Privacy Policy

This privacy policy (“Privacy Policy”) governs the data collection, processing, and usage by Aulder Capital llc (“Company”, “we” or “us”) with respect to the data we collect from individuals who access and use our website and any of our domains or subdomains (respectively, “Website” and “Visitors” or “you”).

This Privacy Policy constitutes an integral part of any other agreement between you and us, including but not limited to the Website’s Terms and Conditions (together “Terms”), and provides you with information regarding what Personal Data (as defined below) we collect and for what purposes, our data processing operations, the lawful basis pursuant to which we process your Personal Data, third parties to whom Personal Data will be transferred, how long we retain Personal Data, etc. This Privacy Policy also describes how you may exercise your rights, where and to the extent applicable under relevant privacy legislation, including the EU General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act (“CCPA”) and any other applicable privacy-related regulation (together “Privacy Legislation”). 

Definitions used herein but not defined herein shall have the meaning ascribed to them in the Terms or the relevant Privacy Legislation. 

You are not required by law to provide us with any Personal Data. Sharing your Personal Data with us is entirely voluntary. However, without your data, we will not always be able to provide you with all or some of our services.

FURTHER, PLEASE NOTE THAT THIS PRIVACY POLICY GOVERNS THE USE OF OUR PROMOTIONAL WEBSITE AND LANDING PAGES, DESIGNATED FOR INFORMATIONAL PURPOSES ONLY, AS EXPRESSLY DESCRIBED IN THE TERMS. THIS PRIVACY POLICY DOES NOT COVER THE USE OF ANY OF OUR PRODUCTS AND SERVICES AND DOES NOT RELATE TO ANY INVESTMENT PROPOSAL OR ADVICE, NOR TO OUR INVESTORS MANAGEMENT AND COMMUNICATIONS. 

 

  1. AMENDMENTS

    We reserve the right to periodically revise this Privacy Policy, which will have immediate effect upon posting the revised Privacy Policy on our Website. The last revision date will be reflected in the “Last Updated” heading at the top of the Privacy Policy. We will make a reasonable effort to notify you by email if we implement any changes that substantially change our privacy practices. We recommend you review this Privacy Policy periodically to ensure that you understand our privacy practices and to check for any amendments. 

  2. ADDITIONAL POLICIES

    If you are a California, Nevada, Virginia or Colorado resident, please review our CCPA Notice below which may apply to you.

  3. OUR DETAILS AND THE DATA CONTROLLER FOR GDPR PURPOSES

    We are: Aulder Capital llc

    Our address is: 21 W 38th St 11th floor, New York, NY 10018 United States

    Phone (toll free number): (888) 831-2962

    Email: privacy@aulder.com 

    If you are an EU resident, under the GDPR, we are the data controller of EU residents’ Personal Data collected on our website.

    If you have any questions or comments about this Privacy Policy, or any concerns with respect to how your privacy any information is handled, please contact our privacy team through the contact details above. Please include your name, mailing address and email address in the message.

  4. THE DATA WE COLLECT AND ITS PURPOSES  

    “Non-Personal Data”: means non-identifiable data, including statistical, aggregated and “de-identified” data, which can no longer be associated with any individual (even if it was derived from Personal Data).  This includes technical data transmitted to us by your device when you access and interact with our services, such as the type of browser, operating system, type of device used, the time and date you access our services, navigation, and language preference, etc. Non-Personal Data is primarily used for technical analysis, research, and development of our services to provide, maintain, develop and enhance it, and is not used to identify individuals. Under this Privacy Policy, we can use any aggregated, statistical and de-identified data with no limitation. Such data may be included in our proprietary information and is not deemed personal data under the law.

    “Personal Data”: means information that identifies or may identify, with reasonable effort, an individual. Such data includes, inter alia, your name, address, phone number, email, and online identifiers (such as IP address or Cookie ID). 

    Please see below the table which specifies the Personal Data we collect and how we use it:

    DATA SET PURPOSE AND OPERATIONS LAWFUL BASIS

    Online Identifiers  

    When you interact with our website, we may collect your online identifiers, such as unique ID, Cookie ID, and IP address (“Online Identifiers“).

    		 We process Online Identifiers for operational and technical purposes, such as to enable the website to be uploaded, as well as fraud prevention and data security.

