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Last Updated: May 1, 2019

  1. INTRODUCTION

    This Privacy Policy (this “Policy”) explains the collection, use, disclosure and protection of Personal Data (defined below) on the web site(s) (the “Site”) controlled by Candex Solutions, Inc. and its affiliates (collectively, “Candex”, “we”, “us” or “our”).  Please read this Policy carefully. We may from time to time update this Policy. Any changes will become effective when we post or link to the revised Policy on the Site.

    You do not have to provide us with any Personal Data to visit the Site. However, if you choose to withhold requested information, you may not be able to visit all sections of the Site and/or use all the features of the Site.

    This Policy shall also apply to any Candex App and other forms of online activity that reference this Policy. In such instances, the term “Site” shall include the mobile application (“App”) or other online activity whenever that term is used herein. In connection with your use of any App, your Personal Data (and Other Data, as described below) may also be collected and used by your mobile device manufacturer, the online store from which you obtained the App, your telecommunication provider, or other third parties involved in the delivery of the App or data to your mobile device, and such collection and use shall be subject to the Policy of the applicable third party. Candex is not responsible for any third party’s privacy practices.


  2. COLLECTION OF PERSONAL DATA

    Personal data is information that identifies you or can be used to identify or contact you, e.g., your name, email address, address, or phone number ("Personal Data"). The type of Personal Data we may collect from you depends on the nature of our relationship with you and applicable law.  We may need to collect and process Personal Data in order to provide requested information, deliver products or services to you, including without limitation, the Site, or because we are legally required to do so.
    1. Candex requests Personal Data from you during the registration process for the Site. This typically includes your name, business email address, company affiliation and job title. As part of the registration process, you will also be required to agree to the Site’s Terms of Service https://www.candex.com/Home/TermsOfUse.
    2. Candex may collect Personal Data voluntarily provided by you, including in emails to the Site, online forms, order and registration forms, surveys, phone calls and online chats with customer service and through other means.
    3. Please carefully safeguard your username and password for the Site and do not disclose it to any other person.
    4. Candex may occasionally collect information through various other means, including participation at conferences and events, individual introductions, from companies that use our products or services, and from selected third-party business partners. From time to time, we may also acquire from third parties’ certain lists containing the names and contact information of individuals who may be interested in our products and services.
    5. As you navigate the Site, certain passive information may also be collected, including Internet Protocol addresses, cookies, navigational data, the name of the domain and host from which you access the Internet, the browser software you use and your operating system, your browser settings, your mobile device type, the date and time you access our Services and other device identifiers.

  3. USE OF PERSONAL DATA COLLECTED 

    We use Personal Data for legitimate business purposes, including the following:
    1. Delivering Products and Services. We may use Personal Data to deliver products and services to you, and provide you with information about products and services that you have ordered or are using. These activities including collecting details of business activity so that we can process payments between buyers and sellers of goods and services and initiate related payments. We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
    2. Other Communications. From time to time, we may use Personal Data to inform you of products, programs, services and promotions that we believe may be of interest to you. If your Buyer is a Candex customer, we may also inform you of such products, programs, services and promotions using Personal Data about you that your Buyer provided to us. If you would prefer that we not send electronic marketing messages to you, please see the "Your Choices Regarding Marketing Communications" section below.
    3. Other Business Purposes. We may also use Personal Data for other business purposes, such as data analysis (for example, to improve the efficiency of our products or services), editorial and feedback purposes, providing customer support, customizing and improving the functionality, content and layout of the Site, completing business transactions including the processing of payments, development of marketing and promotion plans and materials, statistical analysis of user behavior (for example, to understand what parts of the Site are of most interest to users), product development, market research, administering individual accounts, and meeting government regulatory requirements such as sales tax collection, audits, etc. We may also use Personal Data of media contacts for press release distribution or sharing other newsworthy developments related to our business activities. We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
    4. Administrative Communications. We may use Personal Data to send you important information regarding the Site, products, services, your account status, changes to the Terms of Service, this Policy, or any other policies, agreements or transactions relevant to your use of the Site, products and/or services. Because this information may be important to your use of the Site, products and/or services, you may not opt-out of receiving such communications. We will engage in this activity to manage our contractual relationship with you and/or to comply with a legal obligation.

