and applications, however, you may receive email marketing communications from us, and you may receive interest-based advertising from third parties based on cookies dropped on your device by our third party service providers. To opt out of marketing communications and interest-based advertising by third parties, see “Choices.”

We and our service providers may also use “pixel tags,” “web beacons”, “clear GIFs” or similar means (individually or collectively “Pixel Tags”) to analyze usage patterns of consumers. A Pixel Tag is an electronic image, often a single pixel, which is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a web page or in a mobile application and may be associated with cookies on your hard drive. Some Pixel Tags are used to drop cookies on users’ devices. Pixel Tags allow us to count users who have visited certain websites and applications of our business customers, and pages within such websites and applications, and to help determine the effectiveness of marketing campaigns.

Third parties may use cookies or similar technologies on visitors of our Services to serve interest-based advertisements to such visitors when they visit other websites and mobile applications. The collection of information through cookies or similar technologies by such third parties will be governed by such third parties’ own privacy policies and principles, which Sibros does not control.

For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu. To read about your choices with regard to Sibros’ and third parties’ uses of cookies in our Services, please see “Choices.”

We do not track users when they cross to third-party websites, and we do not provide targeted advertising to them, and therefore we do not respond to Do Not Track (DNT) signals.

LEGAL BASIS RELIED ON FOR PROCESSING PERSONAL INFORMATION OF EUROPEAN ECONOMIC AREA INDIVIDUALS Sibros is a data processor with respect to personal data collected or received by us when we receive such information from: our business customers (the data controllers) that make their data available for use via our Services, or you after you have signed up for our Service via our business customers. Where we operate as a data processor, we are processing the data on behalf of our business customers (the data controller(s) of the data) based on their instructions, and it is the responsibility of the data controller to establish an appropriate legal basis for the processing of the data. For example, we may process data when the individual has consented to such processing. On certain occasions we may rely on another lawful basis as a basis for processing, such as when it is in our business customers’ and our legitimate interests to do so and when these interests are not overridden by the individual’s data protection rights. Those legitimate interests include performing our obligations with respect to providing the Services and improving our Services.Sibros is a data controller with respect to any personal data collected or received by us when we receive personal information (such as name, phone number, and email address) through our Sibros Pages without being connected to any business customer. In this case, the data controller is Sibros. Where Sibros operates as a data controller, we rely on legitimate interests to process personal data to provide our Services. On certain occasions, we may also rely on the consent of the individual to process personal information (for example, in some jurisdictions, when the user inputs personal information into the Sibros Pages and consents to receive marketing communications). On other occasions, we may process personal information when we need to do this to fulfill a contract or where we are required to do so by law.

RETENTION We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law, or an individual requests deletion in accordance with applicable law. See “Access and Rights regarding Personal Information.”

CHOICES 
Opting Out of Marketing 
We give you choices regarding our use and disclosure of your personal information for marketing purposes.You may opt-out from receiving electronic communications from us. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing related emails by contacting us at privacy@sibros.tech or by clicking on the opt-out link within the email message that you receive from us.Please also note that if you do opt-out of receiving marketing-related emails from us, we may still be required to send you administrative messages relating to the Services from time to time.

Opting Out of Sibros’ Cookies 
You may disable cookies, including Sibros’ cookies, by modifying the settings in your browser. However, please note that if you delete or disable cookies, you will not be able to stay logged in to the Services and, as a result, the Services will no longer be available to you. Our cookie is required to provide some of our Services. Our cookies are linked to your login information so that you can use the Services on your device throughout the day without logging in each time you visit the Services.

Opting Out of Interest-Based Advertising by Third Parties from Cookies 
Some third parties who use cookies when you visit our websites, have opt out mechanisms either directly from their website or through an industry-developed web page. If you go to optout.aboutads.info or www.aboutads.info/choices, you can learn how to exercise choice regarding the collection of information about your online activities over time and across multiple third-party websites, online services, devices, and applications for interest-based advertising purposes. When you opt out of receiving interest-based advertising from third parties, note that the opt out only applies to the applicable browser in which you set it. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu. Third parties may also combine and use information from websites or applications on your current browser or device with information from your other browsers or devices for advertising purposes. To opt out of such practices, please follow the instructions above for opting out on each of your browsers, and also opt out on each of your mobile devices. Please note that you will need to opt out separately on (1) each of your browsers and (2) each of your mobile devices to ensure that information collected on a particular browser or device is not used on another browser or device.

Opting Out of Use of Precise Location 
To disable the collection of precise location information from your mobile device through mobile applications, you can access your mobile device settings and choose to limit that collection.

Android: For Android 6.0 and above: you can modify privacy settings in Settings > Applications > App Permissions > Location and tap the on/off toggle switch next to Location for each app which has permission to use your location data. For earlier versions of Android: you can modify privacy settings in Settings > More > Permission and tap the on/off toggle switch next to Location to turn location functions off for your device. Alternatively, you may uninstall the relevant program(s).

iOS: In iOS you can modify privacy settings in Settings > Privacy. You can select location data from this list to see which apps have asked for permission to use your location data.

