Cyndx Privacy Policy for Residents of California

Last revised January 1, 2020

With respect to personal information stored by Cyndx Networks LLC (“Cyndx” or “we”), residents of the U.S. state of California have certain rights in addition to the rights set forth in the Cyndx Data and Privacy Policy

This Privacy Policy for Residents of California is designed to be accessible to users with disabilities using screen-reader technology.  If you would prefer to print this policy, please download this PDF.

Categories of Personal Information Collected by Cyndx

We collect information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household (“personal information”).  We have collected one or more data types in the following categories of personal information from or about California consumers within the twelve (12) months preceding the effective date of this Privacy Policy for Residents of California:

Categories One or More Data Types Collected?
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Yes
Any categories of personal data described in Cal. Civ. Code § 1798.80(e), such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Yes
Characteristics of protected classifications under California or federal law. Yes
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. No
Biometric information No
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. Yes
Geolocation data Yes
Audio, electronic, visual, thermal, olfactory, or similar information. No
Professional or employment-related information. Yes
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act. Yes
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. No

In particular, we collect the following types of personal information:

Business Contact Information

Cyndx receives from its users and from third-party business information providers certain business contact information, some of which relates to persons who reside in California.  That business contact information includes the following personal information:

  • names;
  • business affiliations and titles;
  • professional qualifications
  • business-related biographical information;
  • telephone numbers;
  • email addresses;
  • social media profile links;
  • genders; and
  • dates of birth.

Electronic Network Activity Information

In the past 12 months, categories of electronic network activity information collected by Cyndx’s public-facing website and logged-in platform have been the following:

  • username, email address, and password (for users of Cyndx’s logged-in platform only);
  • IP address;
  • country, region and city (based on IP address);
  • web browser type; and
  • referring website.

Cyndx does not disclose this data to any other parties and uses this technical information only (i) to provide, and enhance the provision of, Cyndx’s software-as-a-service products and (ii) to administer Cyndx’s public-facing website.  This information is collected through common web technologies, including, without limitation, browser cookies.

Categories of Sources of Personal Information

Cyndx obtains personal information in the categories described above:

  • Directly from Cyndx customers, which are businesses that purchase our services;
  • From consumers’ activity on Cyndx’s public-facing website;
  • From third-party business information providers; and
  • From information that is publicly disclosed via the internet.

Business Purpose for Collecting Personal Information

Cyndx uses the personal information that we collect for the following purposes:

  • Business information:  We collect business contact information, which includes certain personal information as described above, to make it possible for users of the Cyndx platform to contact businesses listed in the platform.  We also collect information about individuals’ holdings in certain securities.
  • Electronic network activity information: 
    • We collect electronic network activity information to provide, and to enhance the provision of, Cyndx’s software-as-a-service tools.
    • We also collect electronic network activity information to administer our public-facing website.
    • We may collect electronic network activity information to detect security incidents and to protect against malicious, illegal or fraudulent activity.
    • We may collect certain electronic network activity information to maintain or service accounts or to provide customer service.

Categories of Third Parties with whom Cyndx Shares Personal Data

We may share your personal information:

  • With respect to business contact information only, with users of Cyndx software-as-a-service products, who may use such contact information to reach businesses listed on our platform;
  • With our affiliates and third-party service providers that perform services on our behalf, subject to confidentiality restrictions;
  • With law enforcement or governmental authorities if we believe that someone may have engaged in malicious, illegal or fraudulent activity on our website or in our software-as-a-service products; and
  • With respect to electronic network activity information only, with third-party analytics providers, to analyze use of the Cyndx website.

We do not share your personal information with any third parties for their marketing purposes.

In connection with Cyndx’s operation of software-as-a-service products that provide business contact information to paying users of these products, Cyndx has sold the following categories of personal information in the twelve (12) months preceding the effective date of this Privacy Policy for California Residents:

A.        Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

B.        Any categories of personal data described in Cal. Civ. Code § 1798.80(e), such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

I.          Professional or employment-related information.

In connection with Cyndx’s operation of software-as-a-service products that provide business contact information to paying users of these products, Cyndx has disclosed the following categories of personal information in the twelve (12) months preceding the effective date of this Privacy Policy for California Residents:

A.        Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

B.        Any categories of personal data described in Cal. Civ. Code § 1798.80(e), such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

I.          Professional or employment-related information.

Your Rights as a California Resident

As a resident of the state of California, you have certain rights with respect to your personal information under California law. 

