Privacy Policy and Notice of Personal Information Collection

1. SCOPE OF THIS PRIVACY POLICY

Cartera Commerce, Inc. (“Cartera”) provides its services (“Services”) to its business clients. This Privacy Policy describes how Cartera Commerce, Inc. (“Cartera”) handles personal information it may collect about business contacts, client representatives, or prospective clients through your use of this website (the "Site") or in the course of administering or managing Cartera's Service offerings. As used in this Privacy Policy, personal information is any information about you as an individual, as well as a combination of pieces of information that could reasonably allow you to be identified. Cartera is part of the Rakuten Group, which includes the affiliates and subsidiaries of our parent company, Rakuten Group, Inc., based in Tokyo, Japan. To the extent you click through from this Site to our Rakuten Group Careers page or apply for a job with Cartera or another Rakuten Group company, our global Recruitment Privacy Policy will govern the personal information collected from and about you during the recruiting process.

Our Site and Services are intended for adults 18 years of age or over, and we do not knowingly collect, sell, share, or process for targeted advertising the personal information of individuals under 16 years of age without affirmative authorization or without verifiable opt-in consent from a parent for those under age 13.

Note that the Site may contain links to third party websites, which are governed by their own terms of use and privacy policies. This Privacy Policy covers only our collection and use of your personal information and does not include any practices on third-party sites you may choose to visit via a link.

2. CATEGORIES AND SOURCES OF PERSONAL INFORMATION WE COLLECT

We collect personal information directly from you when you voluntarily provide it to us or when you request information or services from us. The categories of personal information that we collect directly from you are

1. Identifiers, such as your name and your business contact details (e.g. business phone number, business email address)
2. Any personal information in the content of any messages or requests you send us or otherwise provide to us

We also collect certain personal information automatically from or about you when you visit our Site or use our Services, including:

1. Identifiers for devices you have used to access our websites, including the IP address and MAC identifiers
2. Internet or other electronic network activity information
1. Information about your interaction, communication, and connectivity data
2. Websites you visited prior to coming to the Site
3. Information about your access and use of the Site, including clicks, internal links, pages viewed or visited, scrolling, searches, and timestamps
4. Information about your use of our Services and platforms or access to dashboards or reporting information.

Some of the automatically collected data comes from “cookies” and other device-identifying technologies. A cookie is a small amount of data that is sent to your browser from our web server. We primarily use cookies that are considered “essential” and to collect statistical information on the usage of our Site. Our use of cookies also allows us to track where users go when they visit the Site and to obtain high-level data such as the referral web domain, type of operating system/browser used, date and time of visit, and other information relating to activities on our Site. This Site uses cookies that are necessary to provide the Site and its core functionality; we do not use cookies to retrieve information from your computer or device for purposes that are unrelated to our Site or your interaction with our Site. You may stop or restrict cookies on your computer or purge them from your browser by adjusting your web browser preferences.

We do not collect, use, or disclose any personal information that is defined as “sensitive” personal information under the California Consumer Privacy Act of 2018, as thereafter amended (“CCPA”) or other U.S. state privacy laws.

3. HOW WE USE YOUR PERSONAL INFORMATION

For the purposes of responding to and resolving your service requests related to our Services, we may use your personal contact information, identifiers, and the content of your request, as well as any additional information we collect from you regarding the issue.

To respond to your inquiries about our Services, we use your personal contact information and the content of your inquiry to contact you.

To improve security, analyze and understand Site usage, and administer and optimize the Site, we automatically log your IP address (a unique code assigned to every computer using the internet) when you visit the Site, and use the information we collect about your access of and activity on the Site.

To improve our Services offerings, we use information you provide us in service requests as well as information about your use of and engagement with our Site and Services.

We may also deidentify or aggregate your personal information for the above or other purposes, and if we do, we maintain this type of information in a deidentified manner and do not attempt to re-identify it.

