Privacy Agreement

This Data Processing Agreement (hereinafter referred to as "the Agreement") is made and entered into as of the 1st of January 2025, by and between Claridigm Inc., a company specializing in account management, customer support, and service improvement (hereinafter referred to as "the Company"), and its users or visitors (hereinafter referred to as "the Users"). This Agreement outlines the terms and conditions governing the collection, processing, and sharing of personal information to ensure transparency, compliance, and the protection of user data.

Definitions

1. "Claridigm Inc." refers to the Illinois-based company that provides account management, customer support, and service improvement services.

2. "Users" refer to individuals or entities who interact with Claridigm Inc.'s services, including account holders, website visitors, and individuals submitting inquiries or support tickets.

3. "Personal Information" refers to data collected by the Company, including but not limited to names, email addresses, and Gateway ID numbers.

4. "Gateway ID Numbers" refer to unique identifiers assigned to users for account management and service tracking purposes.

5. "Cookies" refer to small data files stored on a user's device to enhance their experience on the Company's digital platforms.

6. "Sponsoring Clients" refer to third-party entities that request access to user information for purposes aligned with the Company's services, subject to user consent and applicable laws.

7. "Data Processing" refers to the collection, storage, use, and sharing of personal information to manage accounts, provide customer support, and improve services.

8. "Help Desk Tickets" refer to user-submitted requests for assistance or issue resolution through the Company's support channels.#Overview and Purpose

1. **Introduction** This Privacy Policy outlines how Claridigm Inc. collects, uses, and protects personal information provided by users. It reflects our commitment to safeguarding your privacy and ensuring transparency in our data handling practices, in compliance with applicable data protection laws and regulations in Illinois and the United States.

2. **Scope of the Policy** 2.1. This policy applies to all users of Claridigm Inc.’s services, including individuals who: - Interact with our digital platforms. - Submit help desk tickets for support. - Provide information through online forms. 2.2. The policy governs the collection, use, and sharing of personal information, including but not limited to names, email addresses, and Gateway ID numbers.

3. **Purpose of Data Collection** 3.1. Claridigm Inc. collects personal information for the following purposes: - To manage user accounts effectively. - To provide timely and efficient customer support. - To enhance the quality of our services and improve the overall user experience.

4. **Commitment to Data Protection** 4.1. We are committed to protecting your personal information from unauthorized access, misuse, or disclosure. 4.2. Personal information is shared only under specific circumstances, such as with sponsoring clients upon their request, and always in compliance with applicable laws.

5. **Continuous Improvement** Claridigm Inc. is dedicated to continuously improving its privacy practices to adapt to evolving user needs and regulatory requirements.#Legal Basis for Processing

1. **Compliance with Applicable Laws** Claridigm Inc. processes personal information in accordance with applicable laws, including but not limited to the Illinois Biometric Information Privacy Act (BIPA), the California Consumer Privacy Act (CCPA), and other relevant U.S. privacy regulations. The company is committed to ensuring transparency and safeguarding user data throughout its operations.2. **Legitimate Interest** 2.1. Claridigm Inc. processes personal information under the legal basis of legitimate interest for the following purposes: - Managing user accounts to ensure efficient service delivery. - Providing customer support to address user inquiries and resolve issues. - Enhancing and improving the company’s services and overall user experience. 2.2. These activities are essential to the company’s operations and are conducted in a manner that balances the interests of the company and its users.

3. **Consent** 3.1. Claridigm Inc. relies on user consent for the following activities: - Collecting data through cookies on its digital platforms to improve functionality and user experience. - Sharing personal information with sponsoring clients upon their explicit request. 3.2. Users have the right to withdraw their consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent prior to its withdrawal.

4. **User Rights** 4.1. Users have the right to access, correct, delete, or restrict the processing of their personal information in accordance with applicable laws. 4.2. Users may exercise these rights by contacting Claridigm Inc. through the contact details provided in this document.

5. **Compliance with Jurisdictional Laws** 5.1. Claridigm Inc. adheres to the requirements of U.S. privacy laws, including BIPA and CCPA, and aligns with GDPR principles where applicable. 5.2. The company conducts regular reviews of its data processing practices to ensure compliance with evolving legal standards.