Right to Know

As a California resident, you may request that Cyndx disclose to you the following:

  • the categories of personal information that Cyndx has collected about you;
  • with respect to the 12 months preceding your request, the categories of personal information that Cyndx may have transferred about you and the categories of third parties to whom such personal information was transferred, by category or categories of personal information for each third party to which the personal information was transferred; and
  • with respect to the 12 months preceding your request, the categories of third parties to which Cyndx disclosed your personal information for business purposes. 

If Cyndx receives a request from you for the information listed above, Cyndx may request additional information from you to verify your identity.  Once Cyndx has verified your identity, Cyndx will provide to you the information listed above free of charge.

Nevertheless, Cyndx will under no circumstances provide you with specific pieces of personal information if the disclosure of such personal information creates a substantial, articulable, and unreasonable risk to the security of such personal information, your account with Cyndx, or the security of Cyndx’s platform and systems. 

Moreover, Cyndx will not disclose specific pieces of personal information to you if the disclosure of such information would conflict with other applicable federal or state law.  If Cyndx declines to disclose any personal information to you on the basis of this exception, Cyndx will explain the basis for the denial.

Right to Deletion

As a California resident, you may request that Cyndx delete personal information that Cyndx has collected from you, other than information that Cyndx must retain to do any of the following:

  • to provide services to you;
  • to detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity;
  • to identify and repair errors that limit existing functionality;
  • to exercise Cyndx’s right to free speech or ensure your, or another consumer’s, right to exercise his or her right to free speech, or any other right provided for by law;
  • to comply with the California Electronic Communications Privacy Act;
  • to enable Cyndx’s solely internal use of your personal information in ways contemplated by your relationship with Cyndx under a services agreement or other arrangement between you and Cyndx;
  •  to comply with Cyndx’s legal obligations; or
  • to use your personal information in other exclusively internal ways that are compatible with the context in which you first provided such personal information. 

If Cyndx receives a request for deletion of your personal information, Cyndx may request additional information from you to verify your identity.  Once Cyndx has verified your identity, Cyndx will delete your personal information its databases.

Right to Opt-Out; Right to Opt-In

As a California resident, you have the right, at any time, to request that Cyndx remove your personal information from the database of business contact information that Cyndx makes available to users of Cyndx’s logged-in platform.  If Cyndx has a good-faith, reasonable, and documented belief that your request to opt-out of the sale of your personal information is fraudulent, Cyndx will deny your request and provide you with a written explanation of why Cyndx believes your request is fraudulent.

After you request to opt-out of Cyndx’s maintenance of your business contact information in its platform, you may request to opt-in to the inclusion of your business contact information in Cyndx’s platform at any time. 

With respect to the right of minors or, if applicable, their parents or guardians to opt-in to the sale of their personal information, Cyndx does not possess personal information regarding any persons who are younger than 18 years old. 

Right to Non-Discrimination

If you make a request to access your personal information, delete your personal information or opt out of sale of your personal information to third parties, Cyndx will not discriminate against you by preventing you from accessing Cyndx’s logged-in platform, charging you a higher price for use of Cyndx’s services, providing a different quality of services to you, or suggesting that you may receive a different price for goods or services or that you may receive a different level of quality of goods or services from Cyndx. 

However, if you request that Cyndx delete your personal information, your business contact information will not be available to users of Cyndx’s logged-in platform, which will limit the ability of those users to contact you and may prevent those users from communicating with your business.

Right to Appoint an Authorized Agent to Exercise Rights

An authorized agent may submit requests to opt-out or delete with respect to your personal information if you have given such authorized agent written permission to do so.  If an authorized agent submits a request to opt-out or delete on your behalf, Cyndx will request proof that the agent has been authorized by you to act on your behalf.

How California Residents Can Exercise Their Rights

If you wish to exercise any of the rights  described above, please visit our Do Not Sell My Personal Information request form for California residents or call (877) 237-4418.  If you choose to use our Do Not Sell My Personal Information request form for California residents, you will not be required to create an account to exercise your rights.

Timeframe for Responses

Cyndx will usually respond to your request within 45 days.  If Cyndx is not able to respond to your request within 45 days, Cyndx will provide you with notice and an explanation of the reason that Cyndx will take more than 45 days to respond to your request.