Website Privacy Notice
Last Updated June 24, 2024
This Privacy Notice explains how we collect and use information when you visit cndt.io or our social media or other online channels (altogether, our "Website") offered by Ember Network, Inc. operating under the name Conduit Network ("Conduit Network," "us" or "we"). You consent to this Privacy Notice and our privacy practices by using our Website. If you do not agree with this Privacy Notice, do not access or use the Website.
If you have any questions about our privacy practices, please contact us at hello@cndt.io.
1. WHAT IS PERSONAL DATA?
As used in this Privacy Notice, "Personal Data" means 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 or household. Personal Data falls within certain categories, for example:
Identifiers (e.g., name, email, telephone number, address, username);
Commercial information (e.g., products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies);
Educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);
Employment information (e.g., current or past employment);
Sensitive information (e.g., government identification number; precise geolocation; racial or ethnic origin; religious beliefs; health information; contents of messages when we are not the recipient; in some cases, information about a known child);
Legally protected information (e.g., race, citizenship, marital status, sex);
Biometrics (e.g., DNA, face/voice prints, health data) and audio, electronic, visual, thermal, or olfactory information;
Internet activity (e.g., browsing history; content interactions); and
Inferences drawn from Personal Data to create a profile about preferences, characteristics, trends, predispositions, behaviors, attitudes, intelligence, and aptitudes.
The above list is for definition purposes. We do not collect all of these categories or types of Personal Data.
Please note that not all information about a person qualifies as Personal Data under privacy laws. For example, publicly available information, aggregated data, and anonymized information are often exempt from legal rights and protections.
2. COLLECTION AND USE OF PERSONAL DATA
We collect and process Personal Data with your consent as informed by this Privacy Notice and freely given by you, if we have a legitimate interest, or as authorized or required by law. We will only collect, use, retain, and disclose Personal Data as is adequate and relevant to the specific, express purposes described in this Privacy Notice, or as reasonably necessary and proportionate to provide the Website.
In the preceding 12 months, we have collected identifiers, commercial history, and internet activity through the Website. We collect this information from sources and for purposes described below:
When You Contact Us. If you contact us through the Website, social media, email or otherwise, we will collect identifiers like your name and email address, along with any other Personal Data that you choose to include in your communication to us. We collect this information with your consent and we use it to respond to your inquiries and to send you information about our company and the products and services we offer.
Your Activity on the Website. Like most commercial websites, our Website uses cookies and related technologies to understand how visitors use the Website. We use cookies to collect technical data about your device like your IP address, log information, generalized geolocation when visiting the Website, error messages, and unique device identifiers. We use the following cookies on the Website:
HubSpot hosting and tracking cookies, some of which are essential to the Website's functionality. You can read more about these cookies on the HubSpot website.
Google Analytics to understand how visitors interact with the Website. For more information on how Google Analytics collects and processes data, please visit How Google uses data when you use our partners.
Shopify essential and functional cookies to enable the Website's ecommerce features. Learn more by reading the Shopify Cookie Notice.
We collect this information for our legitimate interest of providing the Website and understanding how visitors interact with the Website. To control how cookies interact with your device, you can adjust your browser settings or install a third-party plugin to block cookies or alert you when a cookie is set. Additionally, you can opt-out of Google Analytics by visiting the Google Analytics opt-out page or by adjusting your device settings.
- Children's Privacy. The Website is designed for adults, not children. If we learn that we have collected or received Personal Data from anyone under the age of 16, we will delete that information. If you believe we may have received Personal Data from someone under the age of 16, please notify us at hello@cndt.io.
In addition to the specific uses described above, we may process Personal Data for other purposes that we disclose to you or as compatible with the context of how we collected your Personal Data. We also reserve the right to use your Personal Data to (i) protect your privacy and the privacy of others; (ii) comply with a law, regulation, legal process, or order; (iii) monitor your compliance with this Privacy Notice and your agreements with us; (iv) protect our legal rights or those of others; or (v) for any other purpose with your consent. We will not collect additional categories of Personal Data or use your Personal Data for purposes that are incompatible with the purpose stated at the time of collection without first notifying you by updating this Privacy Notice or through other means.
3. PERSONAL DATA DISCLOSURES
To provide our Website, we must sometimes disclose certain Personal Data to trusted third parties as described in this section. In the preceding 12 months, we have disclosed the Personal Data we collected as described below:
Service Providers. We work with service providers like web hosting services, cloud services, analytics services, and email and communications providers that may require access to certain Personal Data to perform their contractual obligations to us. Our service providers are contractually required to protect your Personal Data, and we require all service providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Data. The type of information that we disclose to a service provider will depend on the service that they provide.