    Strictly necessary cookies which are required for the proper and basic operation of the website and will be processed based on our legitimate interest. 

    Other cookies, including any targeting and marketing cookies, will be processed based on your consent which we will obtain through our cookie notice and consent management. You may withdraw consent at any time by using the cookie preference settings . 

    Contact Information

    When you voluntarily contact us for support or other inquiries, you may be required to provide us with certain information such as your name, email address, company name, and additional information you decide to share with us (“Contact Information“).

    We will use your Contact Information solely for the purpose of responding to your inquiries.

    Our correspondence with you may be processed and stored by us in order to improve our customer service and in the event, we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable). 

    		 We process Contact Information subject to our legitimate interest. 

    Newsletter

    In the event you voluntarily subscribe to receive our newsletter or other marketing materials, you will be asked to provide us with your contact details, such as your email address. 

    		 We will use this information solely to provide you with the content that you have requested.

    We process such information subject to your consent. You may withdraw consent at any time through the “unsubscribe” link within the email you will receive or by contacting us directly at: privacy@aulder.com . 

    If you unsubscribe, we further retain your email address however solely as part of our opt-out list, based on our legitimate interest and solely to ensure we comply with such preference and choice (meaning so we will know not to send you marketing materials).

    Career

    When you apply for a job position through our website, we will process your CVs, including your name, email address, phone number, information regarding your education and skills, employment history, and your photo (to the extent provided by you). Further, where required by law, we may process diversity and inclusion data regarding your candidacy, such as ethnicity, gender, or any disability. In addition, we may collect further information from public and online sources, referees, and former employers and combine such data with your other data. (“Recruitment Information“).

    We will use your Recruitment Information to process your job application and in order to manage our internal recruitment purposes, for further recruitment steps (e.g., interview), and in order to comply with corporate governance and legal and regulatory requirements.

    Following the completion of the recruitment process, we may further retain and store your Recruitment Information (including other interactions with us under such process) as part of our internal record keeping, including for legal defense from any future claim, as well as, where we find applicable and subject to applicable law requirements, to contact you in the future for other job position we believe will suit your qualifications. 

    If you are hired by us, your data may be used in connection with your employment and our corporate management.

    We may use third parties’ services and platforms to manage the recruitment process, which will process your data on our behalf.

    We process Recruitment Information subject to our legitimate interest.

    Please note, in the event, you send us your CV, your provision of Personal Data in connection with recruiting is voluntary, and you determine the extent of information you provide us. 

    In some cases, for example, where we will ask you to provide health related data or diversity and inclusion data, we will process these data based on your consent.   You may always withdraw consent at any time by contacting us.


    Please note that the actual     processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. Transfer of Personal Data to third-party countries, as further detailed in the Data Transfer section, is based on the same lawful basis as stipulated in the table above. 

    In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of our service, as well as to protect the security or integrity of our databases and Website, and to take precautions against legal liability. Such processing is based on our legitimate interests. 

  5. COOKIES USAGE

    We use “cookies” (or similar tracking technologies such as pixels and tags) when you access and use our Website. The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your browser or device while you are viewing a website. Cookies are used for various purposes, and mainly, as follows: 

    • Essential/Strictly Necessary Cookies – which are strictly necessary for the Website to work correctly.
    • Functional Cookies – allows for enhanced functionality such as saving your language preference and enabling you to navigate between pages mise efficiently. 
    • Targeting/Marketing Cookies – used to collect information from to help us improve marketing campaigns as well as to serve targeted advertisements (for example, if you access our website, you might be displayed with ads on our behalf on other websites). 
    • Social Media Cookies – Social Plug-In Cookies (e.g., Facebook, Twitter, LinkedIn, etc.) enabling social media features such as log-in, sharing content, etc., as well as marketing and targeting campaigns. 
    • Analytics/Performance Cookies – give us aggregated and statistical information regarding the usage of our website (for example pages views, etc.) to improve the services and further develop them.

    You can find more general information about cookies at https://www.allaboutcookies.org/. 

    Cookie’s data is usually collected using third-party services, like Google, Facebook, etc. In those cases, your Personal Data might be transferred to those third parties, which might link it and use it together with other information they have on you from other sources. Such data is “owned” and processed separately by those third-parties under their terms and conditions and the direct accounts or subscriptions you have with those third parties. For example, if you have a Facebook account, the Personal Data collected through Facebook’s Cookies on the website might be linked to other data that Facebook collects from you as a Facebook user and might be used by Facebook per the independent agreements between you and Facebook.

