# Privacy Policy — Icalia Labs > Icalia Labs Privacy Policy. How we collect, use, share, and protect personal data. Legal # Privacy Policy Effective as of January 23, 2025 Icalia takes privacy seriously. By using our website or services, you acknowledge acceptance of the practices outlined in this policy and consent to data collection and sharing as described. ## Table of Contents - What this Privacy Policy Covers - Personal Data - How We Share Your Personal Data - Tracking Tools and Opt-Out - Data Security and Retention - Personal Data of Children - Other State Law Privacy Rights - Changes to this Privacy Policy - Contact Information ## What This Policy Covers It is Icalia's policy to protect consumer and customer Personally Identifiable Information (PII), defined as "information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household." Examples of PII include full name, social security number, passport number, bank account information, credit card number, and driver's license number. ## Personal Data ### Categories of Personal Data We Collect #### Profile or Contact Data - First and last name - Email - Phone number - Unique identifiers such as passwords #### Identifiers - Social security number - Driver's license number - Passport number - Cultural or social identifiers #### Payment Data - Payment card type - Last 4 digits of payment card - Billing address, phone number, and email #### Commercial Data - Purchase history - Consumer profiles #### Device/IP Data - IP address - Device ID - Domain server - Type of device/operating system/browser used to access services #### Web Analytics - Web page interactions - Referring webpage/source - Non-identifiable request IDs - Statistics associated with device or browser interaction #### Social Network Data - Email - Phone number - User name - IP address - Device ID #### Consumer Demographic Data - Age/date of birth - ZIP code - Gender - Race - Ethnicity #### Professional or Employment-Related Data - Resume - Job title - Job history - Performance evaluations #### Geolocation Data - IP-address-based location information - GPS data ### Additional Information Collected We may collect information about individuals or businesses including: - Names or aliases - Physical and work addresses - Phone numbers and email addresses - Date of birth and gender - Government ID and photo identification - Selfies or video authorization - Facial identifiers and images from identification documents ### Categories of Sources of Personal Data #### You - When you provide information directly - When you use interactive tools and services - When you provide information through text boxes, surveys, or questionnaires - When you contact us via email #### Automatic Collection - Through cookies - From location-enabled browsers - From downloaded applications and software #### Public Records - From government or other sources #### Affiliates - From our affiliates in other countries #### Third Parties - Payors - Vendors for analytics and customer support - Advertising partners assisting with marketing services ### Our Commercial or Business Purposes for Collecting Personal Data #### 1\. Providing, Customizing and Improving the Services - Providing requested products, services, or information - Meeting the reason you provided the information - Providing support and assistance - Improving services through testing, research, and product development - Personalizing content and communications based on preferences - Carrying out other stated business purposes under applicable privacy laws #### 2\. Marketing the Services - Marketing and selling services #### 3\. Corresponding with You - Responding to correspondence - Contacting you when necessary - Sending information about Icalia or services - Sending emails according to your preferences #### 4\. Meeting Legal Requirements and Enforcing Legal Terms - Fulfilling legal obligations under law, regulation, court order, or legal process - Preventing, detecting, and investigating security incidents - Protecting rights, property, or safety - Enforcing agreements - Responding to claims about content violations - Resolving disputes We will not collect additional categories without providing notice or use information for materially different purposes without your consent. ## How We Share Your Personal Data We share information with third parties as follows: - Companies providing services such as identity verification, fraud prevention, or credit bureaus - Financial institutions and payment processors - Other transaction parties such as users, merchants, and their service providers - Information technology and service providers worldwide - Independent external auditors and service providers - In connection with business ownership changes, mergers, acquisitions, or reorganizations - To support audit, compliance, and governance functions - Service providers for advertising preparation and deployment - For legal rights establishment and defense, including fraud prevention - In business or asset sales, equity transactions, or mergers - With your consent or direction ### Categories of Parties We Share With #### Governmental Entities Various governmental entities may request or demand delivery of personal data in compliance with law. #### Service Providers These parties help provide services or perform business functions: - Hosting, technology, and communication providers - Security, identification verification, and fraud prevention consultants - Support and customer service vendors #### Advertising Partners - Ad networks - Data brokers - Marketing providers #### Analytics Partners - Companies tracking user referral sources - Companies tracking user interaction #### Affiliates We may share all personal information with our affiliates in other countries. #### Business Partners - Auditors, examiners, and consultants - Businesses you have relationships with - Companies offering joint promotional offers #### Parties You Authorize, Access or Authenticate - Third parties accessed through services - Social media services - Other users ### Legal Obligations Personal data may be shared with third parties in conjunction with activities listed under "Meeting Legal Requirements and Enforcing Legal Terms." ### Business Transfers All collected