Privacy Policy

We maintain the discretion to update and modify this Privacy Policy whenever necessary. Any modifications will become operative as soon as they are posted on our website. By continuing to use our Services under the applicable laws, you acknowledge and consent to any Privacy Policy changes. If the alterations are substantial, we may also send additional notifications to your registered email address.

• Information You Give Us

The Personal Information we gather through our Services might come directly from you. For instance, we may collect Personal Information when you register or use our Services, subscribe to our updates, engage with our Services, participate in promotional activities, apply for job positions, or communicate with us via the Services, including using an installed application on a device. You have the option to submit additional information to us voluntarily through our Services, which may include Personal Information. However, you bear sole responsibility for your Personal Information in cases where we have neither collected such information nor asked you to provide it. Please note that data that has been de-identified or Personal Information that has been “de-identified” may no longer be subject to this Privacy Policy. We and our Service Providers (defined below) have the right to treat it as non-Personal Information and may utilize it without any obligation to you unless such usage is prohibited by relevant laws.

• Automatically Collected Information from Your Use of Our Services

Both we and our Service Providers gather data about the Services you utilize and how you use them. This information, collected automatically via your device, includes IP address; device identifier, Ad ID, browser type; characteristics of your operating system; data regarding your use of our Services; and information pertaining to hardware connected to the network (e.g., computer or mobile device) — this is termed "Usage Information". In cases where Usage Information is deemed Personal Information under relevant law or is merged with Personal Information, we will manage such information as Personal Information as outlined in this Privacy Policy. The strategies we and our Service Providers use to gather Usage Information include:

• Log Information: We accumulate data regarding your use of our Services, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, cookies that may uniquely identify your browser or your account, among other data, storing it in log files.
• Information Gathered by Cookies and Other Tracking Technologies: We and our Service Providers may employ cookies or other tracking technologies ("Tracking Technologies") to collect and store data about your interactions with our Services, including information regarding your browsing and purchasing behavior. Additional details about how we use cookies are available in our Cookie Policy.

By disclosing the presence of Tracking Technologies and offering choices regarding them as explained in Section 13, we aim to ensure that your consent to their use is informed in a meaningful manner.

• Personal Information Collected from Other Sources

We may obtain your Personal Information from various sources including public databases, marketing partners we jointly collaborate with, and social media platforms. This information may be merged with the data we collect from you. If such information from third parties is combined with the Personal Information, we have directly collected from you, we will consider the consolidated information as Personal Information. However, please note that we cannot be held accountable for the accuracy of the information provided by these third parties or their operational practices.

We, along with our Service Providers, may utilize your information to fulfill several objectives:

• We aim to offer, preserve, safeguard, and enhance our Services, develop new services, and ensure the protection of EXEPART and our users.
• We strive to facilitate, manage, customize, and augment your online experience.
• We respond to your inquiries and meet your requests such as dispatching newsletters, brochures, catalogs, and emails.
• For our organizational requirements such as data examination, audits, monitoring, and prevention of fraud, refinement, enhancement, or modification of our Services, identifying usage patterns, and functioning and expanding our business operations; and
• We deliver advertisements and communicate with you about products, services, offers, promotions, rewards, and events that we think might be relevant to you (for more information about managing these communications, refer to Section 13).

Marketing Purposes

For users based in the United States, we might utilize your Personal Information for the purpose of direct marketing. However, if you are a user from a country other than the U.S., we will refrain from using your Personal Information for direct marketing unless we have obtained your explicit consent. As a user from outside the U.S., you possess the right to withdraw from direct marketing. You can ask us to discontinue using your data for such marketing purposes at any time, free of charge.

Our representatives, vendors, advisors, marketing support entities, and other service associates (collectively known as "Service Providers") might obtain, or be granted access to, your data, which includes Personal Information and Usage Information, in relation to the services they provide on our behalf. These Service Providers might be based in nations other than where you reside. These Service Providers are barred from using your Personal Information for any reason other than to offer their support, although we may allow them to use anonymized data or collective information which does not personally identify you or any other user of the Services (for instance, we may consolidate Personal Information to compute the percentage of our users who belong to a specific telephone area code). We also reserve the right to share information about you under the following circumstances:

As needed, for the following reasons:

1. (a) to adhere to legal procedures.
2. (b) to answer requests from public and governmental bodies, including those outside your country of residence to fulfill national security or law enforcement needs.
3. (c) to apply our terms and conditions.
4. (d) to safeguard our operations and uphold our rights, privacy, safety, or property, as well as that of you or others; and
5. (e) to allow us to seek possible remedies or limit the damages that we might incur.

