Effective Date: December 13, 2023
Last Reviewed: October 15, 2023

CINC Privacy Policy

PLEASE READ THIS PRIVACY POLICY CAREFULLY.

CINC Systems, LLC and our affiliated companies (collectively referred to as “CINC” or “we,” “us,” or “our”) respect your privacy and are committed to protecting it through our compliance with this Privacy Policy.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it (“Privacy Policy”). By accessing our website or mobile application, including any products and services offered on or through our website or in the course of doing business online or offline (collectively, our “Services”) or any subsite, subdomain, or successor site, or any mobile application which links to this policy (collectively, our “Website”) or otherwise engage in any business with us online or offline (collectively, our “Services”), you agree to this Privacy Policy. If you do not agree with all of the terms, conditions, and practices set forth below, do not access the Website or use our Services. By submitting personal information to us, you give us permission to receive it, review it, edit it, store it, disclose it, and use it for the purposes described in this Privacy Policy.

This Privacy Policy describes the types of information we may collect from or about you or that you may provide when you visit the Website or access our Services and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy applies to the information we collect on the Website, during the course of providing our Services, and in email, text, or other electronic messages between you and us. This Privacy Policy does not apply to any Services that do not display or link to this Privacy Policy or that have their own privacy policy statements. Additionally, this Privacy Policy does not apply to any external third-party websites that may be linked to the Website.

Information We Collect About You and How We Collect It

We may collect several types of information from or about users of our Website or Services, including information:

• By which you may be personally identified, such as your name, address, email, telephone number, and banking information;
• About you individually which does not identify you; and/or
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information directly from you when you provide it to us and automatically as you navigate through the Website or our Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information We Collect

As you navigate through the Website or use any of our Services, we (including any service providers or third parties acting on our behalf) may collect two types of information from you: (1) “personally identifiable information” (as described below); and (2) “non-personally identifiable information” (as described below).

“Personally identifiable information” is information that can be used to uniquely identify or contact a single person, directly or indirectly in conjunction with other public information.

There are a number of ways in which you may provide us with and consent to our collection of certain personal information. Here are some examples of the ways in which we may collect and store your personally identifiable information through the Website or our Services:

• We may collect your first and last name, email address, mobile phone number or other information when you register for our Services and create an account;
• We may collect certain information about your family members if you add your family or household to your account;
• We may collect personal information you submit to us, such as your name, phone number, and email address when you contact us; and
• We may collect your first and last name, mailing address, and payment information (such as credit card number and expiration date) if you make a payment on the Website.

“Non-personally identifiable information” can be technical information or it can be demographic information, such as your age, name, or gender. Non-personally identifiable information may also mean aggregated, non-identifiable, or anonymized information. Non-personally identifiable information does not identify you personally. If you do provide us with non-personally identifiable information, we may use it for the purposes described in this Privacy Policy, or any other legal purpose.

Here are some examples of ways through which we may collect and store your non-personally identifiable information through the Website or other online Services, and how we use such information:

• Log Information: When you use the Website or view content provided by CINC through our online Services, we automatically collect and store certain information in our server logs. This type of information includes details of how you use our Service, web pages which have been viewed by you, date and time, domain type, device event information such as crashes, system activity, hardware, settings, browser type, browser language, the date and time of your requests, and referral.
• Demographic Information: “Demographic Information” may be gender, age, or ZIP code. We may collect such information about you through our Services and use it to provide you with personalized Services and to analyze trends to ensure that our Website and Services so the information on them is targeted to meet your needs. Please note that we also consider aggregated information, which is not personally identifiable, to be non-personally identifiable information.
• Location Information: When you use the Website or other online Services, we may collect and process information about your actual location. We use various technologies to determine location, including IP address, global positioning systems, and other sensors that may provide CINC with information about nearby devices and WiFi access points.
• Usage Information: When you use the Website or other online Services, we may collect and process information about how you use the Website or other online Services, including how you move through the Website or use our Services.
• Feedback Information: From time to time, we may request that you provide us with feedback regarding the Website as well as the products and Services we offer. We may do this in the form of a survey or other feedback mechanism. We may collect and analyze this information.

The technologies we use for this automatic data collection may include:
• Cookies (or browser cookies): A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website or other online Services. Unless you have adjusted your browser setting so that it will refuse our cookies, our system will use cookies when you direct your browser to our Website or other online Services.
• Flash Cookies: Certain features of our Website or other online Services may use local stored objects (or flash cookies) to collect and store information about your preferences and navigation to, from, or on our Website or other online Services. Flash cookies are not managed by the same browser settings that are used for browser cookies.
• Web Beacons: Pages of our Website or other online Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

If you encounter a screen or page that requests information you do not want to share with us, do not enter the information and do not proceed with that screen or page.