    The specific cookies we currently use, and your choices with regard to such use are detailed HERE.

     

  6. METHODS FOR COLLECTING YOUR DATA

    According to the nature of your interaction with our services, we may collect information as follows:

    • Provided by you voluntarily – we will collect information if and when you choose to provide us with information, such as completing any contact form. 
    • Automatically – we may use cookies and similar tracking technologies (as elaborated in the Cookies Section above) to gather some information automatically when you access the Website. 
    • Provided to us by third parties – as part of our digital marketing efforts as described above. 

  7. DATA SHARING– CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:

    We share your data with third parties, including with trusted partners or service providers that help us provide our services. Below you can find information about the categories of such third-party recipients. 

    CATEGORY OF RECIPIENT DATA THAT WILL BE SHARED PURPOSE OF SHARING
    Internally within our group of companies and affiliated parties analytics, marketing and usage data We may disclose some of our customer’s data with our sister companies and subsidiaries in the Aulder Group, to allow us to mange our business efficiently and effectively. Your data will be always managed under strict procedures and processes ensuring it is being taken care as required under law and with great respect to your privacy and rights.   
    Trusted Agents and Service Providers All data We may disclose Personal Data to our trusted agents and service providers (including, but not limited to, our Cloud Service Provider, our Analytics Service Provider, our CRM provider, etc.) so that they can perform the requested services on our behalf. These entities are prohibited from using your personal information for any purposes other than providing us with requested services. 
    Any acquirer of our business All data We may share Personal Data, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy.
    Legal and law enforcement  Subject to law enforcement authority request We may disclose certain data to law enforcement, governmental agencies, or authorized third parties, in response to a request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose.

     

    Where we share information with services providers and partners, we ensure they only have access to such information that is strictly necessary. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).

  8. INTERNATIONAL DATA TRANSFERS

    The Company’s headquarters is based in New York, USA, and we operate from few separate worldwide sites in which we may access the information stored on servers or other systems such as the Company’s ERP, CRM, and other operational IT systems. In the event that we need to transfer your Personal Data out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. 

    Furthermore, when Personal Data that is collected within the European Economic Area (“EEA”) is transferred outside of the EEA to a country that has not received an adequacy decision from the European Commission, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union. Thus, we will obtain contractual commitments and or assurances from the data importer to protect your Personal Information, using contractual protections that EEA and UK regulators have pre-approved to ensure your data is protected (known as standard contract clauses), or rely on adequacy decisions issued by the European Commission. Some of these assurances are well recognized certification schemes.

  9. YOUR RIGHTS

    Individuals have certain rights under applicable privacy laws concerning their Personal Data. Subject to your jurisdiction (and additional conditions), these rights may include:

    • The right to be informed – you have the right to be provided with information regarding our data collection and privacy practices, as detailed in this Policy. If you have any additional questions, please contact us. 
    • The right to access your Personal Data – you have the right to request a confirmation from us that we process your Personal Data, and in some cases, be provided with a copy of the Personal Data we process.
    • The right of rectification – you have the right to require to update Personal Data that is not correct;
    • The right to the erasure of your Personal Data
      (the right to be forgotten) – you have the right to require the erasure of certain Personal Data if specific conditions are satisfied. This right is not absolute. We may reject your request under certain circumstances, including where we must retain the data in order to comply with legal obligations or defend against legal claims, etc.;
    • The right to restrict the processing of your Personal Data – you may be entitled to limit the purposes for which we process your Personal Data if specific conditions are satisfied;
    • The right to object to the processing of your Personal Data – you have the right to object to the processing of Personal Data, in the event the basis for processing is our legitimate interests. However, we will be permitted to continue the processing if our legitimate interests override your rights, or when processing is necessary to establish, exercise, or defend a legal claim or right, etc.; 
    • Data portability – you have the right to get a copy of your data in a format that may allow you to “port” it to a third party; 
    • The right to file a complaint to a supervisory authority – specifically, with regards to Personal Data collected about you in the EEA or UK, please contact the applicable EU Data Protection Authority.
    • The right to withdraw your consent – when the lawful basis for processing your Personal Data is your consent. For example, you may unsubscribe at any time from our mailing list.
    • Additional rights as further detailed in our CCPA Notice available below, to the extent applicable. 

