Cayuse Privacy & Cookie Policies

Last updated August 19, 2021

Thank you for choosing to be part of the community. Cayuse LLC (“Company”, “we”, “us”, “our”) provides the Services (as described below). This Privacy Notice applies to personal information collected by or on behalf of the Company, including information collected through our websites, including https://www.cayuse.com, https://haplo.com, https://community.cayuse.com or any other site which links to this Privacy Notice (collectively, the “Website”), mobile versions of the Website, by email, in-person, by phone or anywhere else we display this Privacy Notice (collectively, with the Website referred to as the “Services”). Information obtained from the Company’s customers pursuant to our contractual arrangements and use of our products (“Customer Data”) is subject to the privacy and data protection requirements set forth in those agreements and is processed at the direction of the respective customer. If you have questions about Customer Data, please contact the relevant data controller for further assistance or contact isc@cayuse.com for help in identifying the appropriate contact.

“You” or “your” refers to the person accessing and using the Services.

We use the term “personal information” to describe information that is about you and which identifies you.

Please read this Privacy Notice carefully. This Privacy Notice explains the data we collect, how we use it, how we share it, and your choices. If there are any terms in this Privacy Notice that you do not agree with, please discontinue the use of the Services immediately. If you have any questions or concerns about this Privacy Notice or our practices with regards to your personal information, please contact us at isc@cayuse.com.

TABLE OF CONTENTS:

1. WHAT INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?

The personal information that we collect depends on the context of your interactions with us and the Services.

Information You Provide

We collect personal information that you voluntarily provide to us when you visit or interact with the Services or otherwise contact us. For example:

When you express an interest in obtaining information about our Company or our products and services, when you participate in activities through the Services, such as signing up for a webinar, or otherwise when you otherwise interact with or contact us via the Services. Such information may include your name, company name, and title, business email address, mailing address or phone number, or similar contact information.

If you complete one of our web forms for more information or to receive a copy of the resources available on our Services, the personal information we collect may include your name, company name, business phone number, business email address, and job title, etc.

When you apply for a job with us or submit related inquiries to us, we collect the personal information you provide with your submissions, such as your name, email address, phone number, city, employment and education background and experience, and any other information you choose to provide in your resume, cover letter or linked bios. If you elect to share such information with us, we also may collect certain demographic information related to your gender, race or ethnicity, disabilities, or veteran status.

The Services depend on your providing accurate information to us. Please update us of any changes to your information by contacting isc@cayuse.com.

Information Collected Automatically

We may also collect certain information automatically when you visit, use or navigate the Website, using tools such as pixels or “cookies”. This information typically does not identify you individually as a person but may include device and usage information, such as your IP address, browser, and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Website and other technical information. This information is primarily needed to maintain the security and operation of the Website, and for our internal analytics and reporting purposes. Please see our Cookie Policy for additional information.

The information we collect automatically includes:

Device Data. We collect device data such as information about your computer, phone, tablet, or other devices you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system, and system configuration information.

Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt-out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note, however, if you choose to opt-out, you may not be able to use certain aspects of the Services.

Information from Third-Party Sources

If you connect with us or interact with us through third-party sites or applications such as social media platforms, the third party may send us your information such as your profile information from that platform. This includes when you log in using a third-party platform, such as Facebook or Google. We may disclose information collected from third parties to customize ads and to manage and facilitate messaging to you on third-party platforms. We also may periodically obtain both personal and non-personal information about you from other sources, such as affiliated entities, advertising and business partners, data providers, and other third-party sources, and add it to our information to better customize our offerings to you.

2. HOW DO WE USE YOUR INFORMATION?

We use personal information collected via the Services for a variety of commercial business purposes described below.

We use the information we collect or receive to provide the Services, including:

To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.

To post testimonials. We post testimonials on the Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update or delete your testimonial, please contact us at isc@cayuse.com and be sure to include your name, testimonial location, and contact information.

Request feedback. We may use your information to request feedback and to contact you about your use of the Services.

To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.

To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.