4. DISCLOSURE OF PERSONAL INFORMATION

We may disclose for business purposes all the categories of your personal information described in Section 1 to the following types of parties:

1. Service providers that perform business operations and analytics for us.
2. Law enforcement agencies, courts, regulators, and government authorities where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
3. Asset purchasers, such as any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this privacy notice.

We do not “sell”, “share”, or process personal information for “targeted advertising” as those terms are defined in the CCPA and other U.S. State privacy laws.

5. YOUR PRIVACY RIGHTS

You have certain rights in relation to your personal information, under applicable privacy laws, subject to certain exceptions.

Right to Know and Access:

You have the right to know the personal information about you that we collected, used, and disclosed and for what business purposes, including the categories of sources from which we acquired your information and the categories of third parties to whom we disclosed your information for a business purpose.

You have the right to request the above information from us, as well as a copy of the specific pieces of personal information we have collected about you.

Right to Request Deletion:

You have the right to request that we delete any personal information we collected from you or maintain about you. We will delete your personal information, except to the extent we determine that we need the information for a business purpose and have a legal right to maintain it, or if a legal exception applies, in which case we will inform you of that exception.

Right to Correct:

You have the right to request that we correct any inaccurate or incomplete personal information we collected from you or maintain about you, subject to certain exceptions.

Right to Non-Discrimination:

We will not discriminate against you for exercising any of your privacy rights. In accordance with applicable law, we will not do any of the following because you request to know, access, or delete your personal information:

1. deny you goods or services
2. charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
3. provide you a different level or quality of goods or services, or
4. suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Right to Appeal:

You may have the right to appeal our decision regarding your privacy rights request, depending on your state of residence. You may submit an appeal request by contacting us as set forth in Section 10, below. We will respond according to the law applicable in your location.

6. HOW TO EXERCISE YOUR PRIVACY RIGHTS:

To assert your privacy rights, please contact us as provided in Section 10, below. We will need to verify your identity prior to processing any access, correction, or delete request. If we cannot verify your identity from the information we have on file, we may request additional information from you, which we will only use to verify your identity, fulfill your request, and for security or fraud-prevention purposes.

Please note that under certain state laws, we are not required to respond to requests to know/access your personal information more than twice per calendar year.

Agents: Only you, or someone legally authorized to act on your behalf, may make a consumer request related to your personal information. For any agent making a request on your behalf, we may require you to prove that you authorized this agent to submit a request on your behalf, and we will require you to independently verify your identity.

7. DATA RETENTION

We may retain information about you for as long as it is necessary to fulfill the purposes described in Section 2. Some of your information may be retained in our systems even after you request your information to be deleted if an exception applies, including in order to comply with our obligations under applicable law, collect fees owed, resolve disputes, enforce our legal rights, undertake any investigations necessitated by the foregoing, or otherwise use internally in a lawful manner that is reasonably aligned with reasonable consumer expectations and compatible with the context in which the information was provided.

8. INFORMATION SECURITY

We have implemented technical and organizational measures to provide a level of security appropriate to the risk to the personal information that we process. These measures are aimed at preserving the ongoing integrity and protecting the confidentiality of users' personal information. We evaluate these measures on a regular basis to confirm that they continue to maintain and apply an appropriate level of security.

9. CHANGES TO THE PRIVACY POLICY

This Privacy Policy is current as of the effective date set forth above. We reserve the right to modify or update this Privacy Policy from time to time consistent with applicable privacy laws and principles and our practices in relation to personal information. If we change this Privacy Policy, we will notify you by revising the effective date of this Privacy Policy. In the event of a material change, we will provide you with additional notice (such as adding a statement to the homepages of our Site or sending you an email notification).

10. CONTACT US

If you have any questions or suggestions regarding this Privacy Policy, or to exercise your privacy rights described in Section 5 above, please contact us at:

• Email: customerservice@cartera.com
• Phone: (781) 541-6800
• Fax: (781) 541-6801

• Address:
• Cartera Commerce, Inc.
• One Cranberry Hill, Suite 203
• Lexington, MA 02421
• Attn: Customer Care