     

    You may exercise any or all of your above rights in relation to your Personal Data by emailing us at privacy@aulder.com and requesting a Subject Access Request Form.  

     

    Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the relevant supervisory authority. We reserve the right to ask for reasonable evidence to verify your identity before providing you with any such information per applicable law. 

     

  10. RETENTION 

    In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulations, or until you express your preference to opt out, where applicable. 

     

    The criteria used by us to determine our retention periods are as follows: 

    • We retain Personal Data for the periods needed in order to achieve the purpose for which Personal Data was collected. For example, contact us data will be retained, at least as necessary for addressing your inquiry. 
    • We retain Personal Data for the periods needed in order to comply with our obligations under applicable laws. For example, data which may affect our legal exposure may be kept for long periods, up to seven years, in accordance with the legal statute of limitations. 
    • If you have a dispute with us, we may retain certain types of Personal Data as necessary and applicable to your claims, including any legal proceedings between us, until such dispute is resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods. In addition, in the event you request to exercise your rights, we will maintain the relevant correspondence for as long as needed to demonstrate compliance. 

     

    At our sole discretion, we may rectify or erase information from our systems without prior notice to you, once we deem it no longer necessary for such purposes.

  11. SECURITY

    We work hard to protect Personal Data we process from unauthorized access or unauthorized alteration, disclosure or destruction. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry such as: encryption using SSL, we minimize amount of data that we store on our servers, restrict access to Personal Data to our employees, contractors and agents, etc. Note that we cannot be held responsible for unauthorized or unintended access that is beyond our control, and we make no warranty, express, implied or otherwise, that we will always be able to prevent such access. Further, in the event of a data breach, in which we discover your Personal Data is at risk, we will notify you, if technically possible, by sending you an email, subject to applicable law requirements. 

    Please contact us if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

  12. CHILDREN

    Our website and Services are not intended for use by children (the phrase “child”, with respect to the US, is anyone under the age of 13) and we do not knowingly process children’s information. We will discard any information that we receive from a user that is considered a “child” immediately upon our discovery that such a user shared information with us. Please contact us promptly if you have reason to believe that a child has shared any information.


PRIVACY NOTICE FOR CALIFORNIA, NEVADA AND VIRGINIA RESIDENTS


[Last Updated: May 2023]

This CCPA notice (“CCPA Notice”) applies to Aulder’s website visitors (“consumers” or “you“) who are California, Virginia and Nevada residents, in accordance with the following data protection laws as applies respectively – the California Consumer Privacy Act of 2018 as amended and revised by the California Privacy Rights Act of 2020 (“CPRA” and collectively “CCPA“), the Virginia Consumer Data Protection Act (“VCDPA”), the Nevada Privacy of Information Collected on the Internet from Consumers Act (“NPICICA“) or the Colorado Consumer Protection Act (“CPA”)  (collectively “Data Protection Law(s)“).

This CCPA Notice applies to Consumers’ Personal Information, which we collect directly or indirectly while using our Website. 

This CCPA Notice is an integral part of our Privacy Policy. Any capitalized terms not defined herein shall have the meaning ascribed to it under the Data Protection Laws or the Privacy Policy.

 

Part I: A Comprehensive Description of the Information Practices:

1) Categories of Personal Information We Collect

We collect Personal Information which is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device, all as detailed in the table below. 

Personal Information definition under Data Protection Laws further includes Sensitive Personal Information (“SPI”) or Sensitive Data, as detailed in the table below. However, certain types of such data are excluded from the Data Protection Laws, including, without limitation: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; biometric data covered by the Biometric Information Privacy Act (BIPA); Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA) or the Driver’s Privacy Protection Act of 1994. Therefore, Patient’s data collected during the use of our websites and the System is excluded from the scope of this Notice.

Aulder may have collected the following categories of personal information from its website visitors within the last twelve (12) months:

Category Example Collected
A. Identifiers. A real name, email, phone, address, online identifier, Internet Protocol address, email address, or other similar identifiers as detailed in the contact forms available at the website.

Yes, basics contact info as detailed in the website

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

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.