ACCESS AND RIGHTS REGARDING PERSONAL INFORMATION If you reside outside the European Economic Area and Switzerland, and you would like to review, correct, update, suppress, or delete the personal information that Sibros maintains about you, or you would like to request a copy of your personal information held by us, you may contact us at privacy@sibros.tech.

If you are a resident of the European Economic Area, including Switzerland, you have specific legal rights in regard to the handling of your information. You have the following rights with respect to your personal information:

• The right to be informed,
• The right of access,
• The right to rectification,
• The right to erasure,
• The right to restrict processing,
• The right to data portability,
• The right to object,
• The right to lodge a complaint with a supervisory authority, and
• Rights in relation to automated decision making and profiling.

To exercise these rights as a resident of the European Economic Area, including Switzerland, email privacy@sibros.tech.

You may deactivate your account by changing your preferences in the [user settings page] of the Services.

To opt out of receiving marketing communications from us, please see “Choices.”

To opt out of Sibros’ cookies, please see “Choices.”

To opt out of interest-based advertising by third parties from cookies, please see “Choices.”

To opt out of the use of precise location, please see “Choices.”

THIRD PARTIES This Privacy Policy does not cover, and we are not responsible for, the privacy, data or other practices of any third parties (except as required by applicable law), including any third parties operating any site or service to which our Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. These third parties are bound by their own privacy policies.Except as required by applicable law, we are also not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of our service providers, app developers, app providers, ad servers, social media platform providers, operating system providers, wireless service providers or device manufacturers, including any personal information you disclose to other organizations through or in connection with the Services.

SENSITIVE INFORMATION We ask that you not send us, and you not disclose to us, any sensitive information (e.g., social security numbers or other government identifiers, information related to racial or ethnic origin, political opinions, religion or other beliefs, medical or health conditions, criminal background, trade union membership, or sexual orientation) on or through the Services or otherwise to us, except where such information is legally required.

CHILDREN Our Services are not intended for, nor directed to, individuals under the age of 13, and we request that these individuals, and any other individual considered a minor under applicable law, not provide personal information through any of our Services. If you become aware that your child has provided us with personal information without your consent, please contact us at privacy@sibros.tech. If we become aware that a child under 13 (or under the legal age under applicable law) has provided us with personal information without parental consent, we take steps to remove such information and terminate the child’s account.

SECURITY Information that we collect is stored using procedures and practices reasonably designed to help protect from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal information transmitted, stored or otherwise processed by us.

INTERNATIONAL INFORMATION TRANSFERS Please be aware that the information we collect, may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location. Please be advised that we process and store information in any country where we have facilities and/or employees, including the United States, or in which we engage service providers. Your consent to this Privacy Policy or your use of any of the Services or your submission of your information to us or any of our business customers, represents your consent to such transfer, storage and processing outside of your country of residence, including the United States, which may have different data protection rules than those of your country of residence.

MODIFICATIONS TO THIS PRIVACY POLICY We reserve the right to make changes to our Privacy Policy. Please look at the date at the top of this page to see when this Privacy Policy was last revised. Where required by law, we will obtain your consent to make these changes.

CONTACTING US For any questions about this Privacy Policy or Sibros’ privacy practices, please contact us by email at privacy@sibros.tech, or by mail at:

Sibros Technologies, Inc.
Attn: Privacy
785 Orchard Drive
Suite 150
Folsom, CA 95630
USA

CALIFORNIA’S “SHINE THE LIGHT” LAW California’s “Shine the Light” law permits users of our properties that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at the contact information under Contacting Us.

California Privacy Notice Effective as of: January 1, 2020 This notice was last reviewed as of the effective date of the general privacy policy stated above.

If you are a California resident and we collect your personal information, this Privacy Notice for California Residents (“California Notice”) applies to you (“consumers” or ”you”), except as stated below. This California Notice is in addition to the information in our privacy policy above.

Where noted in this California Notice, the CCPA temporarily exempts certain personal information reflecting a written or verbal business-to-business communication or transaction (“B2B personal information”) from certain CCPA requirements. In addition, employees, job applicants, contractors, owners, directors and officers of Sibros who are California residents do not have the same rights as set forth in this California Notice. See “Collection of Information” below for additional information about excluded personal information.

All terms defined in the California Consumer Privacy Act of 2018 (CCPA) have the same meaning when used in this California Notice.

Collection of Information We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device or household (“personal information”).

 Categories of Sources: We obtain the above categories of personal information from the following categories of sources:Directly from you,Automatically collected information,Our business customers,Our service providers, andInformation when you log in with a third party’s single sign-in.

What is not personal information or not covered?

De-identified or aggregated consumer information is not personal information under CCPA.

Publicly available information from government records is not personal information under CCPA.

Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data are also not personal information under CCPA.

Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994 are also not personal information under CCPA.

Certain “excluded personal information” is temporarily excluded from the definition of personal information. The term ”excluded personal information” means personal information that we collect about a natural person who resides in California in the course of the person acting as any of the following (to the extent we collect and use the information solely within the context of that role):a job applicant of Sibros, an employee of Sibros, a controlling owner of Sibros, a director of the board or an officer of Sibros, a medical staff member of Sibros (if any), and a contractor of Sibros. Also, emergency contact information and information needed to administer benefits for the individuals covered above is not covered by this California Notice.

