Consumer Edge Holdings, LLC PRIVACY POLICY

Last updated: July 27, 2026

Consumer Edge Holdings, LLC, and its affiliates (collectively, “Consumer Edge,” “we,” “us,” or “our”), know that data privacy is important to you. We have created this privacy policy (the “Privacy Policy”) to describe how we collect and process information from and about you through our website located at https://www.ConsumerEdge.com (“Site”) and any other website owned and operated by us and related online and offline services, online portals and digital properties (collectively, the “Services”). We have the utmost respect for your data privacy, so this Privacy Policy also explains steps you can take to manage your personal information in connection with the Services.

By accessing or using our Services or otherwise manifesting your assent to this Privacy Policy, you agree to be bound by this Privacy Policy and the accompanying Terms of Use. If you are accepting this Privacy Policy on behalf of your employer or another organization, you hereby certify that you are authorized to bind such party to the terms of this Privacy Policy. If you do not agree to (or cannot comply with) all of the terms of this Privacy Policy or any other terms of the Terms of Use you may not access or use the Services. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use. If you are under the age of 18, you may not use our Services.

Client Portal: Consumer Edge allows its clients (“Clients”) and their authorized users (“Authorized Users”) to choose their own usernames, passwords, and other identification criteria (“Credentials”) to enter the client portal (“Client Portal”) available on the Site. Clients enter the Client Portal for the purpose of accessing and using products purchased from Consumer Edge (“Products”) pursuant to separately executed agreements (the “Client Agreements”). The Client Portal is separate and apart from the Site.

This Privacy Policy will help you understand the following:

ARTICLE I. THE INFORMATION WE COLLECT, PROCESS AND SHARE

While providing the Services, we may collect or receive the following types of information about you, which may include personal information.

1. Contact Information

We collect contact information through our Services, such as your name, email address, phone number, business contact data (e.g., title, company name, office phone number and company email address), employer or organization, job title, account identifier, subscription information, access permissions, organization-administrator information and any information you provide in messages to us, requests to contact you, and other interactions (collectively, “Contact Information”). We use Contact Information for the purpose it was provided such as receiving our newsletter and/or marketing emails, responding to your questions such as inquiries about our products and services, conducting demonstrations, providing resources available on our Site such as white papers and related commentary, or providing the Services.

2. Client Portal Credentials and Use of the Services

Consumer Edge retains the Credentials under this Privacy Policy for the sole purpose of allowing Clients to enter the Client Portal. Clients and their Authorized Users are solely responsible for the security, confidentiality, and use of their Credentials for any purpose. Client will notify Consumer Edge immediately if (i) any Credentials are lost, stolen, or missing, (ii) Client revokes the authority of an Authorized User to access the Client Portal, or (iii) an Authorized User ceases to be employed or engaged by Client for any reason. Consumer Edge reserves the right to block entry to the Client Portal by any Client, Authorized User, or anyone seeking to use their Credentials, at its sole discretion.

3. Information obtained automatically from your online activity

Except for Google Analytics (see below), when Clients or visitors access or use the Site we only use cookies that are necessary for our Site to operate properly. Cookies are small packets of data that a website places on your device for such purpose, and necessary cookies may be placed without your consent. If you do not wish to allow non-essential cookies, you may decline them through our consent tool or disable them in your browser settings; please consult your browser’s documentation for instructions. If you disable strictly necessary cookies, the Site may not operate properly.

Our Site uses strictly necessary cookies, which are required for the Site to function and may be placed without your consent. We also use non-essential cookies and similar tracking technologies, including analytics cookies (such as Google Analytics, described below) and, where applicable, functionality and advertising cookies. In jurisdictions that require prior consent for non-essential cookies and trackers—including the EU/EEA, the UK, some US states, and the Canadian province of Quebec—these non-essential cookies are deployed only after you provide prior opt-in consent through our cookie banner / consent management tool, where “Reject All” is presented as prominently as “Accept All.” You may withdraw your consent or change your preferences at any time through the same tool. In addition to cookies, we may use browser storage to temporarily capture campaign attribution data (such as UTM parameters) when you arrive at our Site via a marketing link should this be permissible by law in your jurisdiction. When used, this information records only the marketing channel or campaign that directed you to the Site, and that information is stored in your browser’s temporary memory for the duration of your current session only and is automatically deleted when you close the browser tab. Unlike cookies, such storage does not persist between sessions and is not accessible to third parties. If you submit a form on our Site during that session, the stored attribution data is transmitted to us as part of your form submission and is used solely to understand which of our marketing campaigns generated your inquiry. No personal information is collected through browser storage beyond what you voluntarily provide through the form itself.