How We Use Your Information

Personally Identifiable Information

If you provide us with personally identifiable information, we will use it only for the purposes described in this Privacy Policy or where it was collected (including in a financial privacy statement). Primarily, we use it to:

• Offer you the products and Services you request;
• Process and complete transactions and send notices about your transactions;
• Create or offer content which is relevant to you;
• Register you as a member and develop your profile to enable you to take advantage of the personalized features of the Website or other online Services;
• Alert you to updated information, and other new Services offered by us or by third parties;
• Improve your user experience and the experience of other users of our Website or other online Services;
• Understand how you use the Website or other online Services;
• Identify you as a poster or provider of communications or content;
• Contact you in response to an email or other communication; or
• For any other legitimate business purpose not otherwise prohibited by applicable law.

Non-Personally Identifiable Information

We may use non-personally identifiable information for the purposes described in this Privacy Policy or where it is collected, or any other legal purpose. Without limiting the above, we may collect information to understand how you use the Website or other online Services and how we can improve the Website’s or other online Services’ functionality.

Reports

We may periodically prepare analyses and reports reflecting our visitor and member use of the Website and Services. In preparing these reports, we may combine and analyze the personal information you provide to us with information from other sources. However, these reports will include only aggregate information about visitors and members. The information in these reports will not identify you individually and any business partner with whom such reports may be disclosed will not be able to contact you based on the information contained in the reports.

Disclosures of Your Information

We may disclose information we obtain about you in compliance with this Privacy Policy.

Personally Identifiable Information

We may disclose your personally identifiable information for the following business or commercial purposes:

• To activate and maintain your account;
• To carry out the transaction(s) you have requested or authorized;
• To respond to your questions, inquiries, comments, and instructions;
• To send you information, including updates and notices and other information about us or our Website or other online Services;
• To assist unaffiliated third-party service providers, agents, or independent contractors who help us maintain our products and Services;
• To comply with law, or if in good faith we believe that such action is necessary to conform to the requirements of law, or comply with legal process served on us, and to protect and defend our rights or property, or act in urgent circumstances to protect your personal safety and the personal safety of our other visitors;
• To inform third parties as part of a corporate reorganization process including, but not limited to, a merger, acquisition, or sale of all or substantially all of our assets;
• To assist or manage our subsidiaries and affiliates;
• With your consent or direction;
• To track and analyze non-identifying, aggregate usage and volume information from our visitors or members and provide such information to third parties;
• To maintain the security of the Website, other online Services, and CINC’s systems;
• To protect against fraud or potential fraud; and
• For any lawful purpose, which may include selling your data to third parties in accordance with applicable law, such as with your consent.

Non-Personally Identifiable Information

We may disclose your non-personally identifiable information for the purposes disclosed in this Privacy Policy or where it is collected, or for any other legal purpose, including when and where applicable, disclosing non-personally identifiable information combined with personally identifiable information.

Legal Disclosure

We may disclose information about you and your use of the Website or other online Services if we believe such disclosure is necessary to:

• Comply with the law and/or legal process where a formal request has been made;
• Protect or defend our rights and/or property and property of others;
• Enforce our Website terms of use and/or this Privacy Policy;
• Conduct investigations of possible breaches of law.

Choices About How We Use, Disclose, and Share Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies: You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly. You may have additional choices with third parties that may be using tracking technologies on our Website or other online Services. For example, to learn more about Google’s privacy practices and to opt-out of Google tracking technologies, please visit: https://policies.google.com/technologies?hl=en-US.
• Marketing Emails and Promotional Offers from CINC: If you do not wish to have your information used by CINC to promote our products or services or receive marketing emails, you may choose not to receive marketing email communications from us by clicking on the “unsubscribe” link in our marketing emails or you also may ask us not to send you marketing or promotional communications by contacting us at compliance@cincsystems.com, and we will honor your request and omit you from future email distributions.

Accessing and Correcting Your Information

Subject to applicable law, you may obtain a summary of your personal information or the type of personal information we maintain about you by contacting your management company or at compliance@cincsystems.com. To help protect your privacy and maintain security, we, or your management company, will take steps to verify your identity before granting you access to the information. In addition, if you believe that personal information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting your management company or at compliance@cincsystems.com.