To deliver and facilitate the delivery of services to the user. We may use your information to provide you with the requested service, such as confirming your webinar registration, providing a copy of an e-book, workbook, or white paper.

To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or the Services, subscribing to marketing, or otherwise contacting us, we will collect personal information from you. You can opt out of our marketing emails at any time (see the “MY RIGHTS AND CHOICES” below).

Deliver targeted advertising to you. Depending on your preferences, we may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

In particular, your personal information may be used by us, our employees, service providers, and disclosed to third parties for the following purposes listed above and below. For each of these purposes, we have set out the legal basis on which we use your personal information.

Purpose	Legal Basis
To provide the Services to you;	For our legitimate business interests (i.e., the provision of the Website and the Services) and, depending on the circumstances, to perform a contract between you and us
To communicate with you and to respond to questions that you have raised with us;	For our legitimate business interests (i.e., the provision of the Website and the Services)
To register individuals for events (i.e., conferences, etc.);	For our legitimate business interests (i.e., the provision of the Website and the Services)
To forward information concerning upcoming events (including details of any events which we believe may be of interest to you) or about products or services in accordance with your preferences as indicated when you entered into any agreement with us, including marketing consent preferences;	For our legitimate business interests (i.e., the provision of the Services). We may request your consent in circumstances
To provide you with products or services that you have requested or purchased;	For our legitimate business interests (i.e., the provision of the Services)
To administer the Website;	For our legitimate business interests (i.e., the provision of the Website)
To prevent and detect fraud; and	For our legitimate business interests and for compliance with legal obligations to which we are subject
To protect and enforce our legal rights.	For our legitimate business interests and for compliance with legal obligations to which we are subject

Where we rely on the legitimate interests of Company or those legitimate interests of a third party to justify the purposes for using your personal information, this will include improvement and development of our business operations and service offerings, or those of a third party; or protection of our business, employees, or those of a third party.

3. WHO WILL YOUR INFORMATION BE SHARED WITH?

We may share your personal information in the following situations:

Intercompany Transfers. We may share or transfer your information to our subsidiaries, including Haplo Services Ltd.

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service, website analytics, and marketing efforts, including content optimization, retargeting, and social media advertising. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data on our behalf about how you interact with our Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages, or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

4. USERS OUTSIDE THE U.S.

Cayuse is located in the United States and the Services are operated in the United States. If you are accessing the Services from outside the United States, please be aware that your information will be transferred to, stored, and processed by us or our service providers in the United States where the data protection laws may not be as protective as the country in which you are located. By providing personal information through the Services, you agree that such information will be transferred, processed, used, and stored as set forth in this Privacy Notice and subject to the laws of the United States.

5. DATA RETENTION

We will retain your personal information for as long as is necessary for the purposes for which it was collected. The precise period will depend on the reason why it was collected. Those periods are also based on the requirements of applicable data protection laws, applicable legal and regulatory requirements, and periods relating to the commencement of legal actions.

6. INFORMATION SECURITY

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, we cannot guarantee the security of your personal information transmitted to or via the Services and any transmission is at your own risk.

7. LINKS TO THIRD-PARTY SITES

We may provide links on the Website or Services to third-party websites we think may be of interest to you, including links to social media sites such as LinkedIn, Twitter, or Facebook or links to event registration content provided by third parties such as Zoom. Please note that these websites are independent of the Website or Services and we are not responsible for the content or privacy practices of such other sites or platforms. When you click on links on the Website or Services that take you to a third-party website, you will be subject to the third party’s privacy policies. Therefore, we encourage you to be aware when you leave the Website and to read the privacy policies of any other website or service you visit.

8. CHILDREN

We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at isc@cayuse.com.

9. MY RIGHTS AND CHOICES

You may contact us using the contact information provided at the end of this Privacy Notice if you have any questions, or if you wish to update, correct, or amend your personal information. (For individuals located in the EEA, UK, or Switzerland, please also see “Your GDPR Rights” and for individuals located in California, please also see “Notice to California Residents” below). Please note that we may not be able to correct or update your personal information previously provided to us by third parties. As mentioned above, we may use your personal information to contact and correspond with you and to respond to your inquiries. We may send you emails or other communications regarding our products and services. We will provide you the opportunity to “opt-out” or unsubscribe from these emails (e.g., the email we send you will tell you how to decline future emails from us).