4. Information Obtained From Other Sources

Social Media: We maintain a presence on LinkedIn, and other social media and third-party sites, including our accounts, pages, and related activities. We may collect personal information when you visit or use social media, including when you access our Site from social media. We will do so in accordance with the terms of use and privacy policies of those sites, mobile apps and applicable law. For example, we may collect the information you shared on our social media pages through an application or form, which will have a link to this Privacy Policy. Personal information may also be collected by the third-party social media sites that host our social media pages. These sites may provide aggregate information and analysis to us about visitors’ use of our social media pages. This allows us to better understand and analyze our user growth, general demographic information about the users of these pages, and interaction with the content that we post. Overall, this information may be used to help us understand the types of visitors and users of our social media pages and use of the content. This Privacy Policy does not cover personal information collected by such third-party social media sites. For more information on their privacy and security practices please review the privacy policies and terms of use on their respective websites.

Acquired from Third Parties: We may purchase or receive information from third parties including information related to you. We may combine your information with such acquired information and use it to improve your experience and/or personalize our Services and content.

5. Information Obtained From Third-Party Analytics Services

We may use third-party analytics services such as Google Analytics to evaluate your access and use of the Services, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to device and internet usage such as: the type of device, the advertising identifier, the operating system and version, carrier and network type; IP addresses (which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device); browser type and language; referring and exit pages and URLs; date and time of access; the content viewed; the amount of time spent on particular pages; what features of the Services are used or visited; details of any purchases; click stream information; and geolocation data. These third-party analytics services use cookies and other technologies to collect, analyze and provide us with the data and related analytics. By accessing or using the Services, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. The information used by such analytics services is generally at the aggregate level. Google may associate such data with visitation information collected from our Site.

We may add to or change these third-party analytics services from time to time. For more information on our analytics services, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Services.

For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics.

6. Information Use and Sharing

We may use and share your personal information as set forth below:

  • To operate and administer our business including:
    • Conducting audits including audits regarding compliance with the CCPA (as defined below) and other applicable laws and standards;
    • Undertaking internal research for technological development and demonstrations;
    • Verifying, analyzing, and maintaining the quality of the Services and implementing improvements;
    • Providing customer support, troubleshooting problems, debugging the Services, and helping to ensure the security and integrity of the Services and the business;
    • Managing Authorized User’s access and designated administrators;
    • Contacting you as per your request to respond to questions, deliver our newsletter, provide information regarding new or improved products and services, and/or otherwise communicate with you; and
    • Engaging in marketing and advertising, and evaluate our efforts, provided that, where required under applicable law, we will obtain your prior opt-in consent to send electronic marketing communications.
  • To third-party contractors and service providers that provide services to us in the operation of our business, such as marketing and advertising companies, consulting service organizations, IT and cloud service providers;
  • To process aggregated, anonymous, user statistics and other information and disclose such data and information to third parties for lawful purposes;
  • To protect and secure our rights and the rights of our Clients;
  • To share with our parent company, subsidiaries, affiliates and/or other companies under common control with us;
  • To fulfill our legal and regulatory obligations under applicable law, such as to comply with a subpoena, or similar legal process, protect or enforce our rights, investigate a security incident, or respond to a government, law enforcement, or judicial request;
  • To assess or complete a corporate sale, merger, reorganization, sale of assets, dissolution, investment, or similar corporate event where we expect that your personal information will be part of the transferred assets;
  • Any results from our Services and other requested content to a MCP that invoked the request;
  • Results sent to the MCP post or associated artificial intelligence (“AI”) services for the use of Client Content for context and display it to the user of our Services;
  • To service providers that support hosting, storage, database services, AI model inference, security, monitoring, logging, analytics, communications, customer support and other service operations;
  • To authenticate users, apply permissions, and maintain MCP connections;
  • To receive, validate, execute, and respond to tool calls and other authorized requests;
  • To retrieve, analyze, format, and return Consumer Edge data and other authorized content;
  • To maintain session or conversation history and user settings where the feature or Client Agreement provides for this;
  • To operate, monitor, maintain, test, and improve the reliability, accuracy, usability, and performance of the MCP;
  • To provide implementation assistance, customer support, and troubleshooting;
  • To detect, investigate, and prevent fraud, abuse, unauthorized access, attacks, and violations of applicable terms;
  • To enforce access limits, protect Consumer Edge and Client rights, and maintain audit records;
  • To produce aggregated service statistics and capacity planning information;
  • To administer the Client relationship, provide service communications, and manage billing or entitlements;
  • To comply with law, legal process, regulatory obligations, and the Client Agreement;
  • To carry out another purpose disclosed when the information is collected or authorized by the Client; and
  • Otherwise with your consent.