Data Security

We have implemented measures to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Once we receive your information, we make reasonable efforts to ensure the security of our systems. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of such firewalls or secure server software.

The safety and security of your information also depends on you. Where you have chosen a password to access our Website or other online Services, you are responsible for keeping this password confidential. We ask that you do not share this password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted via our Website or other online Services. Any transmission of personal information is done at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or other online Services.

Retention and Deletion

We will retain your personal information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purpose(s) remains valid after termination of CINC’s relationship with you. Please note that in many situations we must retain all, or a portion, of your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, to protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes. We will not retain information for longer than is reasonably necessary for any of the disclosed purposes in this Privacy Policy.

We aim to maintain our Services in a manner that protects information from accidental or malicious destruction. Because of this, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.

Children Under the Age of 13

Our Website and other online Services are not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website or other online Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or other online Services or on or through any of its features/register on the Website or other online Services, use any of the interactive or public comment features of this Website or other online Services or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete the information. If you believe we might have any information from or about a child under 13, please contact us at compliance@cincsystems.com.

Third Party Sites

The Website or other online Services may contain links to webpages operated by parties other than CINC. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the user to take precautions to ensure that whatever links the user selects or software the user downloads (whether from this Website or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the user will be subject to upon visiting the third party’s website. CINC strongly recommends that each user review the third party’s terms and policies.

Do Not Track (DNT) Signals

CINC does not respond to Do Not Track (DNT) signals. Some third party sites keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.

You can, however, make decisions about your privacy and the advertisements you receive. The online advertising industry provides websites from which you may be able to opt out of receiving certain targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can control whether some companies serve you behaviorally-based advertising by visiting the Digital Advertising Alliance (“DAA”) web page and using the DAA’s opt-out selection (located at https://www.aboutads.info/choices/) or by visiting the Network Advertising Initiative’s opt out page (https://optout.networkadvertising.org/).

Notice to California Residents

This section is for California Residents and applies solely to all visitors and users who reside in the State of California and is adopted to comply with the California Consumer Privacy Act and its implementing regulations(“CCPA”), and any terms defined in the CCPA have the same meaning when used in this Notice to California Residents (“Notice”).

This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.

In particular, we have collected the following categories of personal information from our prospects, clients, and investors within the last twelve (12) months:

Category Examples Collected
A. Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
YES
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
C. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
YES
D. 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
E. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
YES
F. Geolocation data. Physical location or movements.
YES
G. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information.
YES
H. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
YES
I. Sensitive personal information Personal information that reveals a consumer’s: 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; union membership; or genetic data.

Infers characteristics about a consumer.
YES

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Site.
• Third party vendors that provide databases.
• Service providers.
• Business partners.
• Government entities.
• Operating systems and platforms.
• Social networks.
• Data brokers.

Use of Personal Information
We do not sell your personal information. We may use, disclose, or share the personal information we collect for one or more of the following business or commercial purposes:

• Fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our Services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a Service, we will use that information to provide that Service to you. We may also save your information to facilitate future communications and Services.
• Provide, support, personalize, and develop our Site, products, and Services.
• Create, maintain, customize, and secure your account with us.
• Process your requests, transactions, and payments and prevent transactional fraud.
• Provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• Help maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets, and business.
• Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• Described to you when collecting your personal information or as otherwise set forth in the CCPA.
• Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.
• Audit related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
• Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.
• Debug to identify and repair errors that impair existing intended functionality.
• Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
• Perform services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.
• Provide advertising and marketing services, except for cross-context behavioral advertising, to the consumer provided that, for the purpose of advertising and marketing, a service provider or contractor shall not combine the personal information of opted-out consumers that the service provider or contractor receives from, or on behalf of, the business 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 consumers.
• Undertake internal research for technological development and demonstration.
• Undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

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 via this Privacy Policy.

Disclosing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we make efforts to ensure that the recipient will both keep that personal information confidential and not use it for any purpose except performing the contract.

We may disclose any of the above categories of personal information for any of the above business purposes with the following categories of third parties:

• Affiliates.
• Firms that provide assistance in servicing CINC and that have a need for such information, such as CRMs or other service providers.
• Business partners.
• Government entities.
• Operating systems and platforms.
• Social networks.
• Data brokers.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, CINC has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Commercial information.
Category E. Internet or other similar network activity.
Category F. Geolocation data.
Category G: Sensory data.
Category H. Inferences drawn from other personal information.
Category I: Sensitive personal information

Sales and Sharing of Personal Information

In the preceding twelve (12) months, CINC has not sold personal information. We have no actual knowledge that we have sold any personal information of consumers under 16 years of age.