Other Third Parties. We may disclose your Personal Data to other third parties in certain circumstances as permitted by applicable law, for example: (i) if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); (ii) to comply with a legal requirement or a court order; (iii) when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; (iv) to exercise or defend our legal claims; or (v) for any other reason with your consent.
Law Enforcement. We reserve the right to disclose your Personal Data to law enforcement or other government agencies as permitted or required by law.
Aggregated and Deidentified Information. We reserve the right to disclose aggregated, anonymized, or deidentified information about any individuals with nonaffiliated entities for marketing, advertising, research, or other purposes, without restriction.
4. PERSONAL DATA RETENTION
We retain data as long as it is necessary and relevant to our operations. For example, Personal Data collected when you contact us on the Website or by email is retained as long as necessary to respond to your inquiry or provide you with the products or services you have requested. Data collected from cookies and related technologies may be retained for up to 26 months. When data is no longer needed, we securely delete or deidentify it. We reserve the right to retain Personal Data for longer periods if necessary to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our terms and conditions, or take other actions as permitted by law.
5. YOUR OPTIONS
You can control your Personal Data on our systems and how we use it as detailed below. If you need assistance, please contact hello@cndt.io.
Emails. We may send you informational or support emails related to your use of the Website. Depending on your stated communication preferences, we may also send you marketing emails. If you do not wish to receive emails from us, you can unsubscribe or change your preferences via the links provided in the emails or send a request to hello@cndt.io. Note that if you opt out of marketing communications, we may still send you non-promotional communications related to your use of the Website.
Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser "do-not-track" requests.
Device Settings. You can control the data collected via cookies and related technologies by adjusting your device settings.
Block Location Tracking. You can reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an app by uninstalling the Website or withdrawing your consent through your device settings.
Privacy Requests. Some consumers are legally entitled to certain privacy rights. See the Notice of Privacy Rights in Section 8. If you have privacy rights under consumer privacy laws, you can exercise those rights by sending a request to hello@cndt.io. We will fulfill your request as required by applicable law. We can only legally fulfill a privacy request when we have sufficient information to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Data, and to properly understand, evaluate, and respond to the request. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so, such as requests that are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
6. DATA SECURITY
We have implemented and maintains reasonable and appropriate technical, administrative, and physical security practices and procedures to help protect Personal Data on our systems from unauthorized or illegal access, destruction, use, modification, or disclosure. Our security measures are appropriate to the volume, scope, and nature of the Personal Data processed and designed to meet our duty of care with respect to your Personal Data. All data on our systems is encrypted and stored in a secure cloud environment. Our team members who handle Personal Data are informed of applicable privacy law requirements.
Please note, however, that no transmission of data over the Internet or mobile platforms is 100% secure, and we cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Data for improper purposes. Please sign off your device after each session on our Website and keep your credentials private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized activity.
7. PRIVACY PRACTICES OF THIRD PARTIES
This Privacy Notice applies only to information collected by us through your use of our Website. The Website may include or provide links to third-party content or services, but we have no ability to control, and we are not responsible for, the privacy and data collection, use, and disclosure practices of third parties. We are not responsible for the privacy practices of any third party, and your access to and use of third-party websites is governed by the privacy notices of those websites.
8. YOUR PRIVACY RIGHTS
This section provides notices related to consumer privacy laws. Depending on where you reside, you may be entitled to additional controls over your Personal Data. Some of these laws may not apply to you, or we may be exempt from certain legal obligations, in which case the information in this section is offered as a courtesy.
- United States Privacy Rights. In the United States, consumer privacy is governed by federal privacy laws covering specific industries or data uses and state privacy laws providing general consumer privacy rights. U.S. states including California, Colorado, Connecticut, Iowa, Nevada, Oregon, Tennessee, Texas, Utah, Virginia, and a growing list of additional states require companies to inform consumers about their privacy rights and provide a method to exercise those rights. Below please find notices of privacy rights for residents of certain U.S. states.
Right to know. We provide the required information for a consumer's right to know in this Privacy Notice. We may provide you with additional notices about other ways we process your Personal Data, such as by sending you a notice via email or posting information on the Website.
Right to reasonable expectations. You can expect us to collect, use, or disclose your Personal Data responsibly and not for any other purpose other than as stated at the time of collection or described in this Privacy Notice. If we collect or use your Personal Data based on your consent, we will also notify you of any changes and will request your further consent as required by law. You may withdraw your consent at any time with reasonable notice by contacting hello@cndt.io.