For our Services, Consumer Edge may process authentication credentials, authorization tokens, granted scopes, connection identifiers, model context protocol (“MCP”), Client name and version, protocol version, authorization events, and information needed to validate and maintain a connection. Clients and Authorized Users should not place passwords, private keys, or other secrets in free-text tool inputs.

“Client Content” means all information a Client or Authorized User submits, provides access to, or causes a MCP to transmit to Consumer Edge through the Services. Client Content includes without limitation:

  • questions, instructions, tool calls, arguments, filters, parameters, and selected context;
  • merchant, market, cohort, geography, date-range, product, or other query criteria;
  • files, text, datasets, records, or other content submitted or made available to a MCP tool;
  • conversation or session information transmitted by a MCP;
  • feedback, ratings, annotations, corrections, and support communications; and
  • results, summaries, tables, charts, files, structured data, citations, or other outputs generated or returned through the MCP.

Other than as set forth in this Privacy Policy, the Services are not designed for the submission of any personal information and personal information of any kind is prohibited from being entered into the Services, Client Content or products. Any Client or Authorized User that submits, in connection with the Services, any personally identifiable information, Social Security numbers, payment-card data, account passwords, health information, biometric information, or other sensitive or regulated information may be in breach of their Client Agreement.

7. Modifying Information and Communications Preferences

You may correct or update the personal information that Consumer Edge has about you by contacting us as directed in ARTICLE VI of this Privacy Policy;

You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” hyperlink located on the bottom of any of our marketing emails or by contacting us as directed in ARTICLE VI of this Privacy Policy.

We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely modify information in our databases. We will retain and use your information as necessary to comply with our legal and/or regulatory obligations, resolve disputes, and enforce our agreements.

8. How We Protect Your Information

We take commercially reasonable steps to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, emails sent to or from the Site may not be secure, and you should therefore take special care in deciding what information you send to us via email.

9. Children’s Privacy

Our Services are not directed at or structured to attract children under the age of 18, and we do not knowingly collect personal information from any person under the age of 18 without parental consent. We do not knowingly use, disclose, sell, or share for targeted advertising the personal information of children, and we do not condition a child’s participation in an activity on the disclosure of more personal information than is reasonably necessary. If an individual under the age of 18 has provided us with personal information, a parent or guardian of that child may contact us and request that such information be deleted, and we will take reasonable steps to delete that information as soon as reasonably possible.

10. External Websites and Third Parties

Unless explicitly stated otherwise, our Privacy Policy addresses only our use and disclosure of information we collect from and/or about you in your interactions with the Services. If you choose to disclose information to third parties, the use and disclosure restrictions contained in this Privacy Policy will not apply, as we do not control the privacy policies of such third parties, nor are we subject to them.

Consumer Edge may allow certain hyperlinks to third-party websites, mobile apps or other online resources to appear on the Site (“External Websites”). If you click on a link for any External Site, you will be redirected to a third-party site. The information collected by such third parties or that you choose to provide, is governed by the third-party site’s privacy policy and practices. We have no control over the privacy policies or practices, the content, or the products and services, of any External Websites we provide or allow hyperlinks on our Site. As such, we are not responsible for the content or the privacy policies of those External Websites. You should check the applicable third-party privacy policy and terms of use when visiting any External Websites.