Alongside our affiliates for internal organizational purposes. For instance, managing your orders, meeting your demands, providing customer service, and enhancing our products.

Alongside our subsidiaries, affiliates, business associates, and other third parties for their individual organizational needs. For instance, to enhance their products and services; and

In the context of negotiations involving the restructuring, merger, sale, joint venture, assignment, transfer, or other distribution of all or a portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), your information may be disclosed to a third party entity.

When EXEPART employs the services of third-party providers and needs to share Personal Information with them to facilitate those services, EXEPART ensures these providers manage Personal Information in a way that aligns with this Privacy Policy. Furthermore, where relevant, EXEPART is accountable for ensuring these third parties process EU Personal Information in accordance with the Privacy Shield Principles detailed below (see Section 15) and/or the General Data Protection Regulation or other relevant laws.

Aggregated Information

Without restricting the previously mentioned, at our sole discretion, we may share collective data that does not personally recognize you or anonymized information about you with third parties or affiliated entities for any objective.

Sharing for Marketing Purposes

If you are a user based in the U.S., your Personal Information may be shared with third parties for the purpose of direct marketing. Additional rights are available to residents of California, as detailed in Section 14. However, if you are a user from outside the U.S., your Personal Information will not be shared with third parties for direct marketing purposes unless we have obtained your explicit approval. Non-U.S. users have the privilege to opt-out from direct marketing and can request us to stop using their data for such marketing purposes at any given time without any charges.

We may present sweepstakes, competitions, and other promotional activities (each referred to as a "Promotion"), which may be co-sponsored or provided by third parties, and which may necessitate the submission of Personal Information. If you willingly participate in a Promotion, your Personal Information may be shared with third parties for management purposes and as mandated by law (for instance, in a list of winners). By participating in a Promotion, you consent to the official rules that govern that specific Promotion, and, unless restricted by applicable law, permit the sponsor and/or other entities to utilize your name, voice, and/or image in promotional or marketing materials.

The Services may allow you to publish or submit written material, user profiles, audio or visual recordings, computer graphics, images, data, or other types of content, inclusive of Personal Information (collectively referred to as “User Content”). If you decide to submit User Content to any public section of our Services, your User Content will be deemed “public” and can be accessed by anyone, including us, and is not governed by this Privacy Policy, allowing it to be used to the maximum extent permissible under applicable law. We advise you to exercise discretion when deciding what information to disclose in such public sections. Minors in California should refer to Section 11 for removal of specific posted content.

Our Services may contain links to websites, locations, platforms, or services managed by third parties ("Third Party Service(s)"). These Third-Party Services may independently collect information about you through their own cookies, web beacons, and other Tracking Technology, and they may request Personal Information from you. Certain functionalities within our Services allow for interactions that you initiate between our Services and specific Third-Party Services, like third-party social networks, termed as “Social Features.” Social Features could include actions such as "liking" or "sharing" our content and linking our Service to a Third-Party Service. If you utilize Social Features, and potentially other Third-Party Services, information that you post or provide access to could be publicly displayed either on our Services or on the Third-Party Service you use. Similarly, if you post information on a Third-Party Service that references our Services (for instance, by using a hashtag associated with EXEPART in a tweet or status update), your post might be utilized in association with our Services. Furthermore, both EXEPART and the third party may gain access to specific information about you and your use of our Services and the Third-Party Service. If we amalgamate information from Third Party Services with Personal Information that we gather directly from you on the Services, we will regard the combined information as Personal Information under this Privacy Policy.

Third Party Responsibility

The data collected and held by third parties remains subject to their own privacy practices, including whether they persist in sharing information with us, the kinds of information shared, and your options regarding what is visible to others on Third Party Services. We hold no responsibility for the collection, usage, and disclosure policies and practices (including the data security practices) of any other organization, this includes any Personal Information you reveal to other organizations through or in association with our social media Pages. We do not endorse or make any representations about the policies or business conduct of any third parties or Third-Party Services, and we strongly advise you to acquaint yourself with and review their privacy policies and terms of use.

We may employ third-party advertising companies to display ads on our behalf on the Services and/or on Third Party Services, as well as to deliver analytics services regarding the use of our Services and the performance of our ads and content on Third Party Services. Additionally, we may participate in online advertising networks and exchanges, which display relevant ads to our Service visitors, both on our Services and on Third Party Services, as well as outside our Services, based on your interests as reflected in your browsing patterns on the Services and certain Third-Party Services. These organizations might employ cookies and other Tracking Technologies to automatically gather information about you and your actions, such as assigning a unique identifier to your device and linking that to your online activities on and off our Services. We might utilize this information to analyze and track data, gauge the popularity of specific content, deliver advertising and content tailored to your interests on the Services and Third-Party Services, and gain a better understanding of your online behavior.