CINC may share any of the above categories of your personal information for cross context behavioral advertising based on your personal information obtained from your activity across businesses, distinctly-branded websites, applications, or services, other than our own Website or other online Services. CINC may share your personal information with any of the following categories of third parties for marketing and other customer acquisition business purposes:
• Affiliates.
• Service providers.
• Business partners.
• Social networks.
• Data brokers.
We do not share your sensitive personal information for cross context behavioral advertising.

Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Please note that the CCPA exempts certain personal information from these rights, such as:

o health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
o personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of personal information, including sensitive personal information, we have collected about you.
• The categories of sources for the personal information, including sensitive personal information, we have collected about you.
• The categories of personal information, including sensitive personal information, we have collected, sold, or shared for a business or commercial purpose.
• The categories of third parties with whom we disclose that personal information, including sensitive personal information, and the categories of personal information that was disclosed.
• The specific pieces of personal information, including sensitive personal information, we have collected about you (also called a data portability request).

Right to Correct

If your personal information that we maintain about you is inaccurate, you have to right to request correction. To exercise this right, please email us at compliance@cincsystems.com with “California Right to Correct” in the subject line and the specific pieces of information you would like corrected and the particular inaccuracy.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. Seq.).
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Sensitive Personal Information

• Under CCPA, California residents have the right to restrict the use and disclosure of sensitive personal information under certain circumstances.

We do not use or disclose your sensitive personal information except for purposes other than that which is necessary to perform the Services or for any other uses and disclosures authorized by the CCPA, but if you would like to request that we limit the use and disclosure your sensitive personal data, please email us at compliance@cincsystems.com.

Other CCPA Rights

• The right to know what personal information is sold or shared and to whom.
• The right to opt-out of the sale or sharing of your personal information. We do not sell your personal information. To opt-out of the sharing of your personal information, please click on the Manage Consent link in the footer of our website and click the “Do not sell my personal information.” link in the manage consent pop-up bar or submit a request using the contact information below.

Please note that we will respond to opt-out preference signals in compliance with applicable laws. Please refer to the settings in your browser to use opt-out preference signals.

Exercising Access, Data Portability, Deletion Rights, and Other CCPA Rights

To exercise the access, data portability, deletion, and other CCPA rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 1-855-943-8246 extension 2138
• Emailing us at compliance@cincsystems.com

Only you, or an authorized agent, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
o An email address that operates as a user log-in with CINC, name, and date of birth.
o Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

• For your authorized agent(s), CINC may need to:
o Verify your identity directly.
o Directly confirm that you provided the authorized agent permission to submit the request.

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 relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt, unless you request that we provide personal information beyond the 12-month period. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

No Discrimination or Retaliation
We will not discriminate or retaliate against you for exercising any of your CCPA rights.

Contact Information
If you have any questions or comments about this Notice, the ways in which we collect and use your information described here and in the Privacy Policy, your choices and rights regarding such use, or you wish to exercise your rights under California law, please do not hesitate to contact us at:

• Phone: 1-855-943-8246 extension 2138
• Email: compliance@cincsystems.com

International Users

The Website and other online Services are intended solely for CINC customers residing in the United States. If you are a non-US resident, please be advised that we may transfer information that we collect about you, including your personal information, to subsidiary and affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information about you, including personal information, to a country and jurisdiction that may not have the same data protection laws as the country where you are located. Accordingly, you consent to the transfer of information about you, including your personal information, to the U.S., and the use and disclosure of information about you, including your personal information, as described in this Privacy Policy.

Compliance and Cooperation with Regulatory Authorities

We regularly review our compliance with our Privacy Policy. When we receive formal written complaints, if the person complaining provides contact information, we may contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our customers directly.

Changes to this Policy

From time to time, we may make changes to this Privacy Policy in order to accommodate new technologies, platforms, industry practices, regulatory requirements, or for other purposes. We encourage you to review this Privacy Policy periodically to ensure that you understand how we collect, use, disclose, and share information through the Website or other online Services. If we make changes to this Privacy Policy, we will update the “Effective Date” posted at the top of this Privacy Policy.

Any changes to this Privacy Policy will become effective when the revised Privacy Policy is posted on the Website or other online Services. By continuing to use the Website or other online Services following such changes, you are agreeing to accept the terms of the revised Privacy Policy.

Contact Us

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: compliance@cincsystems.com.