10. NOTICE TO CALIFORNIA RESIDENTS

This section describes the personal information (as defined by the California Consumer Privacy Act of 2018 or the “CCPA”) we collected about California residents in the last 12 months, the sources of that information, our business or commercial purposes for collecting the information, and the third parties with whom we shared that information. Please refer to the corresponding sections of this Privacy Notice for details on the following:

WHAT INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT? This section describes the categories of personal information we collected and the categories of sources from which the information was collected.

HOW DO WE USE YOUR INFORMATION? This section describes the business or commercial purposes for which we collected the information.

WHO WILL YOUR INFORMATION BE SHARED WITH? This section lists the categories of third parties with whom we shared personal information.

Your CCPA Rights and How to Exercise Them

California residents have certain rights under the CCPA. Those rights may only apply in certain circumstances and may be subject to limitations or exceptions. A summary of those rights is provided below as well as information on how to exercise your rights. Please note that we will require certain identifying information about you as necessary for us to verify your request in accordance with applicable law.

Right to Know: You have the ask us to tell you the categories of personal information we collected, used, disclosed, and/or sold about you in the last 12 months. To exercise this right, please call us toll-free at 877.689.3661 or email your request to isc@cayuse.com and include “Disclosure Request” in the subject line of your email.

Right to Access: You have the right to request access to the personal information specific to you individually, that we collected, used, disclosed, and/or sold about you in the last 12 months. To exercise this right, please call us toll-free at 877.689.3661 or email your request to isc@cayuse.comand include “Access Request” in the subject line of your message.

Right to Opt-Out of Sale: You have the right to opt-out or ask us not to sell your personal information. To exercise this right, [insert method]. We do not sell your personal information in exchange for money. We do share certain information with third parties to market products, services, and other offers we think may be of interest to you. The CCPA broadly defines the concept of “selling” information so we offer the opportunity for CA residents to opt-out of our sharing information with third parties in this manner. Please note that if you opt-out of this information sharing with us, we will remove you from these activities; however, other companies may continue to use and disclose your information in the same manner. You should opt-out of these practices with those other companies and websites, as applicable.

Right to Delete: You have the right to request us to delete the personal information we collect or maintain about you. Please note that certain exceptions may apply to your right to delete information, such as when we must retain your information to comply with the law. We will notify you if any such exceptions apply to your request. To exercise this right, please call us toll-free at 877.689.3661or email us at isc@cayuse.com, and include “Deletion Request” in the subject line of your message.

We do not discriminate against you for requesting any of the rights noted above. However, we may offer certain financial incentives, charge reasonable fees related to your requests, or deny your request in accordance with applicable law.

You can exercise these rights yourself or you can designate an authorized agent to make a request on your behalf. Your authorized agent must be able to demonstrate authority to act on your behalf as further instructed when submitting a verifiable request on your behalf.

How We Disclose Information

In the last 12 months, we disclosed or sold your name, email address, phone number, device ID, IP address, browser type, and certain browsing activity or user feedback content to third parties for the commercial purposes of marketing and customizing our services and product offerings to you. Again, we do not sell your personal information in exchange for money. We do not sell the personal information of minors under age 16.

Third-Party Marketing

Under California Civil Code § 1798.83, California residents with whom we have a business relationship can request information about the types of personal information, if any, we shared with third parties for the direct marketing purposes of the third parties and the identities of the third parties with whom we shared such information in the last 12 months. We do not share your personal information with third parties in this manner and have not done so in the last 12 months. You may request more information by contacting us using the contact information provided in the “Contact Us” section below.