  4. COLLECTION AND USE OF OTHER DATA 

    We, and our service providers, may also collect and use the following types of data, referred to in this Policy as “Other Data”:
    1. Monitoring Data. Candex and its service providers may collect and/or track other information such as domain names, computer type, browser types, screen resolution, and other statistical data involving the use of the Site ("Monitoring Data"). We use Monitoring Data to help us understand who uses the Site, to improve the Site, and to market our services. Unless combined with Personal Data, Monitoring Data does not personally identify you or any other user, and we may use it for any purpose.
    2. Aggregated Data. We may aggregate Personal Data in a manner such that the end-product does not personally identify you or any other user of the Site, for example, by using information to calculate the percentage of our users who have a particular telephone area code. Such aggregate information may also be used for any purpose.
    3. Cookies. A cookie is a small text file that the Site saves on your computer or mobile device when you visit the Site. It enables the Site to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you do not have to keep re-entering them whenever you come back to the Site or browse from one page to another. Cookies may be either "persistent" cookies or "session" cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.  Cookies do not contain any Personal Data, but Personal Data may be linked, to the information stored in and obtained from cookies. The cookies used by Candex include those necessary for access and security, that track usage (performance cookies) and remember your login (functionality cookies).  You can control and/or delete cookies as you wish. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed.  If you do this, however, you may have to manually adjust some preferences every time you visit the Site and some services and functionalities may not work. The Site has a “Cookie Policy” that applies to its use of cookies and other similar tracking technologies. The Cookie Policy will apply in addition to this Policy.
      https://www.candex.com/signin/cookies
    4. Tools. We and our service providers may also use various common Internet tools such as 'pixel tags,' ‘action tags,’ ‘web beacons,’ ‘.gif tags,’ 'JavaScript' or similar technologies (together, "Tools") in connection with Site pages and email messages in certain formats to, among other things, track the actions of Site users and email recipients, to determine the success of marketing campaigns and to compile statistics about Site usage and response rates. Tools allow us to count users who have visited certain pages of the Site, to deliver services, and to help determine the effectiveness of promotional or advertising campaigns. When used in email messages in certain formats, Tools can tell the sender whether and when the email has been opened. We use cookies and Tools to understand how the Site is used and to customize and enhance the user experience. When you revisit the Site, Candex  may recognize you by a Tool and customize your experience. For example, once you have completed the registration process, a cookie and/or Tool will be used to avoid having you register again. We believe cookies and Tools add value to the user experience.
    5. Google Analytics. We use Google Analytics, which uses cookies and other similar technologies, to collect and analyze information about Site use and to report on activities and trends. The service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://policies.google.com/technologies/partner-sites, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
    6. Verification. We may use third-party services to verify that you are a human user. Any information collected as part of such verification is subject to the Policy of the third-party service provider.
    7. IP Addresses. When you visit and interact with the Site, we and our third-party service providers may collect Internet Protocol (IP) addresses. Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. We use IP addresses to understand how the Site is used by our users, to improve the Site and to enhance the user experience of the Site. We may also derive your approximate location from your IP address.

      If we are required to treat Other Data as Personal Data under applicable law, then we may use and disclose it for the purposes described above, as well as for the purposes for which we use and disclose Personal Data as detailed in this Policy.

  5. DISCLOSURE OF PERSONAL DATA COLLECTED

    We may disclose Personal Data for the following purposes:
    1. Third-Party Service Providers. We may provide Personal Data to third-party service providers, who provide services to us, including but not limited to, website hosting, technical support, electronic communication services, data analysis, security, payment processing, sub-processing and other services.
    2. Affiliate Communications. Candex may transfer Personal Data among our affiliates to allow our affiliates to contact you regarding the products, programs, services and promotions that they believe may be of interest to you, and such affiliates may otherwise use your Personal Data in accordance with this Policy. If you would prefer not to receive marketing communications from Candex or our affiliates, please see the "Your Choices Regarding Marketing Communications" section below. Candex Solutions, Inc. will be the party responsible for any jointly used Personal Data.
    3. Strategic Partners and Co-Branded Sites. From time to time, we may enter into a special relationship with another company that is not owned by or affiliated with Candex to provide or promote joint products, services, applications, or features (together, “Offered Items”). Any information, including Personal Data, that you provide in connection with one of these Offered Items will be shared with our third-party partners. You should check these third parties’ websites for information regarding their privacy practices. PLEASE NOTE THAT THIS PRIVACY POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES. If you do not want Personal Data about you shared with such third parties, please do not provide Personal Data in connection with the Offered Items.
    4. Promotions. We may share the Personal Data you provide in connection with Promotions with third-party sponsors of such Promotions (irrespective of whether such Promotions are hosted by us), or otherwise in accordance with the rules applicable to those Promotions.
    5. Assignment. We may disclose or transfer any and all Personal Data that we collect to an affiliated entity or a third party (and their respective advisors) 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 without limitation in connection with any bankruptcy or similar proceedings.
    6. Law Enforcement; Emergencies; Compliance. We may use and disclose Personal Data about you to others as we believe to be appropriate: (a) in compliance with laws, rules, or regulations in any country in which Candex operates, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from government or public authorities, including government and public authorities outside your country of residence; (d) to enforce our Terms of Service; (e) to protect our operations or those of any affiliated entities; (f) to protect the rights, privacy, safety or property of Candex, its affiliates entities, you, or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain. For example, we may, to the fullest extent the law allows, disclose Personal Data about you to law enforcement agencies to assist them in identifying individuals who have been or may be engaged in unlawful activities.

