Epsilon3 Privacy Policy

Effective date: - September 25, 2024

1. Introduction

Welcome to Epsilon3.

Epsilon3, Inc. (“us”, “we”, or “our”) operates Epsilon3.io (the “Site”)

We’ll refer to all of the products and services we provide through the Site as the “Service” or “Services”.

We’ll refer to you, the person or entity accessing our Site or using our Services, as “you” or “your”.

Our Privacy Policy governs your visit to Epsilon3.io, and explains how we collect, safeguard and disclose Personal Data that results from your use of our Service.

We use your Personal Data to provide and improve Service. By using Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

By accessing or using our Site or Service, you consent to the collection and use of your Personal Data as set forth in this Privacy Policy.

2. Definitions

The following terms shall have the meaning given to them below when used in this Privacy Policy.

PERSONAL DATA means any information relating to an identified or identifiable natural person or that constitutes personal information or personal data under applicable law.

USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device). Please see the section of this Privacy Policy titled “Cookies” below for more information on how we use Cookies.

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data is processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

3. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Site and Service to you. Please note that this Privacy Policy applies to Personal Data we collect in our role as a Data Controller. We also process Personal Data on behalf of other Data Controllers to which we provide Services. This Privacy Policy does not apply to such Personal Data; the policies of the Data Controllers on whose behalf we process such Personal Data apply to the processing of that data. Any requests or complaints regarding such data processing should be submitted to the applicable Data Controller; if we receive a request in connection with such processing we will forward to the applicable Data Controller for a response.

4. Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain Personal Data, which may include, but is not limited to:

(a) Your email address

(b) Your first name and last name

(d) Your and/or your company’s phone number

(e) Information you choose to provide us through our Service

(f) Usage Data, including server logs which include the IP address of every request to our server, which is collected through the use of Cookies.

If you apply for job with us through the Site, we collect your resume, full name, email, phone, current company, various URLs (LinkedIn, Twitter, GitHub, Portfolio, or others), your citizenship, education background, certifications, and employment history.

Chat Function

Our Site has an automated chat function that you can communicate with. This chat function will collect various information about you (name, email, company name) and may record your communications with the chat function. By using the chat function, you consent to recording of your communications.

Usage Data

We may also collect Usage Data.

This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address, a unique numerical address assigned to a computer as it logs on to the internet), browser type, browser version, operating system, the web page that you were visiting before accessing our Site, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, the links on our Site that you clicked on, and other diagnostic data.

When you access Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.

You can enable or disable location services when you use our Service at any time by way of your device settings.

Cookies

We use cookies and similar tracking technologies (“Cookies”) to track the activity on our Service and we hold certain information. For more detailed information on our Cookies see our Cookie Policy. You can set your Cookies setting at any time by clicking on the Manage Cookies link.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Site. We use cookies to understand and save your preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may also use Cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent Cookies, session Cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Here are the categories of Cookies we use:

· Necessary

These are Cookies are required to enable core Site functionality and to remember user preferences and choices, such as language preferences or customized settings. You cannot turn these Cookies off.

· Performance and Analytics

These Cookies provide quantitative measures of Site visitors. With the usage of these Cookies, we are able to count visits and traffic sources to improve the performance of our Site. You can opt-out of these Cookies by going to the Cookies Setting.

Advertising

These Cookies are used by advertising companies to serve ads that are relevant to your interests.

These Cookies allow us to track browsing habits as you visit the Site. Based on your browsing history and with your permission, we may use third-party advertising partners who can then display to you a relevant ad when you are on a third-party site such as a social media platform. Within these Cookies, we may also know your precise location such as latitude, longitude, GeoIP, and other location-specific information. You can opt-out of these Cookies by going to the Cookies Settings. We may also collect information via standard server logs or clear GIFs (also known as “Web beacons”). Web beacons and pixel tags are images embedded in a webpage or email for the purpose of measuring and analyzing usage and activity. We, or third-party service providers acting on our behalf, may use web beacons and pixel tags to help us analyze usage and improve our functionality and serve targeted advertising. Social media tools, like widgets and plug-ins, may be offered so you can share information on other sites such Facebook and Twitter. These interactive mini-programs collect your IP address, record the pages you visit on our Site, and set cookies that will enable the widget to function properly. Your interactions with these widgets are governed by the privacy policy of the company providing them, not by this Privacy Policy. If we link or associate any information gathered through passive means with Personal Information, we treat the combined information as Personal Information under this Privacy Policy. Otherwise, we use information collected by passive means in non-personally identifiable form only. You can opt-out of these web beacons by clicking the Manage Cookies link.