Right to accuracy, and the right to correct your Personal Data. You can correct or update your Personal Data held by us by logging into your account and making the changes there or by contacting hello@cndt.io. We will update our records to reflect your accurate information.
Right to access your Personal Data. Upon your request and when required by law, we will provide you with a copy of your Personal Data on our systems, along with details about the types of Personal Data we process, why we process it, and any third parties we work with to collect Personal Data on our behalf. Certain laws may limit the scope or frequency of requests we must fulfill.
Right to deletion. Upon your request and when required by law, we will delete Personal Data collected about you via the Website from our systems. This right is not absolute, and we may be entitled to retain and process your Personal Data despite your request. If you make this request, we balance certain legal, contractual, and business interests against your right to request the deletion of your Personal Data.
Limited use and disclosure of sensitive Personal Data. We do not seek to collect sensitive Personal Data via the Website. In no case will we use or disclose sensitive Personal Data for the purpose of inferring characteristics about a consumer.
Right to data portability. In some cases, we are required to provide your Personal Data to another organization at your request and in a structured, commonly used machine-readable format, so that the other organization can read and use it.
No sale of Personal Data. Some jurisdictions entitle consumers to opt out of the sale of their Personal Data. We do not sell Personal Data collected through the Website.
No sharing Personal Data. Some jurisdictions entitle consumers to opt out of their data being shared with third parties for cross-contextual behavioral advertising purposes. We do not share Personal Data through the Website in this manner.
No automated decision-making or profiling. We do not use automated decision-making or any form of automated processing of Personal Data on the Website to evaluate, analyze, or predict your performance, preferences, choices, or behavior.
Right to restrict or opt-out of processing. You may have the right to request that we restrict the processing of your Personal Data if (i) the data is inaccurate, (ii) the processing is unlawful, (iii) we no longer need the Personal Data, or (iv) you change your consent or exercise your right to opt-out or object. Your right to restrict may be limited to Personal Data that is sensitive in nature, or that is sold or shared for certain purposes.
Right to disclosure of certain information. You may have a right to request information about how we collect and use your Personal Data, such as (i) the categories of Personal Data we have collected about you; (ii) the categories of sources for the Personal Data we have collected about you; (iii) our business purpose for collecting, using, disclosing, or selling that Personal Data, as applicable; and (iv) the categories of third parties with whom we disclose that Personal Data. We do not sell or share your Personal Data, but if we did you could request two separate lists stating: (a) sales, identifying the Personal Data categories that each category of recipient purchased; and (b) sharing for a business purpose, identifying the Personal Data categories that each category of recipient obtained. Certain laws may limit the number or frequency of requests we must fulfill.
Right to non-discrimination. We will not (i) deny you goods or services, (ii) charge you different prices or rates for goods or services, (iii) provide you a different level or quality of goods or services, (iv) retaliate against you as an employee, applicant for employment, or independent contractor; or (v) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised your statutory right unless permitted by law.
Right to disclosure of marketing information. If you are a resident of the State of California, California's Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California consumers to request certain disclosures regarding Personal Data sharing with affiliates and/or third parties for marketing purposes.
Health Data Rights. We do not collect any health data through the Website. Some laws entitle consumers to certain details about health data collected about them, including (i) confirmation of whether the entity collects, shares, or sells the consumer's health data and access that data, including a list of all third parties and affiliates with whom the entity has shared or sold the health data and a method to contact those third parties, (ii) a method to withdraw consent related to use of health data, and (iii) the right to have their health data be deleted.
PLEASE NOTE: Certain U.S. privacy laws may not apply to us or our Website, in which case these notices are offered as a courtesy. U.S. consumers may exercise these rights over their Personal Data by submitting a request to hello@cndt.io, subject to any exceptions and limitations that may apply.
- Canadian Privacy Rights. For those in Canada, the Personal Data Protection and Electronic Documents Act and other provincial privacy laws give Canadians specific rights regarding their Personal Data. The rights afforded under Canadian privacy laws are described below.
Right to know why your Personal Data is collected, used, and distributed. This Privacy Notice explains our privacy practices for the right to know. We may provide additional notices about other ways we process Personal Data through the Website or via email.
Right to expect us to collect, use or disclose Personal Data responsibly and not for any other purpose other than which you consented. We set your expectations in this Privacy Notice and collect express or implied consent at various stages of collection or processing for our own processing. You may withdraw your consent from us at any time with reasonable notice by contacting hello@cndt.io.
