Privacy Policy

Last Modified: 10/2022

This Privacy Policy describes the policies and procedures of CModel Data, Inc. (“CModel,” “we,” “our,” or “us”) on the collection, use and disclosure of your information in connection with your use of our SAAS application’s revenue analytics, including all related features, content we offer, and our website at www.C-Model.com (collectively the “Services"). We receive information about you from various sources, including: (i) if you register for an account on our Services, through your user account (your “Account”); (ii) your use of the Services generally; and (iii) if you simply visit our website at www.C-Model.com (together with its subdomains, Content, and Marks, the “Website”). When you use the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy. Throughout this Policy we may occasionally refer to you as the “User.”

What Does This Privacy Policy Cover?

In Short: This Privacy Policy covers the treatment of Personal Information gathered when you are using or accessing our Services.

We are committed to protecting your Personal Information and your right to privacy. Throughout this Privacy Policy, “Personal Information” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with an individual or household. These include information such as full name, postal address, e-mail address and/or telephone number, and if applicable usage data such as your IP address. Such is the data we collect (hereafter “PI”) when you visit the Services.

Here we seek to explain to you in the clearest way possible what PI we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Services. Otherwise, if you have any questions or concerns about this Privacy Policy, or our practices with regards to your PI, please contact our Privacy Officer at privacy@c-model.com.

Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your PI with us.

This Privacy Policy does not apply to the practices of third parties that we do not own or control (each a "Third Party Service Provider") that you elect to access through our Services or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Service Providers that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Service Providers. We encourage you to carefully review the privacy policies of any Third Party Service Providers you access.

That said, we do exchange PI with our Service Providers. “Service Providers” are defined as companies or organizations with whom we have a contractual relationship in connection with fulfilling our Services to you (our “Service Providers”).

What Information Do We Collect Automatically from You?

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you use our Services.

We automatically collect certain information when you visit, use or navigate the Services that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with you or your household. This information may not reveal your specific identity (like your name or contact information) 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 our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The technologies we use for this automatic data collection may include:

Cookies (or Browser Cookies). “Cookies” are small text files that are placed on your device by a Web server when you access our Services. We may use both session Cookies and persistent Cookies to tell us how and when you interact with the Services. We may also use Cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve the Services. Unlike persistent Cookies, session Cookies are deleted when you navigate away from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Services.
Some Service Providers that we engage (including advertisers) may also place their own Cookies on your device. Note that this Privacy Policy covers only our use of Cookies and does not include use of Cookies by any Third Party Service Provider you visit directly, each of which should have its own privacy policies.
Flash Cookies. Certain features of our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Services. Flash cookies are not managed by the same browser settings as are used for Browser Cookies.
Web Beacons. Pages of our Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related Services statistics (for example, recording the popularity of certain Services content and verifying system and server integrity).

What Information Is Collected from Other Sources?

In Short: We may collect limited data from our Service Providers, public databases, marketing partners, and other outside sources.

We may obtain PI about you from other sources, such as public databases, from our Service Providers, and other Third Party Service Providers. Such Third Party Service Providers are neither part of our Services nor a Service Provider with whom we have a contractual relationship. All PI that you provide on or to such Third Party Service Provider or that is collected is provided directly to the controller, owner or operator of said Third Party Service Provider and is subject to the owner’s or operator’s privacy policy. We do not monitor or control any data you provide to Third Party Service Providers. To that end, we are not responsible for the content, privacy or security practices of a Third Party Service Provider. To assure the protection of your PI, we recommend that you carefully review the privacy policies of any Third Party Service Provider you access, as you assume the risk of providing any information to said provider.

With Whom Do We Share Data?

In Short: We may share your PI with our Service Providers.

Any PI collected may be shared with our Service Providers. Following is a list of the Service Providers with whom we share information as of the date of this Policy. Please check this Privacy Policy regularly for updates on other Service Providers that may be added to our Services or contact us at privacy@c-model.com for the most recent list of Service Providers with whom we are legally or contractually obligated to share your information to facilitate your use of the Services.

Google Cloud

We use Google Cloud as a data center, in addition to the below noted specific Google services. Their Privacy Policy can be found at Privacy Policy – Privacy & Terms – Google.

Google Web Fonts

For uniform representation of fonts, the Website fonts are provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly. For this purpose your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our websites.