5. Use of Data; Opting Out

Epsilon3, Inc. uses the collected Personal Data for various purposes:

(a) to provide and maintain our Service;

(b) to notify you about changes to our Service;

(d) to provide customer support;

(e) to gather analysis or valuable information so that we can improve our Service;

(f) to monitor the usage of our Service;

(g) to detect, prevent and address technical issues;

(h) to fulfill any other purpose for which you provide it;

(i) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

(j) to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;

(k) to provide you with news, special offers and general information or marketing or promotional materials about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information; We may use your Personal Data to contact you with newsletters, and other information that may be of interest to you and to serve you targeted advertising.;

(l) to process job applications and for employment purposes;

(m) in any other way we may describe when you provide the Personal Data;

(n) for any other purpose with your consent.

We may also use your Personal Data where necessary for us to comply with a legal obligation, including to share information with government and regulatory authorities when required by law or in response to legal process, obligation or request. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose your Personal Data to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.

Please note that “Do Not Track” options will not affect how we use your Personal Data. Although we do our best to honor the privacy preferences of our customers, we are not able to respond to Do-Not-Track signals from your browser at this time, except for preference signals as required by California law. As discussed above, we track websites and app usage information through the use of cookies for analytic and internal purposes only. Because we do not collect this information to track you across websites or apps over time, your selection of the “Do Not Track” option provided by your browser will not have any effect on our collection of cookie information for analytics or internal purposes.

You may opt out of receiving any, or all, email communications from us by following the unsubscribe link in any such communication.

6. Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will also retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

7. Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. It is important to note that the privacy laws in the United States may not be as comprehensive as those in other countries such as the European Union or the United Kingdom.

Personal Data that we collect from you may be processed by staff operating outside the U.S. who work for us or for one of our suppliers. For example, such staff may be engaged in the processing of an order for our Services, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

8. Disclosure of Data

We may disclose personal information that we collect, or you provide:

(a) Disclosure for Law Enforcement.

Under certain circumstances, 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.

(b) Business Transaction.

If we or our subsidiaries are involved in a merger, acquisition or asset sale, or a bankruptcy, your Personal Data may be transferred to other parties in connection with such transactions.

(i) to our subsidiaries and affiliates;

(ii) to contractors, service providers, and other third parties we use to support our business;

(iii) to fulfill the purpose for which you provide it;

(iv) for the purpose of including your company’s logo on our website;

(v) for any other purpose disclosed by us when you provide the information;

(vi) with your consent in any other cases;

(vii) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

9. Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

10. Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. – See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj.

If you are a resident of the United Kingdom (UK), you have certain data protection rights under the UK GDPR – see more at https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/.

We explain your rights as a resident of the EU, EEA or UK in subsection A below.

The Data Controller for your personal data is

Epsilon3, Inc., a Delaware Corporation

Registration No. 4943506

2708 Wilshire Blvd. #350

Santa Monica, CA 90403

424-209-7005

support@epsilon3.io

Our data representative for the EU:

Instant EU GDPR Representative Ltd
Adam Brogden
contact@gdprlocal.com
+ 353 15 549 700
2 12A Lower Main Street, Lucan Co. Dublin K78 X5P8 Ireland
Reporting link to make any requests under GDPR: https://epsilon3inc.gdprlocal.com/eu

Our data representative for the United Kingdom:

GDPR Local Ltd
Adam Brogden
contact@gdprlocal.com
+ 441 772 217 800
GDPR Local Ltd 1st Floor Front Suite 27-29 North Street, Brighton England BN1 1EB
Reporting link to make any requests under UK GDPR: https://epsilon3inc.gdprlocal.com/uk

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data as required under the GDPR and UK GDPR.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at support@epsilon3.io.

