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Privacy Policy

We value the privacy of your information. When you use our website, “cold-campaigns.com” (“Site” or “Website”), we collect, utilize, protect, and disclose information and data, as explained in our Privacy Policy. Additionally, you can manage your information preferences by choosing to opt out of certain uses of your personal information (described below), as explained in this Privacy Policy. Every User (“You,” “Your,” “Yours,” “Yourself”) of the Site and any other service we offer is subject to this Privacy Policy. This Site is an informational website operated by Cold-Campaigns, a division of Zypha Corporation (“We,” “Our,” or “Us”).

YOUR USE OF THIS WEBSITE CONFIRMS YOUR AGREEMENT TO THIS PRIVACY POLICY. ENSURE YOU READ IT CAREFULLY. IF YOU DO NOT AGREE TO ANY OF THE TERMS OF THIS PRIVACY POLICY, STOP USING THIS SITE IMMEDIATELY.

COLLECTING AND USING YOUR PERSONAL DATA

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TYPES OF DATA COLLECTED

During Your use of Our Website, we may ask for certain personally identifiable information from You in order to identify or contact You. The categories of personally identifiable information may include, but are not limited to:

First name and last name
Position
Company
Email Address
Usage Data

We may use Your personal data to get in touch with You by way of newsletters, marketing, and promotional materials, as well as other information We think would be of interest and relevant to You. If You would like to stop receiving these emails from Us, simply click the unsubscribe link or follow the instructions in any email We send to You.

 

USAGE DATA

Usage Data is collected automatically when using the Website.

Examples of the kinds of information that may be included in Usage Data are the Internet Protocol address (IP address) of Your device, the service provider and version of Your browser, the pages of Our Website that You view, the time and date of Your visit, the duration of Your visit, unique device identifiers, and other diagnostic data.

When You visit the Website using a mobile device, We might automatically collect certain data, including the type of mobile device You use, its unique ID, IP address, operating system, type of mobile browser and other diagnostic information.

Every time You visit Our Website or access it using a mobile device, We may also collect data that is supplied by Your browser.

 

TRACKING TECHNOLOGIES COOKIES

In order to monitor Your behavior on Our Website and to monitor and retain certain data, We use cookies and other tracking technologies. The tracking technologies We might employ consist of:

 

COOKIES OR BROWSER COOKIES.

This is a file saved to Your device each time you visit Our Website. You have the freedom to set Your browser to reject cookies altogether or to alert You when one is being sent. You might not be able to use some sections of Our Website, if You reject cookies. 

Examples of Cookies We Use

  • Preference Cookies: We use Preference Cookies to store Your preferences and enhance Your browsing experience.

  • Session Cookies: Session Cookies are used to keep track of Your activity on Our Website, when the session ends, the cookie is deleted.

  • Security Cookies: We use Security Cookies to prevent unauthorized access, protect user data and detect potential security threats.

 

WEB BEACONS

Certain sections of Our Website and Our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

 

HOW WE PROTECT COLLECTED PERSONAL INFORMATION

We take the security of Your personal information seriously. Your personal information collected will be protected by all appropriate security measures, in compliance with recognized industry standards and applicable law, We have implemented a security protocol that consists of technical, organizational, administrative, and other security measures intended to guard against potential or real threats to the security of personal data (referred to as the “Security Protocol”).

Nevertheless, no transmission of data using the Internet can be guaranteed to be 100% safe, including the security of the data sent to Us. Your information may be lost, misused, destroyed, altered, or accessed by unauthorized parties while it is in Our care, whether it is being transmitted, resides on Our systems, or otherwise. We disclaim all liability for any such theft, loss, unauthorized access, damage, or interception of any data or communications, including personal information, save from Our obligation to maintain the Security Protocol in accordance with relevant legislation. Because of the nature of the expected risks to the personal information We collect, We believe that Our Security Protocol is reasonable and adequate for the nature of Our business and the operation of Our Website. Additionally, We examine and update Our Security Protocol on a regular basis. In accordance with relevant law.

We have certain incident response and management protocols as part of Our Security Protocol, and they are followed anytime We suspect that Your personal data may have been compromised. Additionally, any parties involved in managing Our Website are required to immediately report to Us if they become aware that an incident has taken place which might negatively affect Your personal information.

 

USE OF YOUR PERSONAL DATA

We may use Your Personal Data for the following purposes:

  • To provide and maintain Our Website: including monitoring the usage of Our Website.

  • To contact You: to communicate with You via email, phone calls, SMS, or other comparable electronic communication channels, like push notifications on a mobile application about updates or informational messages about the features, services, events or other Company activities as appropriate.

  • To manage Your requests: to attend and manage Your requests to Us.

We may share Your personal information in the following situations:

  • With Website Providers: We might disclose Your personal data to website providers in order to track and examine how Our Website is used, and to get in touch with You.

  • For business reasons: We reserve the right to disclose or move Your personal information in the course of negotiating or in connection with any merger, asset sale, financing, or purchase of all or a portion of Our Company by another business.