6. **Data Sharing and Consent Management** 6.1. Personal information is shared with sponsoring clients only upon their request and with the user’s explicit consent. 6.2. Users can manage their consent preferences through their account settings or by contacting Claridigm Inc. directly.

7. **Cookie Usage** 7.1. Claridigm Inc. uses cookies to collect data and improve its services. 7.2. Users can manage their cookie preferences through the company’s cookie policy or their browser settings.

8. **Contact Information** For any questions, concerns, or to exercise rights related to the processing of personal information, users may contact Claridigm Inc. at: - Email: webinq@claridigm.com - Phone: 773-609-0646 

#User Rights

1. **Right to Access** 1.1 Users have the right to request a copy of the personal information Claridigm Inc. holds about them. 1.2 Requests for access can be submitted via the designated email address or online form provided in the Contact Information section. 2. **Right to Rectification** 2.1 Users may request corrections to any inaccurate or incomplete personal information held by Claridigm Inc. 2.2 Claridigm Inc. will promptly update the information upon verification of the requested changes. 3.**Right to Deletion** 3.1 Users may request the deletion of their personal information, subject to the following exceptions: a. Data required for legal compliance, such as tax records or fraud prevention. b. Data necessary for ongoing service delivery, such as active account management. 3.2 Claridigm Inc. reserves the right to deny deletion requests that are manifestly unfounded, excessive, or repetitive. 4. **Right to Data Portability** 4.1 Where applicable, users may request their personal information in a portable format for transfer to another service provider. 4.2 Such requests will be fulfilled in compliance with applicable laws and technical feasibility. 5. **Right to Restriction of Processing** 5.1 Users may request that Claridigm Inc. limits the processing of their personal information under specific circumstances, including: a. When the accuracy of the data is contested. b. When processing is unlawful, but the user opposes deletion. c. When the data is no longer needed for processing but required by the user for legal claims. 6. **Request Process** 6.1 Users must submit requests through the designated email address or online form provided in the Contact Information section. 6.2 To verify identity, users may be required to provide a copy of a government-issued ID or confirm account details. 6.3 Claridigm Inc. will acknowledge receipt of the request within 5 business days and provide a full response within 30 calendar days. If additional time is required, users will benotified of the extension and the reasons for it. 7. **Limitations and Exceptions** 7.1 Claridigm Inc. may deny requests that are unreasonable, unlawful, or repetitive. 7.2 Users will not be discriminated against for exercising their rights. 8. **Transparency in Data Sharing** 8.1 Users are informed that their personal information may be shared with sponsoring clients upon request, but only under strict conditions and in compliance with applicable laws. 9. **Legal Compliance** 9.1 Claridigm Inc. complies with all applicable laws, including the Illinois Biometric Information Privacy Act (BIPA) and the California Consumer Privacy Act (CCPA), where relevant. 10. **Contact Information** 10.1 Users may submit requests or inquiries regarding their rights by contacting Claridigm Inc. at: Email: privacy@claridigm.com 

#Data Retention

1. **Retention Periods by Data Type**: 1.1. Names and Email Addresses: Retained for the duration of the user’s account and up to three (3) years after account closure to fulfill operational and legal requirements. 1.2. Gateway ID Numbers: Retained for one (1) year following the user ’s last interaction with the company’s services for purposes of service improvement and analytics. 1.3. Support Tickets: Retained for five (5) years to ensure quality assurance and compliance with applicable legal obligations. 2. **Criteria for Retention**: 2.1. Retention periods are determined based on: a. Legal obligations, including tax, audit, and regulatory requirements. b. Operational needs, such as service improvement, analytics, and dispute resolution. c. User consent or specific requests for deletion, where applicable. 3. **Secure Deletion or Anonymization**: 3.1. Upon expiration of the applicable retention period, personal information will be securely deleted or anonymized to prevent unauthorized access, misuse, or identification. 4. **Exceptions**: 4.1. Personal information may be retained beyond the specified periods in the following circumstances: a. Ongoing legal disputes, investigations, or enforcement actions. b. Compliance with regulatory or statutory requirements mandating extended retention. 5. **Transparency and User Rights**: 5.1. Users have the right to request access to or deletion of their personal information at any time, subject to operational and legal requirements. 5.2. Requests for deletion will be processed in accordance with applicable laws and the company’s operational capabilities. 6. **Compliance with Jurisdictional Laws**: 6.1. Claridigm Inc.’s data retention practices comply with all applicable laws, including but not limited to the California Consumer Privacy Act (CCPA) and relevant Illinois-specific regulations. 7. **Updates to Retention Practices**: 7.1. Claridigm Inc. reserves the right to update its data retention practices to reflect changes in legal, operational, or business requirements. 8. **Clarity and Accessibility**: 8.1. This Data Retention policy is designed to be clear and accessible to all users, ensuring transparency in how personal information is managed. #Security Measures