A. YOUR DATA SUBJECT RIGHTS UNDER THE GDPR AND UK GDPR

If you are a resident of the EU or the UK, You have the following data protection rights if we are acting as a Data Controller of your Personal Data:

(a) the right to access, update or to delete the Personal Data we have on you;

(b) the right of rectification. You have the right to have your Personal Data rectified if that Personal Data is inaccurate or incomplete;

(d) the right of restriction. You have the right to request that we restrict the processing of your Personal Data in certain circumstances;

(e) the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;

(f) the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your Personal Data. You can withdraw consent by emailing us at support@epsilon3.io. We generally do not rely on consent to process Personal Data.

Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not be able to provide Service without some necessary data.

If we collected your Personal Data in our capacity as a Data Processor for our customers, we will direct your request to our customers for a response.

B. PRIVACY STATEMENT

Epsilon3 collects Personal Data in the following ways:

· Directly from you such as when your provide us your Personal Data such as when you use our Services, apply for a job, fill out a contact us form, communicate with us through our chat function, or you are acting on behalf of a company is contracting to use our Services.

· Indirectly from your company if we are providing Services to your company.

· Automatically through the use of cookies and tracking technologies as described in Section 4 above.

Epsilon3 will primarily use the Personal Data we collect as Data Controller to provide Services to you or your company, to respond to your requests and inquiries, to process your job application, and if you have opted-in, to provide you information about our products and services. We may use your Personal Data for other purposes as set forth in Section 5 above.

If we are collecting Personal Data in our capacity as a Data Processor, we only collect the Personal Data on behalf of our customers to provide Services to those customers. We store and process the Personal Data as required by our customers.

We store all Personal Data for as long as necessary to provide the Services to you and to the extent required by applicable laws. Please see Section 6 for more information.

In our capacity as a Data Controller, we generally share your Personal Data with our service providers, who can access your Personal Data to the extent necessary to provide services. In our capacity as a Data Processor, we generally share your Personal Data with our customers and our service providers. However, in both cases, we may share Personal Data in other circumstances as described in more detail in Section 8 above. In addition, our employees can access your Personal Data to the extent required to provide the Services and perform their job duties; those employees are under a duty of confidentiality with respect to your Personal Data.

We implement appropriate technical and organizational measures in compliance with the GDPR and UK GDPR to ensure a level of security appropriate to the risk, including inter alia as appropriate:

· the pseudonymisation and encryption of personal data;

· the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;

· the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident; and

· a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.

C. LEGAL BASES FOR PROCESSING OF PERSONAL DATA

We rely on the following legal bases to process your Personal Data in our capacity as Data Controller:

· To enter into and perform contracts, such as to provide the Service;

· To comply with legal obligations, such as to provide information to a government regulator; and

· For our legitimate interest, such as to develop and improve our Site and Service and for marketing purposes.

If we rely on consent, we will notify you of the purposes for the consent. Please note that we generally do not collect special categories of Personal Data that require consent.

D. COMPLAINTS

If you are an EU or EEA resident, you have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA). If you are a UK resident, you have the right to complain to the Information Commissioner’s Office. See https://ico.org.uk/make-a-complaint/ for more information.

11. Your Data Protection Rights under the California Consumer Privacy Act

The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) affords consumers residing in California certain rights with respect to their personal information as that term is defined in the CCPA. If you are a California resident, this section applies to you.

(a) Categories of Personal Data Collected: In the preceding 12 months, we have collected the following categories of personal information: identifiers, characteristics of protected classifications under California or U.S. law, professional and employment-related information, education information, commercial information, internet and electronic network activity, inferences drawn about your preferences, and other categories of personal information that relate to or are reasonably capable of being associated with you. For examples of the precise data points we collect, please see “Types of Data Collected” above.