Right to accuracy of your Personal Data. We take steps to reasonably ensure that your Personal Data we are using is accurate. In most cases, we rely on you to ensure that your information is current, complete and accurate. We provide methods for you to correct, update, and delete inaccurate Personal Data in your account, and we will provide you with reasonable assistance to ensure that your Personal Data is accurate in our systems and with our service providers.
Right to access your Personal Data. Upon written request and identity authentication, we will provide you with your Personal Data under our control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We will make the information available within 30 days or provide written notice where additional time is required to fulfil the request. If limited by law or potential infringement on another's privacy rights, we may not be able to provide access to some or all the Personal Data you request. If we must refuse an access request, we will notify you in writing, document the reasons for refusal and outline further steps that are available to you.
Consumers in Canada may exercise the above rights over their Personal Data by submitting a verifiable request to hello@cndt.io, subject to our receipt of a verifiable request, as well as any exceptions and limitations that may apply. We endeavor to respond to requests within 30 days of receipt unless we have a valid reason for delay, in which case we may take an additional 30 days to respond.
- EEA and UK Privacy Rights. We adopted this section to comply with the European Economic Area's General Data Protection Regulations and its United Kingdom counterpart law ("GDPR"). This section applies solely to residents of the European Union and the United Kingdom ("Data Subjects"). We operate the Website as a data controller. If you are a Data Subject, you have the following rights in relation to Personal Data we hold about you:
Right to know how we process your Personal Data. We have set the required notices in this Privacy Notice. We may provide you with additional notices about other ways we process your Personal Data, such as by sending you a notice via email or by other means of communication.
Right to access your Personal Data. You can request to access your Personal Data. Upon request, we will provide you with a copy of your Personal Data, along with details about the types of Personal Data we process, why we process it, and any third parties we work with to collect Personal Data on our behalf. We may have one or more legally valid reasons to refuse your request in whole or in part, for example to protect the rights of other individuals.
Right to restrict processing of your Personal Data. You can request that we restrict the processing of your Personal Data if (i) the data is inaccurate, (ii) the processing is unlawful, (iii) we no longer need the Personal Data, or (iv) you exercise your right to object.
Right to rectify your Personal Data. If you become aware that the Personal Data that we hold about you is incorrect, or if your situation changes (e.g., change of address), please inform us and we will update our records.
Right to data portability. In some cases, we are required to provide your Personal Data to another organization at your request and in a structured, commonly used machine-readable format, so that the other organization can read and use it.
Right to erasure (a.k.a. the "right to be forgotten"). Upon your request, and in certain circumstances and where we are required to do so by law, we are required to delete your Personal Data. This right is not absolute, and we may be entitled to retain and process your Personal Data despite your request. If you make this request, we balance certain legal, contractual, and business interests against your right to request the deletion of your Personal Data.
Right to object to certain processing of your Personal Data. Upon your request, and in certain circumstances and where we are required to do so by law, we will limit our processing of your Personal Data as you request.
Right to not be subject to automated decision-making. We do not use automated decision-making or profiling as part of the Website. If this changes in the future, we will update this Privacy Notice and provide you with an option to exercise your privacy rights related to such processing.
Data Subjects may exercise these rights over their Personal Data by submitting a request to hello@cndt.io, subject to any exceptions and limitations that may apply. We endeavor to respond to requests from Data Subjects within 30 days of receipt. If you are an Data Subject and you believe we are unlawfully processing your Personal Data, you also have the right to complain to your local data protection supervisory authority. If you are a resident in Switzerland, you have the right to complain to the Swiss data protection authorities. If we cannot comply with part or all of your requests, we will explain the reasons in our response.
9. CROSS-BORDER DATA TRANSFERS
Conduit Network is owned and operated in the United States. If you access the Website from outside the United States, the Personal Data we collect about you may be transferred outside of your country of origin to our servers in the United States or other countries. Some countries' laws are more restrictive than in the United States, or result in governments, courts, law enforcement, or regulatory agencies having access to or obtaining disclosure of your Personal Data pursuant to the laws of the applicable foreign jurisdiction. We are committed to transferring Personal Data via an adequacy decision, standard contractual clauses, or other lawful data transfer mechanisms. By allowing us to collect Personal Data about you, you consent to the transfer and processing of your Personal Data as described in this paragraph. Please also note that our Website may not be available to everyone in every country.
10. CHANGES TO THIS PRIVACY NOTICE
If we make material changes to our privacy practices, we will post the revised Privacy Notice on this page. You are responsible for periodically visiting this Privacy Notice to be aware of our current privacy practices. Your continued use of the Website after we make changes is deemed to be your acceptance of those changes.