11. YOUR GDPR RIGHTS

If your personal information is protected by the GDPR or UK GDPR (i.e., you are located in the European Economic Area, UK, or Switzerland), then you have certain data protection rights described below with respect to the personal information collected and used by us. These rights may only apply in certain circumstances and are subject to certain exemptions. You can exercise these rights using the contact details at the end of this Privacy Notice (see “Contact Us” below). The rights are as follows:

	Summary of your rights
Right of access to your personal information	You have the right to receive a copy of the personal information that we hold about you, subject to certain exemptions.
Right to rectify your personal information	You have the right to ask us to correct your personal information that we hold where it is incorrect or incomplete.
Right to erasure of your personal information:	You have the right to ask that your personal information be deleted in certain circumstances. For example (i) where your personal information is no longer necessary in relation to the purposes for which they were collected or otherwise used; (ii) if you withdraw your consent and there is no other legal ground for which we rely on for the continued use of your personal information; (iii) if you object to the use of your personal information (as set out below); (iv) if we have used your personal information unlawfully; or (v) if your personal information needs to be erased to comply with a legal obligation.
Right to restrict the use of your personal information	You have the right to suspend our use of your personal information in certain circumstances. For example (i) where you think your personal information is inaccurate and only for such period to enable us to verify the accuracy of your personal information; (ii) the use of your personal information is unlawful and you oppose the erasure of your personal information and request that it is suspended instead; (iii) we no longer need your personal information, but your personal information is required by you for the establishment, exercise or defense of legal claims; or (iv) you have objected to the use of your personal information and we are verifying whether our grounds for the use of your personal information override your objection.
	You have the right to obtain your personal information in a

Right to data portability	structured, commonly used and machine-readable format and for it to be transferred to another organization, where it is technically feasible. The right only applies where the use of your personal information is based on your consent or for the performance of a contract, and when the use of your personal information is carried out by automated (i.e. electronic) means.
Right to object to the use of your personal information	You have the right to object to the use of your personal information in certain circumstances. For example (i) where you have grounds relating to your particular situation and we use your personal information for our legitimate interests (or those of a third party); and (ii) if you object to the use of your personal information for direct marketing purposes.
Right to withdraw consent	You have the right to withdraw your consent at any time where we rely on consent to use your personal information.
Right to complain to the relevant data protection authority	You have the right to complain to the relevant data protection authority where you think we have not used your personal information in accordance with data protection law.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

9. DO-NOT-TRACK; THIRD-PARTY TRACKING

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, the Website does not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice. More information about “do not track” is available at www.allaboutdnt.org concerning such information. Third parties, other than our vendors (such as our website analytics provider), do not have authorization from us to track which websites you visited prior to and after visiting the Website. That said, we cannot control third-party tracking and there may be some third-party tracking that occurs without our knowledge or consent.

10. THIRD-PARTY LINKS

The Website may contain links to the websites of third parties. We have no control over the content or operation of these websites, nor do we control the confidentiality or privacy practices of the website operators. Consequently, any personal information you submit through such websites is

governed by the privacy policies of the websites in question. It is therefore your responsibility to find out about the third-party policies in order to protect information that concerns you.

11. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time. The updated version will be indicated by the “Last Updated” date and the updated version will be effective as soon as it is posted. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

12. CONTACT US; DATA CONTROLLER

If you have questions or comments about this notice, you may email us at isc@cayuse.com or by mail to:

Cayuse, LLC

121 Southwest Salmon Street

Suite 900

Portland, OR 97204

United States

Cayuse, LLC is the data controller for the purpose of data protection law, in respect of your personal information collected and used through your use of the Website and the Services. This is because we dictate the purpose for which your personal information is used and how we use your personal information.

Last updated August 19, 2021

This Cookie Policy explains how Cayuse, LLC (“Company”, “we”, “us”, and “our”) uses cookies and similar technologies to recognize you when you visit our websites at https://www.cayuse.com or https://haplo.com, https://community.cayuse.com (collectively, the “Website”).

In some cases, we may use cookies to collect personal information or pieces of information that become personal information if combined. In such cases, our Privacy Policy (https://www.cayuse.com/privacy) will apply in addition to this Cookie Policy.

What are cookies and why do we use them on our Website?