(b) Business or Commercial Purpose for Collecting and Using Data: We collect Personal Data for the business purposes described in the “Use of Data” section above.

(c) Categories of Sources of Personal Data: We collect personal information from you and from our customers as described above.

(d) Categories of Personal Information Disclosed and Categories of Third-Party Recipients: In the preceding 12 months, we have disclosed identifiers, commercial information, and internet and electronic network activity to the following categories of recipients: cloud service providers, consultants, data analytics providers, internet service providers, data storage providers, and operating systems and platforms.

(e) Sale or Sharing of Personal Information (as defined by the CCPA): We do not sell your personal information; we may share your personal information for cross-context behavioral advertising with social media and advertising platforms.

Your Consumer Rights as a California Consumer

As a California resident, you have the following rights regarding your personal information:

· The right to know what personal information we have collected about you, 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 we disclose personal information, and the specific pieces of personal information that we have collected about you.

· The right to delete personal information that we have collected from you, subject to certain exceptions.

· The right to correct inaccurate personal information that we maintain about you.

· If we sell or share personal information, the right to opt-out of the sale or sharing of their personal information by us. We do not sell your personal information, but may share your personal information for cross-context behavioral advertising. To opt-out of such sharing, click the Do Not Sell or Share My Personal Information link at the bottom of the Site.

· If we use or discloses sensitive personal information for reasons other than those set forth in section 7027, subsection (m), the right to limit the use or disclosure of sensitive personal information by us. We do not offer this right because we do not use or disclose sensitive personal information to infer characteristics or for purposes other than those specified in section 7027, subsection (m).

· The right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights.

We do not sell or share personal information of individuals under the age of 16.

You may make a request by emailing us at support@epsilon3.io or visiting this page. We will verify your request by asking you to provide information sufficient to confirm your identity, such as your name, email address, and information about your interactions with us. If you would like to use an authorized agent to exercise your rights, we may request evidence that you have provided such agent with power of attorney, or that the agent otherwise has valid signed authority to submit requests on your behalf, and ask that you verify your identity directly with us. If you are an authorized agent seeking to make a request, please write to support@epsilon3.io.

12. Other States

Residents of other states may have data privacy rights, which may include the right to access, the right to correct, the right to delete, the right to opt-out of sale, and the right to opt-out of automated decisionmaking, profiling and targeted advertising, right to non-discrimination in the exercise of these rights, and the right to appeal our decision denying any requests. If you believe you have such rights, and wish to exercise them, please email us at support@epsilon3.io. If we are subject to state laws requiring a response, we will verify your request by asking you to provide information sufficient to confirm your identity, such as your name, email address, and information about your interactions with us.

13. Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

RB2B

Cookies may be used by RB2B to identify your email and/or LinkedIn profile. To prevent RB2B from using your information for marketing purposes, you can opt-out here: https://app.retention.com/optout

14. Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en.

We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

Mixpanel

Mixpanel is provided by Mixpanel Inc.

You can prevent Mixpanel from using your information for analytics purposes by opting out. To opt-out of Mixpanel service, please visit this page: https://mixpanel.com/optout/.

For more information on what type of information Mixpanel collects, please visit the Terms of Use page of Mixpanel: https://mixpanel.com/terms/.

15. CI/CD tools

We may use third-party Service Providers to automate the development process of our Service.

GitHub

GitHub is provided by GitHub, Inc.

GitHub is a development platform to host and review code, manage projects, and build software.

For more information on what data GitHub collects for what purpose and how the protection of the data is ensured, please visit GitHub Privacy Policy page: https://help.github.com/en/articles/github-privacy-statement.

16. Payments

We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (for example, payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their privacy policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

Stripe:

Their Privacy Policy can be viewed at: https://stripe.com/us/privacy.

17. Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

18. Children's Privacy

Our Services are not intended for use by children under the age of 16 (“Children”).

We do not knowingly collect personally identifiable information from Children under 16. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

19. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

20. Contact Us

If you have any questions about this Privacy Policy, please contact us by visiting this page on our website: https://www.epsilon3.io/contact.