11. Do Not Track

Some web browsers transmit legacy “Do Not Track” (“DNT”) signals. Because there is no common industry or legal standard for recognizing or honoring DNT signals, our Site does not currently respond to browser DNT signals. However, we do recognize and honor opt-out preference signals such as the Global Privacy Control (“GPC”). Where you use a browser or extension that transmits the GPC signal, we will treat it as a valid request to opt out of the sale or sharing of personal information (and, where applicable, targeted advertising) for that browser or device, and—where we can associate the signal with a known account—for the associated consumer, to the extent required by applicable law.

12. Notice to Nevada Residents

We do not sell your personal information as defined under Nevada law. Nonetheless, if you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties. You can exercise this right by contacting us under ARTICLE IV of this Privacy Policy. We may request additional information to assist with locating your personal information in our records. If we are unable to do so, we may decline your request.

13. Residents of Colorado.

Residents of Colorado may refer to ARTICLE II to view more information regarding each category of personal information we process, the purposes for which we process each category, and the categories of entities to whom the personal information is disclosed. Residents of Colorado may refer to Article II to view more information about the categories of personal information that are ‘sold’ (as defined in Colorado law) or used for ‘targeted advertising’ (as defined in Colorado law, defined as ‘sharing’ by the CCPA). Please note that we do not engage in profiling that produces legal or similarly significant effects.

14. Additional U.S. State Privacy Rights

Residents of U.S. states that have enacted comprehensive consumer privacy laws—including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Florida, Iowa, Delaware, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Kentucky, Rhode Island, and Indiana, among others as their laws take effect—have rights regarding their personal data. Depending on your state of residence, these may include the right to confirm whether we process your personal data and to access it; to correct inaccuracies; to delete personal data; to obtain a portable copy; and to opt out of (i) the sale of personal data, (ii) targeted advertising, and (iii) certain profiling in furtherance of decisions that produce legal or similarly significant effects. Where we process sensitive data, we do so only with your consent or, in states that require it, subject to your right to opt out.

To exercise these rights, submit a request as described in ARTICLE VI. If we decline your request, you have the right to appeal by contacting us at legal@consumer-edge.com; if your appeal is denied, you may contact your state Attorney General. We recognize universal opt-out mechanisms, such as the Global Privacy Control, in states that require them. Consumer Health Data: if you are a resident of Washington (My Health My Data Act), Connecticut, or another state with a consumer-health-data law, additional protections apply to health-related data, including any health inferences we may derive—we process such data only with your consent, do not sell it without separate authorization, maintain a separate Consumer Health Data Privacy Policy where required, and do not use geofencing around health-care facilities.

15. Contact Us

Questions or privacy requests relating to this Site or our Services may be directed to:

Email: legal@consumer-edge.com

Postal address: Consumer Edge, 140 East 45th Street, New York, NY, 10017

Attn: Legal

Second Email: privacy@consumer-edge.com

ARTICLE II. CCPA NOTICE TO CALIFORNIA RESIDENTS

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”) gives California residents (“consumers”) and households additional rights regarding their personal information. This notice (the “CCPA Notice”) supplements our Privacy Policy. We also disclose the retention period (or the criteria used to determine it) for each category of personal information we collect; honor opt-out preference signals such as the Global Privacy Control; and, where we use automated decision-making technology or profiling that produces legal or similarly significant effects, we provide the disclosures and opt-out/appeal rights required by the CCPA and its implementing regulations as those obligations take effect.

1. Collection, Use, Disclosure, and Retention of California Residents’ Personal Information

If you are a California resident, the CCPA requires us to provide you with the following additional information about: (1) the purpose for which we use each category of “personal information” (as defined in the CCPA) we collect; and (2) the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) “share” personal information for “cross-context behavioral advertising,” and/or (c) “sell” such personal information. Under the CCPA, “sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites, and “selling” is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration. Our use of third-party online advertising services, which are described in detail above, may result in the disclosure of online identifiers (e.g., cookie data, IP addresses, device identifiers, and usage information) in a way that may be considered a “sale” or “sharing” under the CCPA.