1. **Data Encryption** 1.1. All personal information collected by Claridigm Inc. is encrypted both in transit using TLS/SSL protocols and at rest using AES-256 encryption. 1.2. Encryption keys are securely managed and rotated periodically to ensure data integrity and security.

2. **Access Controls** 2.1. Access to personal information is restricted to authorized personnel only, based on the principle of least privilege. 2.2. Multi-factor authentication (MFA) is implemented for all internal systems handling sensitive data to prevent unauthorized access.

3. **Employee Training** 3.1. Employees undergo regular training on data protection, cybersecurity best practices, and compliance with applicable laws and regulations. 3.2. Training programs are updated periodically to address emerging threats and changes in legal requirements.

4. **Physical Security** 4.1. Personal information is stored in secure facilities equipped with physical safeguards, including biometric access controls, surveillance systems, and 24/7 monitoring. 4.2. Access to these facilities is limited to authorizedpersonnel only.

5. **Network Security** 5.1. Claridigm Inc. employs firewalls, intrusion detection/prevention systems (IDS/IPS), and regular vulnerability assessments to protect its network from unauthorized access and cyber threats. 5.2. Security patches and updates are applied promptly to maintain system integrity.

6. **Regular Security Audits** 6.1. The company conducts regular internal and third-party security audits to identify and address vulnerabilities in its systems and processes. 6.2. Audit findings are reviewed and remediated promptly to ensure continuous improvement in security measures.

7. **Incident Response Plan** 7.1. Claridigm Inc. has a robust incident response plan in place to detect, contain, and mitigate any data breaches or security incidents. 7.2. Affected users will be notified promptly in compliance with applicable laws and regulations.

8. **Data Minimization and Retention** 8.1. The company collects only the personal information necessary for its operations and processes it solely for the purposes outlined in its privacy policy. 8.2. Personal information is retained only for as long as required by law or business needs, after which it is securely deleted or anonymized.

9. **Third-Party Security** 9.1. Any third-party service providers engaged by Claridigm Inc. to handle personal information are required to adhere to equivalent security standards through binding contractual agreements. 9.2. Regular assessments are conducted to ensure third-party compliance with these standards.

10. **Disclaimer** 10.1. While Claridigm Inc. implements reasonable and industry-standard measures to protect personal information, no system is entirely secure. 10.2. Users are encouraged to take precautions to protect their own information, such as using strong passwords and safeguarding their account credentials. #Use of Cookies and Tracking Technologies

1. **Introduction to Cookies and Tracking Technologies** 1.1. Claridigm Inc. uses cookies and other tracking technologies to collect information about user interactions with its website and services. 1.2. Cookies are small text files stored on a user ’s device, while tracking technologies, such as web beacons and pixel tags, are tools used to monitor user behavior and improve service delivery.

2. **Types of Cookies and Tracking Technologies Used** 2.1. **Essential Cookies**: These cookies are necessary for the website to function properly, such as enabling user authentication and maintaining session integrity. 2.2. **Performance and Analytics Cookies**: These cookies collect data on user behavior to help analyze website performance and improve services. 2.3. **Functional Cookies**: These cookies enhance user experience by remembering preferences, such as language settings or login details. 2.4. **Advertising/Targeting Cookies**: If applicable, these cookies are used to deliver personalized marketing content based on user interests. 2.5. **Other Tracking Technologies**: Claridigm Inc. may use web beacons or pixel tags to monitor user engagement and optimize service offerings.