Cookies are small data files that are placed on your computer or mobile device when you visit our Website. Cookies are used by Website owners for a variety of reasons. Cookies allow us to recognize your device, allow our Website to remember certain pieces of information about you, and perform analytics and other functions in relation to your, and others, use of our Website. This helps us to provide you with a good, secure, and personalized experience when you browse our Website and allows us to improve our Website over time.

Cookies set by the website owner (in this case, Cayuse, LLC) are called “first-party cookies”. First-party cookies are used to help evaluate and enable the performance and secure functionality of our Website. These cookies may also enable us to collect or remember certain usage data about your device, potentially including website pages visited prior, during, and after visiting our Website, clicks or interactions made with the pages on our Website, consents, and preferences, time spent on our pages and date/timestamps of visits and interactions, device identifiers such as IP address or operating system type, and browser type.

Cookies set by parties other than the Website owner are called “third-party cookies”. Third-party cookies enable third-party features or functionality to be provided on or through our Website (e.g., advertising, interactive content, and analytics). The parties that set these third-party cookies can recognize your computer both when it visits the Website in question and also when you visit certain other websites.

In addition to the reasons mentioned above, we may use first and third party cookies for the following:

Technical reasons for our Website to operate efficiently a.k.a. “essential” or “strictly necessary” cookies;
To track and target the interests of our users to enhance the experience on our Website; and
Advertising and analytical purposes.

What are the types of cookies used on our Website?

We use the following types of cookies for the following purposes:

Strictly Necessary Cookies (a.k.a. Essential Cookies): These cookies are essential for you to browse our Website and use their intended functionality, including accessing secure areas of our Website. These cookies cannot be rejected.

Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They help us to know which pages are the most and least popular and see how visitors move around our Website. All the information these cookies collect is aggregated and therefore not intended to identify you individually. If you do not allow these cookies, we will not know when you have visited our Website.

Functional Cookies: These cookies enable the Website to provide enhanced functionality. They may be set by us or by third-party service providers whose services we have added to pages of our Website.

Marketing Cookies: These cookies may be set on our Website by our advertising and marketing service providers. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They are based on uniquely identifying your browser and internet device. This recognition is used to serve relevant adverts, links, or other information about our products and services to users visiting other websites after having previously visited our Website or interacted with our products and services. If you consent to these cookies, you may experience targeted advertising.

How can I control cookies?

IF A COOKIE CONSENT MANAGER IS IN USE:

You have the right to decide whether to accept or reject cookies. You can exercise your cookie rights by setting your preferences in the Cookie Consent Manager. The Cookie Consent Manager allows you to select which categories of cookies you accept or reject. Please note that essential cookies cannot be rejected as they are strictly necessary to provide you with the services our Website offers.

The Cookie Consent Manager can be found in the notification banner and on our Website. If you choose to reject cookies, you may still use our Website though your access to some functionality and areas of our Website may be restricted. You may also set or amend your web browser controls to accept or refuse cookies. As the means by which you can refuse cookies through your web browser controls vary from browser to browser, you should visit your browser’s help menu for more information.

IF A COOKIE CONSENT MANAGER IS NOT IN USE:

The first time you visit our Website and depending on your jurisdiction, you may be displayed a banner providing you with information about the use of cookies on our Website. This banner will provide you with the opportunity to accept the use of cookies as you use our Website. As regulations continue to evolve, we may change the management and preference options of cookies in the near future, so please check back to this policy to remain up to date on our use of cookies and your rights as a user of our Website.

In addition, most advertising networks offer you a way to opt-out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.

What about other tracking technologies, like web beacons?

Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Websites or opened an e-mail including them. At a minimum, this allows us to monitor the traffic patterns of users from one page to another within a website, to deliver or communicate with cookies, to understand whether you have come to the website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.

How often will you update this Cookie Policy?

We may update this Cookie Policy from time to time to reflect, for example, changes to the cookies we use or for other operational, legal, or regulatory reasons. Please re-visit this Cookie Policy regularly to stay informed about our use of cookies and related technologies.

The date at the top of this Cookie Policy indicates when it was last updated.

Where can I get further information?

If you have any questions about our use of cookies or other technologies, please email us at isc@cayuse.com or by post to: