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 [email protected].

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:

  1. 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.

  2. 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:

    1. 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.
    2. 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.
    3. 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.

  3. 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 [email protected].

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.

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:

  1. 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.

  2. 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.

  3. Law Enforcement. We reserve the right to disclose your Personal Data to law enforcement or other government agencies as permitted or required by law.

  4. 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.

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 [email protected].

  1. Emails. We may send you informational or support emails related to your use of the Website. 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 [email protected].

  2. 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.

  3. Device Settings. You can control the data collected via cookies and related technologies by adjusting your device settings.

  4. 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.

  5. 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 [email protected].

6. DATA SECURITY

We have implemented and maintain 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. All data on our systems is encrypted and stored in a secure cloud environment.

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.

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.

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.

  1. 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.

  • Right to know. We provide the required information for a consumer's right to know in this Privacy Notice.

  • 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.

  • Right to accuracy, and the right to correct your Personal Data. You can correct or update your Personal Data held by us by contacting [email protected].

  • 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.

  • 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.

  • No sale of Personal Data. We do not sell Personal Data collected through the Website.

  • No sharing Personal Data. We do not share Personal Data through the Website for cross-contextual behavioral advertising purposes.

  • 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.

  • Right to non-discrimination. We will not deny you goods or services or treat you differently because you exercised your statutory rights.

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 by submitting a request to [email protected].

  1. 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.

  • Right to know why your Personal Data is collected, used, and distributed. This Privacy Notice explains our privacy practices for the right to know.

  • Right to accuracy of your Personal Data. We take steps to reasonably ensure that your Personal Data we are using is accurate.

  • Right to access your Personal Data. Upon written request and identity authentication, we will provide you with your Personal Data under our control within 30 days.

Consumers in Canada may exercise the above rights by submitting a verifiable request to [email protected].

  1. 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"). If you are a Data Subject, you have the following rights in relation to Personal Data we hold about you:

  • Right to access your Personal Data. You can request to access your Personal Data at any time.

  • Right to restrict processing of your Personal Data. You can request that we restrict the processing of your Personal Data in certain circumstances.

  • Right to rectify your Personal Data. If your Personal Data is incorrect, 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 in a structured, commonly used machine-readable format.

  • Right to erasure. Upon your request, and in certain circumstances, we are required to delete your Personal Data.

  • Right to not be subject to automated decision-making. We do not use automated decision-making or profiling as part of the Website.

Data Subjects may exercise these rights by submitting a request to [email protected]. If you are a Data Subject and believe we are unlawfully processing your Personal Data, you also have the right to complain to your local data protection supervisory authority.

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. We are committed to transferring Personal Data via an adequacy decision, standard contractual clauses, or other lawful data transfer mechanisms.

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. Your continued use of the Website after we make changes is deemed to be your acceptance of those changes.