 Yes, names and telephone numbers
C. Protected classification characteristics under California or federal law. 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). No
D. Commercial information. Records of personal property, products or websites purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.  No
E. Biometric information. 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. No
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Yes, cookies and other technical data on the website 
G. Geolocation data. Physical location, approximate location derived from IP address or movements.  Yes, approximate location derived from IP address.
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No 
I. Professional or employment-related information. Current or past job history or performance evaluations. Yes, only from job applicants if provided to apply to a position in Aulder
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)). 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. No
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. No
L. Sensitive personal information. Social security, driver’s license, state identification card, passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, or union membership, the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication, genetic data, biometric data, information concerning health, sexual life or sexual orientation. No


2) Categories of Sources of Personal Information 

Depending on the nature of your interaction with Aulder, Aulder collects the Personal Information as follows:

From website’s visitors:

  • Provided by the visitor voluntarily in order to contact Aulder.
  • Automatically through Aulder third party website providers – for example, in order to collect visitors’ IP address.

From Job Applicants:

  • Provided voluntarily and directly when the candidate files an application to a position.
  • Automatically through Aulder third party website providers – for example, in order to collect visitors’ IP address, or following the application from relevant recruitment agencies.

3) Use of Personal Information

We may use the Personal Information collected as identified above, for the following purposes: 

  • For contacting you as per your request or inquiry;
  • To improve our services including the website through statistical analysis website’s visitors usage of the website;
  • For screening you as a job applicant to a position in Aulder; 
  • Respond to law enforcement; or otherwise as detailed in our Privacy Policy. 

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice. 

4) Disclosures of Personal Information for A Business Purpose

We may disclose your Personal Information to a contractor or website provider for a business purpose. When we disclose Personal Information for a business purpose, we enter into 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. We further restrict the contractor and website provider from selling or sharing your Personal Information. 

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose: 

Business Purpose  Category (corresponding with the table above) Category of Recipient 
Auditing that is related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards. 

Category A

Category D

Category F

Category G

 Advertising networks; data analytics providers; social media networks. 
Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes.

Category A

Category B

Category F

 Subsidiaries, operational partner, security and fraud prevention providers, operating systems. 
Debugging to identify and repair errors that impair existing intended functionality

Category A

Category B

Category F

 Analytic providers, operational partner, security and fraud prevention providers, operating systems.
Short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

Category A

Category F

Category G

 Advertising networks; data analytics providers; social media networks.
Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider NA NA
Undertaking internal research for technological development and demonstration.

Category A

Category F

Category G

 cloud and hosting providers, SaaS platforms for task management and development, customer support and optimization tools. 
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned or controlled by the business.

Category A

Category F

Category G

 Developers, operating systems, cloud and hosting providers, SaaS platforms for task management and development, customer support and optimization tools. 
Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the Personal Information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with Personal Information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you.

Category A

Category F

Category G

 Advertising networks; data analytics providers; social media networks. Marketing service providers and technical platforms such as CRM and tracking tools (tracking within the Properties). 
Advancing our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.

Category A

Category F

Category G

 Subsidiaries and affiliates; operating systems and platforms, Advertising networks; data analytics providers; social media networks.


5) Sale or Share of Personal Information 

In the preceding twelve (12) months, we did not “sell” or “share” any Personal Information. 

6) Children Under the Age of 16

We do not knowingly collect information from children under the age of 16.

 

7) Data Retention

In general, we retain the Personal Information we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you express your preference to opt-out, where applicable. 

The retention periods are determined according to the following criteria:

  1. For as long as it remains necessary in order to achieve the purpose for which the Personal Information was initially processed. 
  2. To comply with our regulatory obligations. 
  3. To resolve a claim, we might have or a dispute with you, including any legal proceeding between us, until such dispute will be resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.

Please note that except as required by applicable law, we will not be obligated to retain Personal Information for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.

 

PART II: EXPLANATION OF YOUR RIGHTS UNDER THE CCPA AND HOW TO EXERCISE THEM

(A) YOUR RIGHTS UNDER THE CCPA [INCLUDING, VCDPA, CPA AND NEVADA PRIVACY LAWS] AND HOW CAN YOU EXERCISE THE RIGHTS?