Online Behavioral Advertising

Some details about your browsing activity on the Services and certain Third-Party Services could be gathered over time and across numerous services and then shared with third parties to provide you with ads and/or other content on the Services and certain Third-Party Services. EXEPART may receive information about Third Party Services that you have visited and utilize this data for marketing initiatives—a process sometimes referred to as "(re)-targeting," "interest-based advertising," and "online behavioral advertising."

Do Not Track

Your web browser settings may provide the option to send a "Do Not Track" signal to the online services you visit. It is important to note that there is no universally agreed-upon definition for "Do Not Track" in this context, as different industry participants have varying interpretations. Similar to many other online services, we currently do not modify our practices based on receiving a "Do Not Track" signal from a visitor's browser. For more information about "Do Not Track," you can visit http://www.allaboutdnt.com.

We strive to implement reasonable technical and organizational security measures to safeguard your information against loss, theft, misuse, unauthorized access, disclosure, alteration, or destruction. Furthermore, EXEPART will retain your Personal Information only for as long as necessary to fulfill the purposes outlined in this policy. However, it is important to note that no data transmission or storage system can be entirely secure, and we cannot provide a guarantee of the absolute security of your information collected through our Services. Your Personal Information is stored on servers located in the U.S., U.K., and Hong Kong, managed with the assistance of a third-party data storage provider.

Venatronics LLC and its listed US subsidiaries adhere to the Privacy Shield Framework, which is established by the U.S. Department of Commerce in collaboration with the European Commission. This framework governs the collection, use, and retention of Personal Information received from the European Union. As part of the Privacy Shield, Venatronics LLC is subject to the authority and enforcement powers of the Federal Trade Commission. EXEPART undergoes an annual certification process to demonstrate compliance with the Privacy Shield Principles, which include notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement, and liability. All U.S. entities and subsidiaries listed in our Privacy Shield certification record adhere to these principles. For more information about the EU-U.S. Privacy Shield Framework, please visit https://www.privacyshield.gov/EU-US-Framework. To view EXEPART's certification, please visit https://www.privacyshield.gov/list. If the Privacy Shield is invalidated, any information pertaining to EU residents will only be transferred in accordance with approved transfer mechanisms, such as the model contract clauses. As a U.S.-based company, we operate under U.S. law regarding the information we collect from the U.S. If you access our Services from outside the U.S., please note that the information collected through the Services may be transferred to, processed, stored, and used in the U.S. Your Personal Information may also be transferred to, processed, stored, and used in other jurisdictions where we have subsidiaries, affiliates, or service providers. The data protection laws in these jurisdictions may differ from those of your country of residence. By using our Services or providing any information, you consent to the transfer, processing, usage, sharing, and storage of your information, including Personal Information, in these jurisdictions, as described in this Privacy Policy.

Our Services are designed for adult users and are not specifically aimed at individuals under the age of thirteen (13). If you are a child under the age of thirteen (13), you are prohibited from using the Services and should refrain from providing any personal information about yourself to us.

COPPA

We are committed to not knowingly collecting any Personal Information from children under the age of thirteen. If we become aware that we have received information from a user under the age of thirteen, we will promptly delete that information in compliance with the Children's Online Privacy Protection Act (COPPA). If you are a parent or guardian and believe that your child under the age of thirteen (13) has provided us with Personal Information without the necessary consent as required by COPPA, please contact us at compliance@exepart.com.

EXEPART offers web pages or other mechanisms that allow you to update or correct certain Personal Information you have provided to us. Access Rights Users from the European Union, Singapore, Hong Kong, Japan, New Zealand, Mexico, and Australia have the right to access their Personal Information, request corrections and/or deletions, and object to the use of their Personal Information for specific purposes, subject to legal exceptions. These users are also entitled to request information regarding the origin of their Personal Information, the recipients or types of recipients who have received their Personal Information, the purpose for which their Personal Information is being stored, and the ways in which their Personal Information has been or may have been used or disclosed by us within one year prior to the date of the request. To make such a request, please send a written request by email to compliance@exepart.com or by mail to Venatronics LLC, 21921 Rimhurst Dr, Lake Forest, CA 92630. To ensure privacy protection, we will require evidence of your identity before granting access to or making changes to your information. No fees will be charged for complying with such requests. Changes and Deletions We will make reasonable efforts to implement requested changes in our active databases as soon as possible (while retaining prior information as permitted by applicable law). However, please note that it may not always be feasible to completely remove or delete all your information or public postings from our databases (refer to Section 11 for California minors), and residual data may remain on backup media or for other legitimate reasons. We may also keep cached or archived versions of your information for a designated period. Individuals may also exercise the right to be forgotten by emailing reminder@exepart.com.