The following chart provides information about our practices in the 12 months leading up to the effective date of this Privacy Policy:

Categories of information collected Purposes for which we used the information Categories of entities to whom we disclose the information for business and operational purposes Categories of Third Parties to Which We “Share” and/or “Sell” this Personal Information for Advertising/Analytics Purposes
Identifiers, such as name, email address, phone number, username, IP address, and device identifiers.
  • Operate, maintain, and provide the Services;
  • Handle your registration, inquiries, and requests;
  • Communicate with you;
  • Facilitate transactions;
  • Personalize your experience and our communications with you;
  • Advertising and marketing;
  • Analyze and understand use of the Services;
  • Provide seminars and webinars;
  • Improve our products and services; and
  • Security, fraud prevention, and legal compliance.
  • Vendors;
  • Business partners;
  • Ad networks, advertising providers, and analytics providers;
  • Lead generation providers;
  • Affiliates;
  • Customers with whom you are affiliated;
  • Entities for legal and security purposes;
  • Entities for sales or transfer of business or assets; and
  • Others with your consent
  • Online advertising and analytics partners; and
  • Lead generation providers
Professional or employment-related information, such as company name, position, title, business address, business email address and phone, and the size, location, and needs of your company.
  • Operate, maintain, and provide the Services;
  • Handle your registration, inquiries, and requests;
  • Communicate with you;
  • Facilitate transactions;
  • Personalize your experience and our communications with you;
  • Advertising and marketing;
  • Analyze and understand use of the Services;
  • Provide seminars and webinars;
  • Improve our products and services; and
  • Security, fraud prevention, and legal compliance.
  • Vendors;
  • Business partners;
  • Ad networks, advertising providers, and analytics providers;
  • Lead generation providers;
  • Affiliates;
  • Customers with whom you are affiliated;
  • Entities for legal and security purposes;
  • Entities for sales or transfer of business or assets; and
  • Others with your consent
  • Online advertising and analytics partners; and
  • Lead generation providers
Financial information, such as EIN and other information necessary to receive ACH payments.
  • Operate, maintain, and provide the Services;
  • Handle your registration, inquiries, and requests;
  • Communicate with you;
  • Facilitate transactions; and
  • Security, fraud prevention, and legal compliance.
  • Vendors;
  • Affiliates;
  • Entities for legal and security purposes; and
  • Others with your consent
  • We do not share/sell financial information
Internet or other electronic network activity information, such as information about how you browse and interact with the Services and information about your device and browser.
  • Operate, maintain, and provide the Services;
  • Handle your registration, inquiries, and requests;
  • Communicate with you;
  • Facilitate transactions;
  • Personalize your experience and our communications with you;
  • Advertising and marketing;
  • Analyze and understand use of the Services;
  • Provide seminars and webinars;
  • Improve our products and services; and
  • Security, fraud prevention, and legal compliance.
  • Vendors;
  • Business partners;
  • Ad networks, advertising providers, and analytics providers;
  • Lead generation providers;
  • Affiliates;
  • Customers with whom you are affiliated;
  • Entities for legal and security purposes;
  • Entities for sales or transfer of business or assets; and
  • Others with your consent
  • Online advertising and analytics partners; and
  • Lead generation providers
Survey, feedback, or similar information, such as information you provide in response to a survey in relation to the Services.
  • Operate, maintain, and provide the Services;
  • Handle your registration, inquiries, and requests;
  • Communicate with you;
  • Facilitate transactions;
  • Personalize your experience and our communications with you;
  • Advertising and marketing;
  • Analyze and understand use of the Services;
  • Provide seminars and webinars;
  • Improve our products and services; and
  • Security, fraud prevention, and legal compliance.
  • Vendors;
  • Business partners;
  • Ad networks, advertising providers, and analytics providers;
  • Lead generation providers;
  • Affiliates;
  • Customers with whom you are affiliated;
  • Entities for legal and security purposes;
  • Entities for sales or transfer of business or assets; and
  • Others with your consent
  • Online advertising and analytics partners; and
  • Lead generation providers
Customer service interaction information
  • Operate, maintain, and provide the Services;
  • Handle your inquiries and requests;
  • Communicate with you;
  • Facilitate transactions;
  • Personalize your experience and our communications with you;
  • Analyze and understand use of the Services;
  • Improve our products and services; and
  • Security, fraud prevention, and legal compliance.
  • Vendors;
  • Business partners;
  • Affiliates;
  • Customers with whom you are affiliated;
  • Entities for legal and security purposes;
  • Entities for sales or transfer of business or assets; and
  • Others with your consent
  • We do not share/sell customer service interaction information
Other information that is reasonably capable of identifying you
  • Purposes of use will depend on the information you provide.
  • Disclosures will depend on the additional information you provide.
  • Online advertising and analytics partners, depending on the additional information you provide; and
  • Lead generation providers, depending on the additional information you provide.

