Marketing Site Privacy Policy

Last updated: August 7, 2020

This Privacy Policy describes how your personal information is collected, used, and shared when you visit the Custodia (“Custodia, “Our”, “We”) marketing web site at https://www.custodia.ai (“Marketing Site”).

Personal Information We Collect

When you visit our Marketing Site, we automatically collect certain information about your device, which includes:

• IP address
• Time zone
• Web browser
• Device type
• Cookies

Additionally, we collect information about the individual web pages or screens that you view, what websites or search terms referred you and information about how you interact with our Marketing Site. We refer to this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:

“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org. Click here to learn more about our cookie policy.

“Log files” track actions occurring with our Marketing Site, and collect data including your IP address, browser type, device type, referring/exit pages, and date/time stamps.

“Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse our Marketing Site.

Additionally, when you fill out a form through our Marketing Site, we collect certain information from you, including your name, email address, and phone number. We refer to this as “Referral Information.”

When we talk about “Personal Information” in this Privacy Policy, we are talking about both Device Information and Referral Information.

How Do We Use Your Personal Information?

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Marketing (for example, by generating analytics about how our customers browse and interact with our Marketing Site, and to assess the success of our marketing and advertising campaigns).

We use the Referral Information that we collect to communicate with you, screen for potential risk or fraud and when in line with the preferences you have shared with us, provide you with information or advertising related to our products or services.

Sharing Your Personal Information

We share your Device Information and Referral Information with third parties to help us use the relevant information as described above. For example, we use Google Analytics to help us understand how our customers use our Marketing Site–you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/.  You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to subpoenas, search warrants or other lawful requests for information we receive, or to otherwise protect our rights.

Behavioral Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by visiting:

• https://www.facebook.com/settings/?tab=ads (Facebook)
• https://www.google.com/settings/ads/anonymous (Google)
• https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads (Bing)
• https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out?trk=microsites-frontend_legal_cookie-policy (LinkedIn)
• https://www.indeed.com/legal/ccpa-dns?hl=en&co=US (Indeed)

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at http://optout.aboutads.info/.

Do Not Track

Please note that we do not alter our Marketing Site’s data collection and use practices when we see a Do Not Track signal from your browser.

Your Rights

You have the right to access the personal information we hold about you and to ask that your personal information is corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

Data Retention

Any information you enter and submit to us via our Marketing Site may be maintained unless and until you ask us to delete this information.

Privacy Shield

We have certified to the U.S. Department of Commerce that we adhere to the Privacy Shield Principles.  If there is any conflict between these terms and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/ and to view our Privacy Shield Policy, please visit https://www.custodia.ai/privacy-shield-policy/.

Changes

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

Contact Us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at privacy@custodia.ai.