Use of Information We may use the personal information for one or more of the following purposes: Fulfilling your requests. Providing and improving the Service, including tracking rewards.Sending you communications. For our business purposes. As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations and the security of our Services; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity. As described to you when collecting your personal information or as otherwise permitted in the CCPA. 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.

Information Sharing Sales of Personal InformationIn the preceding twelve (12) months, we have not sold your personal information. “Sold” is defined under the CCPA.

Disclosures of Personal Information for a Business Purpose We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.We share your personal information with the following categories of third parties: Our affiliates; Our business customers; Our service providers; A buyer of our business; The public, voluntarily by you.

We may also share your information as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations and the security of our Services; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: Category A: Identifiers. Category B: California Customer Records personal information categories. Category C: Protected classification characteristics under California or federal law.Category D: Commercial information. Category F: Internet or other similar network activity. Category G: Geolocation data.Category K: Inferences drawn from other personal information.

Your Rights and Choices Under the CCPA, California residents have specific rights about their personal information. See below for information about these rights. The CCPA does not give these rights to consumers with B2B personal information.

Access to Specific Information and Data PortabilityYou have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Rights), we will disclose to you:The categories of personal information we collected about you.The categories of sources for the personal information we collected about you.Our business or commercial purpose for collecting that personal information.The categories of third parties with whom we share that personal information.The specific pieces of personal information we collected about you (which will allow you to exercise your data portability right).

Deletion Request You have the right to request that we delete any of your personal information that we collected from you and still retain, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.We may deny your deletion request if retaining the information is necessary for us or our service providers to: Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.Debug products to identify and repair errors that impair existing intended functionality.Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.Comply with a legal obligation.Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Rights To exercise your rights above, please submit a verifiable consumer request to us by either:Emailing us at privacy@sibros.tech and providing your full name and email address and the request that you are making (e.g., right to access, portability or deletion). Submitting a web form located [on our support portal] and providing your full name and email address and the request that you are making (e.g., right to access, portability or deletion).

The CCPA does not give these rights to consumers with B2B personal information.

Only you, or someone legally authorized to act for you, may make a verifiable consumer request about your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; Describe your request with sufficient detail that allows us to properly understand and respond to it; We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request; Making a verifiable consumer request does not require you to create an account with us. We may require you to make your request through your account if you have an account with us.

Format of Response and Timing We will try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period.If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically. Any disclosures we provide will only cover the 12-month period preceding the request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity.

Non-Discrimination We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:Provide you a different level or quality of goods or services.Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.Deny you goods or services.Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.We may offer certain financial incentives permitted by the CCPA that could result in different prices, rates, or quality levels. The incentive will reasonably relate to your personal information’s value to us and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Privacy Notice for California Company Workforce Effective as of January 1, 2020 

This Privacy Notice for California Company Workforce (“California Workforce Notice”) applies solely to employees, job applicants, controlling owners, directors, officers, independent contractors, and medical staff of Sibros (if any) who reside in California (“you” or ”Company Workforce”).We have adopted this California Workforce Notice to comply with the California Consumer Privacy Act of 2018 (CCPA) with respect to certain Company Workforce. Any terms defined in the CCPA have the same meaning when used in this California Workforce Notice.

Information We Collect from Company Workforce We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual in the Company Workforce in the course of the natural person acting in his/her capacity as an individual in the Company Workforce (“personal information”).

Use of Personal Information We may use the personal information of the Company Workforce for one or more of the following purposes: Employees, directors and officers: We may use your information for the following purposes: identifying you, verifying work authorization, administering taxes and health, medical and other benefit plans, keeping track of your records, contacting you, facilitating payment to bank accounts, contributing to 401(k) plans, garnishing wages required by law, evaluating performance, tracking efficiency and productivity, protecting against disclosure of confidential information and trade secrets, and ensuring compliance with applicable laws and company policies. Job applicants: We may use your information for the following purposes: identifying you, keeping track of records, contacting you, evaluating your candidacy, performing background and reference checks, and onboarding you. Independent contractors: We may use your information for the following purposes: identifying you, administering taxes, keeping track of your records, contacting you, facilitating payment to bank accounts, evaluating performance, tracking efficiency and productivity, protecting against disclosure of confidential information and trade secrets, and ensuring compliance with applicable laws and company policies. Legal and Other Uses: We may also use your information if we believe it is required or appropriate: (a) to prevent or stop activity that we may think is, or is at risk of being, illegal, unethical or legally actionable activity; (b) to protect our rights, privacy, safety or property, and that of you and others; (c) to protect our operations and the security of our Services; (d) under applicable law; (e) to comply with legal process and our legal obligations; (f) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (g) to enforce our terms and conditions; and (h) to allow us to pursue available remedies or limit potential damages.We may use your information as described to you when collecting your personal information or as otherwise set forth in the CCPA.

Sibros 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. 

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