Retention. We retain your information as necessary to provide the Services and to fulfill the transactions you have requested, and for other necessary purposes such as complying with our legal obligations, resolving disputes, enforcing our agreements, and for fraud prevention and related security purposes. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. For example, we retain your email address as an authentication credential (where applicable) as long as you have an account with us and an additional period of time after that for our legitimate interests and for our fraud and legal compliance purposes. If you opt out of email marketing, we maintain your email address on our suppression list for an extended time to comply with your request. We may delete or de-identify your information sooner if we receive a verifiable deletion request, subject to exemptions under applicable law. We may retain cached or archived copies of your information. Aggregated or anonymous data derived from your information, which cannot be traced back to your account, may remain on our production servers indefinitely. We reserve the right to use any aggregated or anonymous data derived from or incorporating your information.

Please see the “Your Rights and Choices” section of our Privacy Policy below for information about the additional rights you have with respect to your personal information under California law and how to exercise them.

2. Your Rights and Choices

Right to Know About Your Personal Information

In addition to the information provided above, you have the right to know and access the specific pieces of personal information that we have collected about you. You may exercise this right up to two times in any 12-month period.

Right to Request Deletion

You have the right to request deletion of your personal information. We will honor such request unless we are required to retain your personal information under an exemption. Examples of such exceptions are:

  • Completing a transaction or performing a contract we have with you;
  • Detecting and addressing data security incidents, and repairing or upkeep of our IT systems;
  • Protecting against fraud or other illegal activity;
  • Complying with applicable law or a legal obligation, or to exercise rights under the law (e.g., the right to free speech); or
  • Using your personal information internally to improve our Services.

Right to Request Correction

You have the right to request that we correct inaccurate personal information that we maintain about you. We will honor such request unless it is impossible to do so or would involve disproportionate effort, or if we have a good-faith, reasonable, and documented belief that a request to correct is fraudulent or abusive.

Right to Opt-Out of the Sale or Sharing of Personal Information

You have the right to opt-out of the sale or sharing of personal information. Please note, however, that we do not sell or share for the purpose of cross-context behavioral advertising any personal information obtained about you on the Site, nor have we done so in the past twelve (12) months.

Right to Limit the Use and Disclosure of Sensitive Personal Information

You have the right to limit the use and disclosure of sensitive personal information. Please note, however, that our data collection in connection with the Services is limited to the information referenced in this Privacy Policy which does not include sensitive personal information.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. We will not (i) deny you products or services, (ii) charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties, (iii) provide you a different level or quality of products or services, and/or (iv) suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.

Right to Designate an Authorized Agent

If you submit a request to know or delete your personal information through the use of an authorized agent, we may require that you (i) provide the authorized agent written permission to act on your behalf, and (ii) verify their identity directly with us.

3. Exercising Your Privacy Rights

Rights to Know, to Request Deletion, and to Request Correction of Personal Information

To exercise these rights, please submit a verifiable consumer request to us entitled “California Privacy Request,” or similar as described in ARTICLE IV of this Privacy Policy.

What we need to know to fulfill your request

The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) 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 personal information if we cannot verify your identity or authority to make the request and confirm the personal information related to you. Making a verifiable consumer request does not require you to create an account with us.

How you will hear back from us

We will confirm receipt of a verifiable consumer request within then (10) business days of its receipt. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of its receipt. If we require more time, we will notify you of the extension and provide an explanation of the reason for the extension in writing, and we will provide you with a response no later than ninety (90) calendar days of receipt of the request. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We may charge a reasonable fee to process or respond to your verifiable consumer requests if they are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for this decision and provide you with a cost estimate before completing your request.

Right to Opt-Out of the Sale and/or Sharing of Personal Information

As mentioned above, we do not sell or share your personal information for the purpose of cross-context behavioral advertising.

4. Other California Privacy Rights.

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To submit such a request, please contact us pursuant to ARTICLE VI of this Privacy Policy.

ARTICLE III GDPR NOTICE

The General Data Protection Regulation (“GDPR”) may give natural persons located in the European Union, Lichtenstein, Norway, or Iceland, or in the United Kingdom (collectively, “Data Subjects”) additional rights regarding their personal data. This GDPR Notice supplements our Privacy Policy. Under the GDPR, “Personal Data” generally means information that can be used to identify a natural person, and “processing” generally refers to actions that can be performed on data such as its collection, use, storage, transfer, or disclosure.