A. Tracking Technologies Generally

Typically, regular cookies can be disabled or deleted using tools provided by most mainstream web browsers. In some cases, you can also choose to block cookies in the future by adjusting specific settings. It's important to note that different browsers offer varying functionalities and options, so you may need to configure them individually. Please be aware that disabling or removing cookies may result in certain parts of our Services not functioning properly. Additionally, when you revisit our Services, your ability to control browser-based Tracking Technologies is dependent on your browser settings and any limitations they may have. For our mobile applications, you can prevent the collection of information by uninstalling the app. Furthermore, you may have the option to exercise specific privacy choices, such as enabling or disabling location identification services, by adjusting the permissions on your mobile device.

B. Analytics and Interest-Based Advertising

Certain companies may take part in the Digital Advertising Alliance (DAA) AdChoices Program, displaying an Advertising Option Icon for interest-based ads. This icon provides a link to an opt-out tool that enables you to make certain choices regarding targeted advertising. To find out more about the DAA AdChoices Program, you can visit http://www.youradchoices.com/. For mobile applications, you can access the opt-out program at http://www.aboutads.info/appchoices.

Moreover, specific advertising networks and exchanges may participate in the Network Advertising Initiative (NAI), which offers a tool allowing consumers to opt-out of targeted advertising delivered by NAI members' ad networks. To learn more about opting out of targeted advertising or to utilize the NAI tool, you can visit http://www.networkadvertising.org/choices/.

Please note that even if you opt-out of certain types of targeted advertising, you may still receive non-targeted ads. We are not responsible for the effectiveness or compliance of any third-party opt-out options or programs, nor can we guarantee the accuracy of their statements about their programs. However, we support the ad industry's 2009 Self-regulatory Principles for Online Behavioral Advertising (http://www.iab.net/media/file/ven-principles-07-01-09.pdf), and we expect that the ad networks we directly engage with for serving you interest-based ads will adhere to these principles as well, although we cannot guarantee their compliance.

C. Communications

You have the option to opt-out of receiving promotional communications (such as emails or text messages) from us at any time by following these steps: (i) To unsubscribe from promotional emails, you can click on the provided unsubscribe link in the emails or modify your communication preferences by logging into your account; (ii) To stop receiving text messages, you can follow the instructions given in the text messages and reply with the word "STOP". Please keep in mind that your opt-out request is specific to the email address or phone number used and will not affect any subsequent subscriptions. If you choose to opt-out of only certain communications, you may still receive other subscriptions. Please note that even if you opt-out of receiving promotional communications, we may, as permitted by applicable law, continue to send you non-promotional communications related to your account, transactions, service, or our ongoing business relationship.

D. Mobile Applications

Our mobile applications have the capability to send you notifications, which may consist of alerts, sounds, and icon badges. These notifications, including both operational and promotional messages about products, services, and offers that may be relevant to you, can be customized in the settings. Like email communications, if you choose to opt-out of receiving promotional notifications, you may still receive non-promotional push notifications, such as those related to your use of the applications or our ongoing business relationship.

Scoope

Section 14 of the policy is specifically relevant to the Personal Information of individuals who are residents of the U.S. state of California and function as consumers ("California consumers").

The term "California consumer" excludes individuals who are acting in their capacity as human resources, such as employees, job applicants, directors, and contract workers of EXEPART (referred to collectively as "HR individuals"). It also does not include individuals who are acting as emergency contacts, dependents, or beneficiaries of HR individuals. Additionally, individuals who are acting as employees or agents of a business engaged in a transaction with EXEPART are not considered "consumers" under this definition.

Section 14 pertains to all Personal Information of California consumers, regardless of whether it was collected, disclosed for business purposes, or sold by EXEPART, whether through online or offline channels.

Now, let us discuss how we gather the Personal Information of California Consumers.

Obligation to Provide Personal Information

EU individuals may need to provide Personal Information to us on certain occasions as it is necessary to enter into a contract or fulfill contractual obligations. This includes situations such as providing our products and services, processing payments for the products and services offered, and managing billing, shipping, and delivery. While you have the freedom to withhold your Personal Information, please note that without this data, we will be unable to execute the contract or provide you with our products and services.