If you are a California, Virginia, Colorado or Nevada residents, you may exercise certain privacy rights related to your Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law. We may limit our response to your exercise of these privacy rights as permitted under applicable law, all as detailed herein: 

The Table below applies to California, Virginia, Colorado Residence (Nevada related rights are separately detailed below):

California Privacy Right Details 
The right to know what Personal Information the business has collected and access rights.  

The right to know what Personal Information the business has collected about the consumer, including the categories of personal information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom the business discloses Personal Information, and the specific pieces of Personal Information the business has collected about the consumer.

You can exercise your right by reviewing this Notice and the Privacy Policy, in case you would like to receive the specific pieces please fill in this form to and sending it to us by mail.
Deletion Rights.

The right to delete Personal Information that the business has collected from the consumer, subject to certain exceptions. 

You can exercise your right to deletion by filling in the following form to and sending it to us by mail.

We reserve the right to reject such request under certain circumstances, and will inform you of the basis for the denial, which may include, but is not limited to, ensure the security and integrity, provide the services, a legal obligation, etc. 
Correct Inaccurate Information The right to correct inaccurate Personal Information that a business maintains about a consumer. At any time, you may correct any of the account data we collect by filling in the following form to and sending it to us by mail.
Opt-Out of Sharing for Cross-Contextual Behavioral Advertising (“CCBA”) or from selling, where applicable. 

You have the right to opt-out of the “sharing” of your personal information for “cross-contextual behavioral advertising,” often referred to as “interest-based advertising” or “targeted advertising.”, you may opt out through the “do not sell or share my personal information” button available within the Websites’ footer. You may opt out through device settings (opt-out from tracking AAID, ADID, please see the following for information applicable to all devices: https://thenai.org/opt-out/mobile-opt-out/). 

Further, you can opt-out from interest-based advertising, CCBA, by using Self-Regulatory Program for Online Behavioral Advertising such as: 

Digital Advertising Alliance’s (“DAA”): https://www.aboutads.info/choices  and https://www.aboutads.info/appchoices, and the Network Advertising Initiative (“NAI”): https://www.networkadvertising.org/choices. 

Last, you can join Global Privacy Control (“GCP”) for opting out generally through your browser: https://globalprivacycontrol.org/. Our Consent Management Platform (“CMP”) will know to read all of these signals and ensure compliance with your request. 
Non-Discrimination The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicants, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights, denying a consumer goods or services, charging different prices or rates for goods or services, providing you a different level or quality of goods or services, etc. We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information.
Data Portability You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format. In case you would like to receive the specific pieces, you can exercise your right by filling in the following form to and sending it to us by mail.

 

Note: You may only exercise this right, unless legally required otherwise, twice within 12 years.

 

(B) Authorized Agents 

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

 

(C) Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require additional time (up to an additional forty-five (45) days), we will inform you of the reason and extension period in writing by mail or electronically, at your option. If we determine that the request warrants a fee, we will tell you why we made such decision and provide you with a cost estimate before completing your request.

For Virginia Residence: We may require specific information from you to help us confirm your identity and process your VCDPA request. If we denied a request, you may appeal our decision, and within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform. 

 Part III: Other State Laws and Rights  

Do Not Track Settings: Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we so not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us. 

Notice to Virginia Residents: The VCDPA provides Virginia residents with the right to receive certain disclosures regarding the Personal Information we process about them. This CCPA Notice provided any and all needed disclosures under the VCDPA. If you are a Virginia resident, the VCDPA grants you the right to: (1) confirm whether or not we are processing your Personal Information and access such Personal Information; (2) correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of your Personal Information; (3) delete Personal Information you have provided or we have obtained about you; and (4) obtain a copy of your Personal Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means. The rights and how to exercise them are detailed under this CCPA Notice and are applicable for Virginia residence as well and you may exercise your rights as detailed above. 

Notice to Nevada Residents: Nevada law allows Nevada residents to opt out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We currently do not sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and will record your instructions and incorporate them in the future if our policy changes. You may send opt-out requests to privacy@aulder.com . 

 

CONTACT US: 

By email: privacy@aulder.com

Our address is: 21 W 38th St 11th floor, New York, NY 10018 United States

Phone (toll free number): (888) 831-2962


UPDATES:

This notice was last updated in May 2023. As required under the CCPA, we will update this CCPA Notice at least every 12 months. The last revision date will be reflected in the “Last Updated” heading at the top of this CCPA Notice.