Consumer Edge will usually be the controller of your Personal Data processed in connection with the Services.

1. Types of Personal Data we Collect.

We currently collect, receive, and otherwise process the types of Personal Data described in ARTICLE I of this Privacy Policy.

2. How we Receive Personal Data and the Purpose(s) of Processing.

We collect, receive, and otherwise process Personal Data in the ways and for the purposes listed in ARTICLE I of this Privacy Policy. We will only process your Personal Data if we have a lawful basis for doing so. Under the GDPR, the lawful bases we rely on for processing this information are:

  • Your Consent. In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection. You can remove your consent at any time. You can do this by contacting us as set forth in ARTICLE IV of this Privacy Policy with the subject line “GDPR Request,” or similar.
  • We Have a Contractual Obligation. We process certain categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform our contractual obligations to you, which enables us to provide you with access to the Client Portal. When we process data due to contractual necessity, failure to provide such Personal Data may result in your inability to use some or all portions of the Services that require such data. These categories of Personal Data are set forth in ARTICLE I of this Privacy Policy.
  • We Have a Legitimate Interest. We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
  • Contact information and other Identifiers
  • Usage Data
  • Information about your Internet or network activity such as your interactions with the Services

Our legitimate interests are:

  • Information Security: We process contact information, the information collected through Tracking Technologies, and when you use the Services in order to maintain an audit log of activities performed. We use this information pursuant to our legitimate interests in tracking usage, combating DDOS or other cyberattacks, and removing or defending against malicious individuals or programs.
  • Operation and Improvement of our Services: We process server log information and information collected analytics services pursuant to our legitimate interest in operating and improving our Services.
  • Audience Measurement: Pursuant to your consent, we use analytics cookies and collect identifiers for purposes of audience measurement, analytics, audience reaction to the Services, and creating relevant user experiences.
  • General Business Development and Management: We process Personal Data pursuant to our legitimate interest in creating and managing our business relationships with Data Subjects, including without limitation:
    • To respond to inquiries from Data Subjects and provide requested materials such as our newsletter
    • To assist Data Subjects with any issues encountered while using the Services;
  • Protection of Rights: We may also Process Personal Data to respond to claims of violation of third-party rights or to enforce and protect our rights.

We Have a Legal Obligation. We may be required to disclose Personal Data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose Personal Data to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

3. How we Share Your Personal Data.

ARTICLE I of this Privacy Policy explains how and why we share your Personal Data with third parties.

4. How we Store and Protect Your Personal Data.

We use commercially reasonable administrative, technical, and physical safeguards to protect your Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, for which we take into account the nature of the Personal Data, its processing, and the threats posed to it. Unfortunately, no data transmission or storage system can be guaranteed to be secure at all times. We retain your Personal Data for as long as needed to fulfill the purposes for which we obtained it, as further described in this Privacy Policy. We will only keep your Personal Data for as long as allowed or required by law.

5. Your Data Protection Rights.

You have certain rights with respect to your Personal Data, including those set forth below. You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may need additional time to comply, or ask you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

  • Right of access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
  • Right to rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
  • Right to erasure: You can request that we erase some or all of your Personal Data from our systems.
  • Right to restriction of processing: You have the right to ask us to restrict the processing of your Personal Data.
  • Right to object to processing: You have the right to object to the processing of your Personal Data in certain circumstances.
  • Right to data portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
  • Right to withdraw consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of the Services.
  • Objecting to Legitimate Interest/Direct Marketing: You may object to Personal Data processed pursuant to our legitimate interest. In such case, we will no longer process your Personal Data unless we can demonstrate appropriate, overriding legitimate grounds for the processing or if needed for the establishment, exercise, or defense of legal claims. You may also object at any time to processing of your Personal Data for direct marketing purposes by clicking “Unsubscribe” within an automated marketing email. In such case, your Personal Data will no longer be used for that purpose.

To exercise your rights under the GDPR, please submit a request as described in ARTICLE IV herein, or contact our EU or UK Representative, as applicable, as set forth in ARTICLE III, Section 7 of this Privacy Policy.