When you engage in a purchase on or through our Services, it is necessary to provide Personal Information to ensure compliance with applicable tax and legal requirements. While you have the choice to withhold your Personal Information, please be aware that without this data, we will be unable to provide you with our products and services in accordance with these obligations.

Automated Decision-Making

On occasion, we utilize the Personal Information of EU individuals submitted through our Services for automated decision-making processes. For instance, we may display advertisements and send emails to you that contain content automatically selected based on the products or services you have previously engaged with. However, it is important to note that we do not employ the Personal Information of EU individuals submitted through our Services for automated decision-making, including profiling, that could have legal consequences or significantly impact them in a similar manner.

Legal Bases for Processing

We process your Personal Information based on your consent and as required by law. Furthermore, we process your Personal Information to fulfill the sales contract, such as processing orders, payments, and providing you with quotations for products and services upon your request. We also process Personal Information based on our legitimate interests, which include:

Research and Development: Conducting research on the usage of our products and services and improving and developing new offerings.

Marketing and Advertising: Within the bounds permitted by applicable law, we use your Personal Information regarding products and services you have ordered or expressed interest in to analyze your preferences and provide you with information about other products and services that we believe might interest you.

Security: Personal Information is utilized for facility, network, and information security purposes, including fraud prevention and reporting suspected criminal activities. For instance, in the event of fraud, a security incident, or suspicion of criminal behavior, we may examine Personal Information associated with the incident to investigate and address the matter, report to relevant authorities, and prevent future occurrences.

Accuracy and Access to Personal Information

EU individuals have the right to request access to their Personal Information in accordance with applicable law in their home country. They may also request the correction, amendment, or deletion of their Personal Information if it is inaccurate or has been processed in violation of the Privacy Shield Principles. EXEPART will make reasonable efforts to fulfill such requests to the extent required by applicable law. Users outside the United States have the right to request that their Personal Information not be processed for marketing purposes. We will inform you in advance (before collecting your information) if we intend to use your information for such purposes or disclose it to any third party for such purposes. You can exercise your right to prevent such processing by selecting certain options on the forms used to collect your information.

To exercise these rights, you can contact us at compliance@exepart.com or send a letter to the addresses provided in Section 16 below.

Right to Object to Processing for Direct Marketing or Legitimate Interests

EU individuals possess the right to object to the processing of their Personal Information by EXEPART for the purposes of direct marketing or legitimate interests. To exercise this right, you can contact us at compliance@exepart.com or send a letter to the addresses provided in Section 16 below.

Revocation of Consent

Users located outside the U.S. also retain the right to withdraw their previously granted consent concerning the use and sharing of their Personal Information. However, it is essential to acknowledge that in certain situations, immediate or complete execution of such a request may not be possible due to legal obligations that require us to continue using your Personal Information. Additionally, it's important to note that revoking consent for certain purposes may impact our ability to continue providing the services you have requested. You can withdraw your consent at any time by reaching out to us at compliance@exepart.com or by sending a letter to the addresses provided in Section 16 below.

Accountability and Inquiries

If any EU individual is not satisfied with EXEPART's adherence to the EU-U.S. Privacy Shield or other applicable legislation, they can reach out to us at compliance@exepart.com or send a letter to the addresses provided in Section 16 below. In the event that a complaint remains unresolved, the individual agrees to attempt mediation, administered by the International Centre for Dispute Resolution under its Mediation Rules, before resorting to arbitration, litigation, or any other dispute resolution process. Details regarding the procedures and how to file a claim at no cost can be found at: http://info.adr.org/safeharbor/.

Should an EU individual remain dissatisfied, they have the option to contact their national Data Protection Authority in the country where they reside. EXEPART has committed to cooperating and complying with appropriate EU Data Protection Authorities and the Department of Commerce to resolve such disputes. If the individual meets the pre-arbitration requirements specified in Annex I Part C of the EU-U.S. Privacy Shield Framework, they may invoke binding arbitration as per the procedures outlined in Annex I of the EU-U.S. Privacy Shield Framework Principles, accessible here: https://www.privacyshield.gov/EU-US-Framework.

If you have any requests regarding your Personal Information or if you have any inquiries concerning this Privacy Policy, please feel free to reach out to us at:

Venatronics LLC,
21921 Rimhurst Dr, Lake Forest, CA 92630
compliance@exepart.com