3. **Purpose of Using Cookies** 3.1. To ensure the website and services function correctly. 3.2. To analyze user behavior and improve the overall user experience. 3.3. To provide personalized content and recommendations. 3.4. To support customer service and account management processes.

4. **Third-Party Involvement** 4.1. Claridigm Inc. may use third-party cookies or tracking technologies provided by analytics services, such as Google Analytics, to gather insights into user interactions. 4.2. These third parties may have access to user data collected through cookies, subject to their respective privacy policies.

5. **User Control and Consent** 5.1. Users can manage their cookie preferences through the cookie banner displayed on the website or by adjusting their browser settings. 5.2. Users may opt out of non-essential cookies; however, disabling certain cookies may affect website functionality and user experience.

6. **Data Retention and Security** 6.1. Cookies and tracking data are retained only for as long as necessary to fulfill their intended purposes. 6.2. Claridigm Inc. ensures that data collected through cookies is stored securely and processed in compliance with applicable privacy regulations.7. **Compliance with Laws** 7.1. This clause is designed to comply with relevant privacy laws, including the California Consumer Privacy Act (CCPA) and Illinois privacy regulations. 7.2. Claridigm Inc. is committed to maintaining transparency and protecting user rights in accordance with industry standards.

8. **Updates to the Clause** 8.1. Claridigm Inc. reserves the right to update this clause periodically to reflect changes in technology, legal requirements, or business practices. 8.2. Users will be notified of any significant updates through the website or other appropriate channels.

9. **Contact Information** 9.1. For questions or concerns regarding the use of cookies and tracking technologies, users may contact Claridigm Inc. at Webinq@claridigm.com  #Children's Privacy

1. **Commitment to Children's Privacy** Claridigm Inc. is committed to protecting the privacy of children under the age of 13 in compliance with the Children's Online Privacy Protection Act (COPPA) and other applicable laws. 2. **Data Collection Policy** 2.1. Claridigm Inc. does not knowingly collect personal information from children under the age of 13. 2.2. The services provided by Claridigm Inc. are not intended for use by children under the age of 13. 3. **Parental Consent** 3.1. If it becomes necessary to collect personal information from children under the age of 13 for a specific service, Claridigm Inc. will obtain verifiable parental consent prior to collecting such information. 3.2. The process for obtaining parental consent may include requiring a signed consent form or other verifiable methods as permitted by applicable laws. 4. **Inadvertent Data Collection** 4.1. In the event that Claridigm Inc. becomes aware of inadvertently collecting personal information from a child under the age of 13, the company will take immediate steps to delete such information from its records. 5. **Parental Rights** 5.1. Parents have the right to review, delete, or refuse further collection of their child's personal information. 5.2. To exercise these rights, parents may contact Claridigm Inc. at Webinq@claridigm.com. 6. **Protective Measures** 6.1. Claridigm Inc. employs industry-standard security measures to protect any personal information collected from children under the age of 13, should such data ever be collected with parental consent. 7. **Transparency and Updates** 7.1. Claridigm Inc. will notify parents of any material changes to this Children's Privacy clause. 7.2. The company is committed to updating this clause as necessary to remain compliant with evolving laws and regulations. 8. **Contact Information** For any questions or concerns regarding children's privacy, please contact Claridigm Inc. at webinq@claridigm.com . #Changes to the Privacy Policy

1. **Right to Modify** Claridigm Inc. reserves the right to update or modify this Privacy Policy at its sole discretion.

2. **Notification Methods** Users will be notified of significant changes to this Privacy Policy through one or more of the following methods: a. Posting a notice on the company’s website. b. Sending an email to registered users. c. Utilizing other appropriate communication channels.

3. **Effective Date** Changes to this Privacy Policy will become effective on the date specified in the updated policy. If no date is specified, changes will take effect immediately upon posting.

4. **User Responsibility** Users are encouraged to review this Privacy Policy periodically to stay informed about how their information is being protected and processed.

5. **Implied Consent** Continued use of Claridigm Inc.’s services after any changes to this Privacy Policy constitutes acceptance of the updated terms.