6. How to Complain

If you have any concerns about our use of your Personal Data, you may submit a complaint to us under ARTICLE IV herein, or by contacting our EU or UK Representative, as applicable, as set forth in ARTICLE III, Section 7 of this Privacy Policy.

You also have the right to lodge a complaint about the processing of your Personal Data with a supervisory authority where you work or live or where any alleged infringement of data protection laws occurred. A list of most of the supervisory authorities can be found here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

7. Our Representatives

UK Representative. Our representative in the UK (identified below) is available to answer any questions and assist in exercising your privacy rights under ARTICLE III of this Privacy Policy.

UK Representative
Attn: Data Privacy Officer
Email: legal@consumer-edge.com

EU Representative. Our representative in the EU (identified below) is available to answer any questions and assist in exercising your privacy rights under ARTICLE III of this Privacy Policy.

EU Representative
Attn: Data Privacy Officer
Email: legal@consumer-edge.com

8. Corporate Restructuring.

In the event of a merger, reorganization, dissolution, or similar corporate event, or the sale of all or substantially all of our assets, the information that we have collected, including Personal Data, may be transferred to the surviving or acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such Personal Data as set forth in this GDPR Notice.

9. Transfers of Personal Data.

The Services are hosted and operated in the United States, Germany and the United Kingdom through Consumer Edge and its service providers (the “Consumer Edge Locations”). The laws in Consumer Edge Locations may differ from the laws governing data privacy and security in your country of residence. By accessing or using the Services, you acknowledge and agree that Consumer Edge will transfer Personal Data about you, regardless of whether provided by you or obtained from a third party, or to one or more Consumer Edge Locations, and thereafter may transfer your Personal Data between Consumer Edge Locations, for purposes of processing in accordance with this Privacy Policy. Where we transfer Personal Data from the EEA, the United Kingdom, or Switzerland to the United States, our primary transfer mechanism, where Consumer Edge or the relevant recipient is self-certified, is the EU-U.S. Data Privacy Framework, together with the UK Extension to the EU-U.S. Data Privacy Framework (the “UK-U.S. Data Bridge”) and the Swiss-U.S. Data Privacy Framework, which the European Commission recognized as providing adequate protection in its adequacy decision of 10 July 2023. You may verify our participation on the Data Privacy Framework List at https://www.dataprivacyframework.gov. As a fallback—and for transfers to recipients or countries not covered by an adequacy decision—you hereby consent to the transfer of your Personal Data to the U.S. we transfer Personal Data pursuant to an appropriate data processing agreement incorporating the modernized standard contractual clauses for the transfer of Personal Data to third countries promulgated by the European Commission on 4 June 2021, a copy of which can be obtained at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en, and/or, as applicable, the UK International Data Transfer Addendum, the UK International Data Transfer Agreement, or another data transfer mechanism approved pursuant to the GDPR.

ARTICLE IV EXERCISING YOUR PRIVACY RIGHTS

To exercise your privacy rights described in ARTICLE I (Nevada Residents), ARTICLE II (California Residents), or ARTICLE III (EEA/UK Data Subjects), please submit a request by:

Email to: legal@consumer-edge.com with a subject line indicating, as applicable, Nevada Privacy Rights, CCPA Rights Request, or GDPR Rights Request, or similar.

  • Writing to us at: Consumer Edge, 140 East 45th Street, New York, NY, 10017.
  • GDPR Rights Requests may also be submitted to our EU Representative or UK Representative as described in ARTICLE III, Section 7 of this Privacy Policy.

ARTICLE V CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We reserve the right to modify this Privacy Policy at any time. We may update this Privacy Policy from time to time with or without notice to you. Where required by applicable law, we will provide notice of, and where necessary obtain your consent to, material changes before they take effect. We will indicate at the top of this Privacy Policy when it was most recently updated, and we encourage you to revisit this page periodically to stay aware of any changes. By accessing the Services after we change this Privacy Policy, you are deemed to have accepted such changes.

ARTICLE VI CONTACTING US

If you have any questions or comments regarding our Services or the Privacy Policy, or want to exercise your rights and choices, please contact us as set forth below:

Email: legal@consumer-edge.com

Postal address: Consumer Edge, 140 East 45th Street, New York, NY, 10017

Attn: Legal

Second Email: privacy@consumer-edge.com