Coldforge Privacy Policy

Introduction

This privacy policy ("Privacy Policy") applies to all visitors, users and customers of the Coldforge.ai hosted services and websites (collectively, the "Service" or "Services") and self-managed installations, which are offered by Coldforge Systems, Inc. and/or any of its subsidiaries and/or affiliates ("Coldforge" or "we" or "us") and describes how we process your personal information in connection with those Services or self managed installations, customer events and demos, and how we collect information through the use of cookies and related technologies. It also tells you how you can access and update your personal information and describes the data protection rights that may be available under your country’s or state's laws, including (in the European Economic Area ("EEA"), and UK), a right to object to some processing that we carry out or, where we rely on consent, how to withdraw that consent. Please read this Privacy Policy carefully. By accessing or using any part of the Services or self-managed installations, you acknowledge you have been informed of and consent to our practices with regard to your personal information and data. Unless otherwise stated, we act as the data controller for the data processing operations described in this Privacy Policy.

Types of Data Collected

The following types of Personal Data are collected, either directly or through third parties:

• Usage Data
• Browsing history
• Device information

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Coldforge.

Unless specified otherwise, all Data requested by Coldforge is mandatory and failure to provide this Data may make it impossible for Coldforge to provide its services. In cases where Coldforge specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact Coldforge.

Data Processing and Retention

Methods of Processing

Coldforge takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.

In addition to Coldforge, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Coldforge (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by Coldforge.

Retention Time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Personal Data collected for purposes related to the performance of a contract between Coldforge and the User shall be retained until such contract has been fully performed. Personal Data collected for the purposes of Coldforge's legitimate interests shall be retained as long as needed to fulfill such purposes.

Coldforge may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, Coldforge may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.

The Purposes of Processing

The Data concerning the User is collected to allow Coldforge to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:

• Traffic optimization and distribution
• Displaying content from external platforms
• Hosting and backend infrastructure
• Analytics

Detailed Information on the Processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Cookie Policy

A cookie is a string of information that a website stores on a visitor's computer, and that the visitor's browser provides to the website each time the visitor returns. Coldforge uses cookies to help Coldforge identify and track visitors, their usage of the Services, and their Service access preferences. Coldforge visitors who do not wish to have cookies placed on their computers may set their browsers to refuse cookies before using the Services. Disabling browser cookies may cause certain features of Coldforge's websites to not function properly.

Information for Users in the European Union

Legal Basis of Processing

Coldforge may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes.
• Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof.
• Processing is necessary for compliance with a legal obligation to which Coldforge is subject.
• Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in Coldforge.
• Processing is necessary for the purposes of the legitimate interests pursued by Coldforge or by a third party.

User Rights

Users may exercise certain rights regarding their Data processed by Coldforge. In particular, Users have the right to:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
• Access their Data. Users have the right to learn if Data is being processed by Coldforge, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, Coldforge will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from Coldforge.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Right to Object

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in Coldforge or for the purposes of the legitimate interests pursued by Coldforge, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes.

How to Exercise These Rights

Any requests to exercise User rights can be directed to Coldforge through the contact details provided in this document. Such requests are free of charge and will be answered by Coldforge as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by Coldforge to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort.

Information for Users Residing in the US

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running Coldforge and, if the case may be, its parent, subsidiaries and affiliates.

This section applies to all Users who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island, and Montana.

Notice at Collection

Sources of Personal Information

Information is collected directly from Users through submissions and indirectly through automatic collection during site navigation, as well as from third parties working with Coldforge.

User Rights

All Users residing in the covered states have the following rights:

• Right to access and know about personal information processing
• Right to correct inaccurate personal information
• Right to request deletion of personal information
• Right to obtain a portable copy of personal information
• Right to opt out of the sale of personal information
• Right to non-discrimination for exercising privacy rights

Additional Rights for California Residents

• Right to opt out of the sharing of personal information for cross-context behavioral advertising
• Right to limit the use and disclosure of sensitive personal information to that which is necessary

Additional Rights for Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island, and Montana Residents

• Right to opt out of the processing of personal information for targeted advertising or profiling in furtherance of decisions that produce legal or similarly significant effects
• Right to freely give, deny, or withdraw consent for the processing of sensitive personal information
• Minnesota and Maryland residents may obtain a list of the specific third parties to which personal information has been disclosed
• Minnesota residents additionally have rights regarding profiling results, the reasons underlying profiling, the potential actions that may be taken, data review, and correction

Additional Rights for Utah and Iowa Residents

• Right to opt out of the processing of personal information for targeted advertising
• Right to opt out of the processing of sensitive personal information

How to Exercise These Rights

Users may submit requests via the contact information provided in this document. Identity verification is required. Users are not required to create an account to exercise their rights. Personal data collected for verification is used solely for that purpose and not retained longer than necessary. Adults may request on behalf of minors under their authority.

Users may exercise opt-out rights via privacy choices links on the site or through user-enabled global privacy controls such as the Global Privacy Control (GPC) signal, without additional friction.

Response Timeline

Coldforge will respond without undue delay, within the timeframes required by applicable law. Additional time needed will be communicated to the User. Denials will include an explanation. No fees are charged unless requests are manifestly unfounded or excessive, in which case reasonable fees may apply with explanation. Manifestly unreasonable requests may be refused with stated reasons.

Additional Information About Data Collection and Processing

Legal Action

The User's Personal Data may be used for legal purposes by Coldforge in Court or in the stages leading to possible legal action arising from improper use of Coldforge or the related Services. The User declares to be aware that Coldforge may be required to reveal personal data upon request of public authorities.

System Logs and Maintenance

For operation and maintenance purposes, Coldforge and any third-party services may collect files that record interaction with Coldforge (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Changes to This Privacy Policy

Although most changes are likely to be minor, Coldforge may change this Privacy Policy from time to time, and in Coldforge's sole discretion. We may also provide notification to customers who have provided us email addresses of material changes to this Privacy Policy by sending an email or by displaying a notice through our Services or products, or otherwise. Coldforge encourages visitors to frequently check this page for any minor changes to its Privacy Policy. Your continued use of this site, any of the Services, self-managed installations, deployments, or other Coldforge products after any change in this Privacy Policy will constitute your acceptance of such change and acknowledgement of the updated Policy.

Should the changes affect processing activities performed on the basis of the User's consent, Coldforge shall collect new consent from the User, where required.

Definitions and Legal References

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information - including a personal identification number - allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through Coldforge (or third-party services employed in Coldforge), which can include: the IP addresses or domain names of the computers utilized by the Users who use Coldforge, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using Coldforge who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Coldforge. The Data Controller, unless otherwise specified, is Coldforge of Coldforge.

Coldforge (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by Coldforge as described in the relative terms (if available) and on this site/application.

Sale

The exchange of a consumer's Personal Information by the business to a third party for monetary or other valuable consideration as defined by the applicable US state law.

Sharing

The sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information to a third party for cross-context behavioral advertising, as defined by California law.

Targeted Advertising

Displaying advertisements to a consumer where the advertisement is selected based on personal information obtained from that consumer's activities over time and across nonaffiliated websites or online applications to predict such consumer's preferences or interests, as defined by the applicable US state law.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User's device.

Contact

The relevant data controller for any personal information processed in connection with our Service is:
Coldforge Systems, Inc.
56 Broad St STE 59919
Boston, MA 02109

If you have any questions about this Privacy Policy or our privacy and security practices or you wish to make a complaint about our compliance with applicable privacy laws, please feel free to contact us at privacy@coldforge.ai