  • With Affiliates: We may share Your information with Our affiliates, in which case We will require those affiliates to honor this Privacy Policy. Affiliates include Our shareholders, joint venture partners or other companies that We control or that are under common control with Us.

  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

 

RETENTION OF YOUR PERSONAL DATA

Your Personal Data will only be kept by the Us for the duration required to fulfill the objectives outlined in this Privacy Policy. To the extent required to fulfill Our legal duties (for instance, if We must keep Your data on file to abide by applicable laws), settle disputes, and uphold Our legal commitments and policies, We will keep and utilize Your Personal Data.

We will also keep Your Personal Data for in-house analysis. Useful information is typically kept for a shorter amount of time, unless it is used to enhance the functionality or security of Our Website, or unless We are required by law to keep it longer.

 

TRANSFER OF YOUR PERSONAL DATA

We process Your information, including Personal Data, at Our operating offices and any other locations where any contracted parties engaged in the processing of personal data have their offices. This implies that this data may be moved to and kept on computers situated outside of Your nation, state, or other governmental jurisdiction, where the regulations governing data protection may be different from those in Your jurisdiction. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

During data transfer, We will take all reasonably required actions to ensure that Your data is handled securely and in compliance with this Privacy Policy. Your Personal Data will not be transferred to another organization or nation unless sufficient safeguards, such as those pertaining to the security of Your data and other personal information, are in place.

 

DISCLOSURE OF YOUR PERSONAL DATA

BUSINESS TRANSACTIONS

Your Personal Data could be transferred, shared, or disclosed if the We are involved in a merger, acquisition, or asset sale. Before Your Personal Data is moved and is covered by a totally new privacy policy, We will notify You.

 

LAW ENFORCEMENT

Under certain circumstances, the We may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

 

OTHER LEGAL REQUIREMENTS

We may disclose Your Personal Data in good faith if such action is necessary to:

  • Comply with a legal obligation
    • Prevent or investigate possible wrongdoing in connection with the Website

  • Protect the personal safety of Users of the Website or the public

  • Protect and defend the rights or property of the Company

  • Protect against legal liability

 

SECURITY OF YOUR PERSONAL DATA

We take the security of Your Personal Data very seriously, but no method of electronic data transfer over the Internet or method of electronic data storage is 100% safe. We cannot guarantee the complete security of Your Personal Data, save that we protect it using commercially reasonable methods.

 

PROCESSING OF YOUR PERSONAL DATA

The website providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Website in accordance with their privacy policies.

 

ANALYTICS

We may use third-party Website providers to monitor and analyze the use of Our Website.

 

EMAIL MARKETING

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest and relevant to You. You may opt-out of receiving any of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting at: info@cold-campaigns.com

 

GDPR PRIVACY

LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER GDPR

We are GDPR-compliant. We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes, or

  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof, or

  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject, or

  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person, or

  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company, or

  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by Us.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

 

YOUR RIGHTS UNDER THE GDPR

We respect the confidentiality of Your Personal Data and ensure You can exercise Your rights. You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever possible, You can access, update or request deletion of Your Personal Data directly within Your account settings section. If You are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.

  • Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.

  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and You want to object to Our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.

  • Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.

  • Withdraw Your consent. You have the right to withdraw Your consent on using Your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of Our Website.

 

EXERCISING YOUR GDPR DATA PROTECTION RIGHTS

You may exercise Your rights of access, correction, cancellation and rejection by contacting Us. Please note that We may ask You to verify Your identity before responding to such requests. If You make a request, We will try Our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

 

CCPA PRIVACY POLICY

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

 

CATEGORIES OF PERSONAL INFORMATION COLLECTED

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular User or device. The following is a list of categories of personal information that We may collect or may have collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects Our belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

Category A: Identifiers.

Examples: A real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, or name.

Collected: Yes.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A 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. Some personal information included in this category may overlap with other categories.

Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: No.

Category D: Commercial information.

Examples: Records and history of products purchased

Collected: Yes.

Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity.

Examples: Interaction with Our Website or advertisement.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: Yes.

Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: Yes.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Under CCPA, personal information does not include:

  • Publicly available information from government records

  • Deidentified or aggregated consumer information
    Information excluded from the CCPA’s scope, such as:

  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.

  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
    Sources of Personal Information
    We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from You. For example, from the forms You complete on Our Website, preferences You express or provide through Our Website, or from Your purchases on Our Website.

  • Indirectly from You. For example, from observing Your activity on Our Website.

  • Automatically from You. For example, through cookies We or Our Website Providers set on Your Device as You navigate through Our Website.

  • From Website For example, third-party vendors to monitor and analyze the use of Our Website, third-party vendors for payment processing, or other third-party vendors that We use to provide the Website to You.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:

  • To fulfill or meet the reason You provided the information. For example, if You share Your contact information to respond to an offer or to ask a question about our Website, We will use Your personal information to respond to Your inquiry.

  • For internal administrative and auditing purposes.
    • To respond to law enforcement requests and as required by applicable law, court order, or government regulations.

  • As described to You when collecting Your personal information or as otherwise set forth in the CCPA.

  • To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how We use this information, please refer to the “Use of Your Personal Data” section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

  • Category A: Identifiers

  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

  • Category D: Commercial information

  • Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects Our belief, to the best of Our knowledge that some of that information from the stated category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

 

SALE OF PERSONAL INFORMATION

According to the CCPA, the terms “sell” and “sale” refer to a business’s selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a customer’s personal information to a third party for a valuable consideration, whether orally, in writing, electronically, or through another means. This implies that while We might not have benefited monetarily, We might have benefited in some other way for sharing personal information.

We do not sell Your personal data.

Sharing of Personal Information

We may share Your personal data identified in the above categories with the following categories of third parties:

  • Website Providers
    • Third party vendors when You or Your agents authorize Us to disclose Your personal information in connection with services We provide to You

  • Our business partners

  • Our affiliates

  • Payment processors

 

SALE OF PERSONAL INFORMATION OF MINORS UNDER 16 YEARS OF AGE

We do not intentionally collect personal information from minors under the age of 16 through Our Website. 

We do not sell personal data. 

Should You suspect that a child under the age of 16 has given Us personal data, we will remove it on request.

Your Rights under the CCPA

Residents of California have certain rights with relation to their personal data under the CCPA. The following rights are Yours if You live in California:

  • The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

  • The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and sharing of personal data. Once We receive and confirm Your request, We will disclose to You:

    • The categories of personal data We collected about You

    • The categories of sources for the personal data We collected about You

    • Our business or commercial purpose for collecting or selling that personal data

    • The categories of third parties with whom We share that personal data

    • The specific pieces of personal data We collected about You

    • If We disclosed Your personal data for a business purpose, We will disclose to You the categories of personal data categories disclosed

The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Website Providers to delete) Your personal data from Our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Website Providers to:

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights, including by:

  • Denying services to You

  • Charging different prices or rates for services ,including the use of discounts or other benefits or imposing penalties

  • Providing a different level or quality of services to You

 

EXERCISING YOUR CCPA DATA PROTECTION RIGHTS

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

  • Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative.

  • Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.
    We cannot respond to Your request or provide You with the required information if We cannot:

  • Verify Your identity or authority to make the request, and

  • Confirm that the personal information relates to You

  • We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.

For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

 

MOBILE DEVICES

By adjusting the settings on Your mobile device, You can prevent location data from being collected from it.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Do Not Track signals are not recognized by Our Website.

Nevertheless, several websites owned by third parties do monitor Your browsing habits. You can instruct websites that You do not wish to be tracked by configuring Your browser’s options if You visit such sites. By going to Your web browser’s preferences or settings page, You can enable or disable DNT.

 

CHILDREN’S PRIVACY

Oue Website is not intended for anyone under the age of 18. We do not knowingly ask anyone younger than 18 for personally identifying information. Please get in touch with Us if You are a parent or guardian and You know that Your child has given Us Personal Data. We will delete Personal Data from Our servers if We know that We have obtained such information from anybody under the age of 18.

Your California Privacy Rights (California’s Shine the Light law)

California citizens who have an established business relationship with Us may obtain information once a year regarding the sharing of their Personal Data with third parties for the third parties’ direct marketing purposes under California Civil Code Section 1798, sometimes known as California’s Shine the Light statute.

If You live in California and would want to obtain additional information under the California Shine the Light law, please use the contact details listed above to get in touch with us.

 

LINKS TO OTHER WEBSITES

There may be links within Our Website to external websites that are not run by Us. A third party’s website will be displayed if You click on one of their links. We strongly suggest that You go over each website’s privacy statement.

The content, privacy practices, and policies of any third-party websites are beyond Our control and responsibility.

 

DATA BREACH NOTIFICATION

Keeping Your personal data safe is Our top priority. We are committed to swiftly informing You and taking the required actions to minimize any effect in the rare case of a data breach.

  • Notification Process: With 72 hours of learning of the incident, We will send out emails to everyone who may have been impacted. We shall also publish a notice on Our Website and, if required, notify the public media outlets in the event that the breach is of a considerable kind. In the unlikely event of a data breach, We are committed to promptly notifying You and taking the necessary steps to minimize any impact.

  • Information Provided: We will provide You with information regarding the type of breach, the data categories compromised, the anticipated consequences of the breach, and the steps We have taken or plan to take to remedy the breach. We’ll also offer advice on precautions You can take to keep safe.

  • Inquiry and Correction: In the event of a breach, we shall investigate it thoroughly and where possible, take immediate action to address the root cause.

 

CHANGES TO THIS PRIVACY POLICY

We might occasionally make changes to Our Privacy Policy. Any modifications will be communicated to You by posting the updated Privacy Policy on this page.

It is recommended that You routinely check this Privacy Policy for updates. Any modifications to this privacy statement take effect immediately upon posting on this website.

CONTACT US

If You have any questions about our Privacy Policy, please contact Us at: info@cold-campaigns.com

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