6. **Archiving Previous Versions** Previous versions of this Privacy Policy will be archived and made available upon request for reference.7. **Compliance with Laws** All updates to this Privacy Policy will comply with applicable Illinois privacy laws and broader U.S. regulations, including but not limited to the California Consumer Privacy Act (CCPA). 8. **Contact Information** For questions or concerns regarding changes to this Privacy Policy, users may contact Claridigm Inc. at [email address].#Marketing Communications

1. **Purpose of Marketing Communications** Claridigm Inc. may send marketing communications to inform users about new features, updates, or services that aim to enhance their experience with the company.

2. **Opt-In Mechanism** Users will only receive marketing communications if they have explicitly opted in by selecting the relevant option during account registration or through their account settings.

3. **Opt-Out Mechanism** Users may opt out of receiving marketing communications at any time by clicking the "unsubscribe" link included in each email or by updating their preferences in their account settings.

4. **Types of Communications** Marketing communications may include newsletters, promotional offers, and updates about Claridigm Inc.’s services.

5. **Frequency of Communications** Claridigm Inc. will limit marketing communications to no more than two emails per month to ensure users are not overwhelmed.

6. **Third-Party Sharing** Claridigm Inc. does not share users’ personal information with third parties for their marketing purposes.

7. **Compliance with Laws** All marketing communications will include Claridigm Inc.’s physical address and a clear option to unsubscribe, in compliance with applicable laws, including the CAN-SPAM Act.

8. **Data Retention for Marketing** User information will be retained for marketing purposes only as long as the user remains subscribed to receive such communications.

9. **User Control and Transparency** Users can manage their marketing preferences at any time through their account settings, ensuring full control over their choices.

10. **Contact Information for Queries** For any questions or concerns regarding marketing communications, users may contact Claridigm Inc. at support@claridigm.com.

#Contact Information

1. **Dedicated Email Address**: For inquiries or concerns related to this Privacy Policy, users may contact Claridigm Inc. via email at **privacy@claridigm.com**. This email address is monitored regularly to ensure timely responses.

2. **Physical Mailing Address**: Users who prefer to send written correspondence may address their inquiries to: **Claridigm Inc.** 332 S. Michigan Ave, Suiite 1032 #C250,  Chicago, IL 60604-4434, USA.

3. **Phone Number for Urgent Concerns**: For urgent privacy-related matters, users may contact us at **(773) 609-0646** during business hours (9 AM - 5 PM CST).

4. **Purpose of Contact**: The provided contact details are intended exclusively for questions, concerns, or requests regarding this Privacy Policy. For other matters, please visit our general support page at Claridigm.com.

5. **Response Time**: Claridigm Inc. aims to respond to all inquiries within **5 business days**. However, response times may vary depending on the complexity of the request.

6. **Updates to Contact Information**: This contact information is subject to change. Users are encouraged to review this Privacy Policy periodically for the most up-to-date details.#Severability# If any provision of this Agreement is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be deemed severed from this Agreement and shall not affect the validity, legality, or enforceability of the remaining provisions. The parties agree to replace any invalid provision with a valid provision that most closely approximates the intent and economic effect of the invalid provision.

Waiver# The failure of either party to enforce any provision of this Agreement or to exercise any right or remedy provided herein shall not be construed as a waiver of such provision, right, or remedy. Any waiver must be in writing and signed by the waiving party. A waiver of any specific breach or default shall not constitute a waiver of any subsequent breach or default.Entire Agreement# This Agreement constitutes the entire understanding between the parties with respect to the subject matter herein and supersedes all prior or contemporaneous agreements, representations, or understandings, whether written or oral. No amendment or modification of this Agreement shall be effective unless made in writing and signed by both parties.

Attestation# IN WITNESS WHEREOF, the undersigned hereby acknowledge that they have read and understood the terms and conditions of this Agreement, dated as of the 1st of January 2025, made between Claridigm Inc. (hereinafter referred to as "the Company") and the undersigned party. The undersigned affirms that the information provided in this Agreement is true and accurate to the best of their knowledge. The Company confirms its commitment to adhering to the terms and conditions outlined in this Agreement.