  6. YOUR CHOICES REGARDING MARKETING COMMUNICATIONS

    We give you choices regarding our use and disclosure of your Personal Data for marketing purposes.
    1. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may stop receiving these marketing-related emails by sending an email to notice@candex.com or by changing your preferences in the settings page of the Site at any time.
    2. If you would prefer that we do not share your Personal Data on a going-forward basis with our affiliates or with unaffiliated third parties for their marketing purposes, you may cease this sharing by sending an email to notice@candex.com or by changing your preferences in the settings page of the Site at any time.

      We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you exercise the second option as described above, we will not be able to remove your Personal Data from the databases of our affiliates or unaffiliated third parties with which we have already shared your Personal Data (i.e., to which we have already provided your Personal Data as of the date that we implement your request). Further, please note that requesting us not to share your Personal Data with affiliates or unaffiliated third parties may result in you no longer receiving any marketing emails from Candex. Please also note that if you choose not to receive marketing-related messages from us, we may still send you important administrative messages, and you cannot elect to stop receiving such administrative messages, unless you choose to stop receiving services from us.

      You may also indicate your choices regarding marketing-related emails by contacting us via postal mail or telephone using the “Contact Information for Candex” below, or by changing your preferences in the settings page of the Site at any time.

  7. HOW YOU CAN ACCESS, CHANGE OR SUPPRESS YOUR PERSONAL DATA

    If you would like to request to review, correct, update, suppress, delete or otherwise limit our use of your Personal Data that has been previously provided to us, or if you would like to request to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may: (a) make a request by contacting us using the information provided in the “Contact Information” below; or (b) change your preferences in the settings page of the Site at any time. We will respond to your request as soon as reasonably practicable and consistent with applicable law. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any business transactions that you began prior to requesting the change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.


  8. MISCELLANEOUS
    1. Links
      The Site may contain links to other websites, including social media sites and third-party hosted collaboration tools. These linked sites are not under Candex’s control. We provide links only as a convenience, and do not endorse or control, and is not responsible for the privacy practices or the content of these linked sites. If you provide any Personal Data through any third-party web site, or choose to communicate with us using third-party collaboration tools or other social media platforms, your transaction will occur on that third party's website (not the Site) and the Personal Data you provide will be collected by, and controlled by the Policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES, INCLUDING, WITHOUT LIMITATION, AFFILIATED ENTITIES THAT DO NOT POST OR LINK DIRECTLY TO THIS POLICY.

    2. Security Measures
      Candex has established reasonable organizational and technical measures to protect Personal Data within our organization from loss, misuse, or unauthorized access, disclosure, alteration or destruction. Please note that while we have endeavored to create a secure and reliable Site for users, no site is 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us of the problem immediately by contacting us using the information provided below in "Contact Information." Please note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to any issue.

    3. Data Integrity
      Candex will use Personal Data only in ways that are compatible with the purposes for which it was collected, authorized by this Policy, or authorized by you. Candex will take reasonable steps to ensure that Personal Data is relevant to its intended use, and is accurate, complete, and current. Candex depends on you to update or correct your Personal Data whenever necessary.

    4. Retention Period
      We will retain Personal Data about you for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

    5. Cross Border Transfer of Personal Data
      We primarily store Your Personal Data in the EU.  However, your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Data.

      If you are located in the European Economic Area (“EEA”): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available on the EU Commission’s adequacy list online

      https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures to protect your Personal Data.

    6. Use of this Site by Minors
      This Site is not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Data through this Site.  We do not knowingly collect Personal Data from anyone under the age of 18.

    7. Sensitive Personal Data
      We ask that you not send us, and you not disclose, any sensitive Personal Data, for example, social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership on or through this Site or otherwise to us.

    8. Contact Information
      Questions or concerns regarding our data protection practices should be addressed to:

      Privacy Department
      Candex Solutions, Inc.
      420 Lexington Avenue Suite 300
      New York, NY 10170
      Phone: +1 215 650-3214
      E-mail: notice@candex.com

      If you choose to contact us via email about this Policy, please mark the subject heading of your email “Privacy Inquiry.”

      In the EEA, you also may file a complaint with the data protection authority for your country or region or where an alleged violation of applicable data protection law occurs.

    9. Changes to this Policy
      We may update this Policy from time to time as we deems necessary in our sole discretion. We will provide notification of any material changes to this Policy through the Site or as otherwise required by applicable law.  We encourage you to review this Policy periodically to be informed regarding how we are using and protecting your information and to be aware of any changes. Your continued relationship with Candex after the posting or notice of any amended Policy shall constitute your agreement to be bound by any such changes. Any changes to this Policy take effect immediately after being posted or otherwise provided by us.

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