personal data may be transferred if we undergo merger, acquisition, bankruptcy, or other transaction. We will make reasonable efforts to notify you before information becomes subject to different privacy policies. ### Data That Is Not Personal Data We may create aggregated, de-identified, or anonymized data from collected information by removing personally identifiable elements. We may use and share such data with third parties for lawful business purposes without identifying you. ## Tracking Tools and "Do Not Track" The Services use cookies and similar technologies such as "pixel tags, web beacons, clear GIFs and JavaScript" to enable recognition, analyze trends, and improve services. ### Types of Cookies #### Performance/Analytical Cookies These allow understanding of visitor behavior by collecting information about visitor numbers, page views, and viewing duration. They help measure advertising campaign performance. Google uses cookies with its Google Analytics services. You may opt-out by visiting [www.google.com/privacy\_ads.html](https://www.google.com/privacy_ads.html) or downloading the [Google Analytics Opt-out Browser Add-on](https://tools.google.com/dlpage/gaoptout/). ### Cookie Management You can decide whether to accept cookies through your browser settings. Most browsers allow disabling cookies and provide options to accept or reject individual cookies. You can delete existing cookies, though some functionalities may not work properly afterward. For more information about cookies, visit [www.allaboutcookies.org](http://www.allaboutcookies.org/). ## Data Security, Retention and Control Over Your Information We seek to protect personal data from unauthorized access using "appropriate physical, technical, organizational and administrative security measures." You should protect your data by selecting strong passwords, limiting device access, and signing off after use. No method of data transmission or storage is completely secure. You have the right to request correction or deletion of data within 30 days, unless retention is required for legal or contractual obligations. ## Applicable State Laws ### Vermont and California Requirements Vermont and California laws prohibit financial institutions from sharing customer PII unless customers take affirmative action authorizing such sharing. Customers with Vermont or California addresses must be removed from campaigns involving information sharing with unaffiliated third parties. ### California Consumer Privacy Act (CCPA) The CCPA covers California residents and applies to any business collecting California resident PII, regardless of business location. Icalia has developed privacy and security controls complying with federal law including the Gramm-Leach-Bliley Act and Fair Credit Reporting Act. ### California Privacy Rights California residents, subject to limitations and exceptions, have the right to: #### Right to Know - Specific pieces of personal information collected - Categories of personal information collected - Categories of collection sources - Business or commercial purposes for collection or sale - Categories of third parties receiving information #### Right to Delete The right to request deletion of collected or maintained personal information. #### Right to Opt-Out of Sale The right to opt-out of personal information sale. Icalia does not sell personal information. #### Right to Non-Discrimination The right to not receive discriminatory treatment for exercising privacy rights. ### Limitations on Rights We may not honor requests if we cannot verify identity or authority, or if exceptions apply such as when disclosure would adversely affect another consumer's rights or information is not subject to CCPA rights. We will not provide social security numbers, driver's license numbers, government identification numbers, financial account numbers, passwords, security questions, or other information if disclosure presents unauthorized access risk. ### How to Exercise CCPA Rights California residents may exercise rights by: - Submitting a request via email to [weare@icalialabs.com](mailto:weare@icalialabs.com) ### Children Online Privacy Protection Act (COPPA) COPPA imposes requirements protecting children under 13 privacy. Icalia's policy is NOT to sell customer PII to third parties and NOT to collect PII from individuals under 13 or under 16 per CCPA. Icalia does not intentionally or knowingly collect or solicit personal information from children under 13. Contact us if you believe a child under 13 provided information without parental consent. ### Vermont State Law Icalia does not share information of customers with Vermont addresses with affiliated companies. ### Privacy and Opt-Out Notice Customers provide private information during business, and we commit to treating it responsibly. We provide Privacy and Opt-Out Notice to all consumers at account opening, enrollment, upon privacy practice changes, and annually thereafter as required. ## Changes to This Privacy Policy We may change this policy as we improve services. We will alert you through website notice, email, or other means. Changes are effective upon posting, and continued service use indicates agreement with modifications. ## Reporting Unauthorized Disclosure of Personal Data When unauthorized PII disclosure occurs, our response and communication to customers and regulatory agencies can affect compliance outcomes. Information breaches create reputational risk and noncompliance. Incidents include situations where customer personal, financial, or health information may be lost, misdirected, or accessed by unauthorized individuals. Any incidents or suspected incidents involving data security should be reported immediately to the IT Department and Senior Management per the Information Security Policy. Unaffiliated third-party service providers must report all unauthorized access and disclosure of customer information. ## Contact Information For questions or comments about this Privacy Policy or our practices: - **Phone:** [+1 832-336-7786](tel:+18323367786) - **Email:** [weare@icalialabs.com](mailto:weare@icalialabs.com) - **Website:** [www.icalialabs.com](https://www.icalialabs.com) - **Austin Office:** 1606 Headway Cir STE 9094, Austin, TX 78754