Google Analytics

We use Google Analytics, a web analysis service of Google Inc. on our Website. Google Analytics is a web analysis tool with the help of which we analyze the interaction of the visitors with our Website and thus are able to improve our Website for you further. Google Analytics also uses Cookies, as they were in principle described in more detail above. We have a legitimate interest in analyzing user behavior to optimize both the Website and its advertising. The information saved by the Cookies includes, for instance, the time of the Website visit, the frequency with which the visitor has called up the Website, and from where the visitor has accessed the Website. You can prevent the saving of the cookies by Google Analytics by a corresponding setting in your browser software; however, reference should again be made to the fact that in this case you may not be able to use all functions of our Website.

Amazon Web Services

We use Amazon Web Services (AWS) as one of our global data centers. Their Privacy Policy can be found at AWS Privacy (amazon.com).

Hubspot

We use Hubspot as our CRM to manage our sales pipeline. Their Privacy Policy can be found at HubSpot Privacy Policy.

How Do We Use Information We Collect?

In Short: We do not sell or trade your Personal Information, but we do share it with our Service Providers to provide the Services.

How we use information we collect depends on what Services you use, how you use them, and on any preferences you may have communicated to us. Below we list specific purposes of using information about you.  

To provide the Services and personalize your experience: We use information about you to provide the Services to you. This includes transactions processing, User authentication, customer support, and Services operation and maintenance. Our Services also include tailored features that personalize your experience and enhance your productivity with them.  
For research and development: We constantly look for ways to make our Services smarter, faster, more secure, integrated, and useful to you. We use collective anonymized findings about how people use our Services as well as the feedback provided directly to us to troubleshoot issues and to identify Services usage trends, activity patterns, and the areas for Services integration enhancing and general improvement. In some cases we apply these findings across our different Services to improve and develop similar features or to better integrate them with other Services you use.   
To communicate with you about the Services: We use your contact information to communicate with you via email and within the Services to confirm your purchases, send reminders about subscription expiration date, respond to your questions and requests, provide customer support, send out technical notices, updates, security alerts, administrative messages, and so on. We also provide tailored communications based on your activity and interactions with us. We also send you communications as you on-board to a particular Service to help you become more proficient in using that Service.  
To market, promote, and drive engagement with the Services: We may use your contact information and the information about how you use the Services to send relevant promotional communication that may be of specific interest to you; that includes promotion email and by displaying our ads on other companies’ websites and applications, as well as on platforms like Facebook and Google. These communications include information about new features, survey requests, newsletters, and events that we think may be of interest to you and are aimed at driving engagement and maximizing the Services’ value for you. We also communicate with you about new product offers, promotions, and contests. You can always opt out from our email campaigns by clicking “Unsubscribe” at the bottom of our email. 
For customer support: We use your information to resolve technical issues you may encounter with the Services, to respond to your assistance requests, to analyze crash information, and to repair and improve the Services.

On the whole, we may store the following categories of information that could be considered PI:

Email and full name of the authorized User
Identifiers and last modified dates of synchronized records
Services sync engine to temporarily keep the names of records that it encounters issues with, solely to display these details to our users in sync error logs and notifications
The Services temporarily keep selected meeting slots and invitees’ names and email addresses in order to build interactive selection tables and send out the invites
Diagnostics logs temporarily keep certain data, such as email or meeting identifiers, Sent/Received dates, etc. solely for customer support and troubleshooting purposes. The logs are transferred and kept securely.
User details such as First name, Last name, title, phone, and email of user to provide the possibility to send email to business contacts imported from the CRM by the user’s request and the IP address
User contact details such as business contacts may be imported from the CRM or other sources.
Related email correspondence including replies, and other correspondence, Sent date, Subject, Recipients list, Email body
Email templates and attachments imported from the CRM and files attached to business correspondence, for communication processing

You may permanently delete the persisted data by using one of the following methods:

Manually: one recipient at a time or in a bulk manner. In this case our Services will purge the recipients’ details and all related data used in the system.
By request sent to us at privacy@c-model.com. In this case all recipients’ details and related data will be purged irrecoverably from our servers

Do We Store Information of Children?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect or solicit PI from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send us any of your Personal Data. If we learn that we have collected Personal Data from a child under age 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us PI, please contact us at privacy@c-model.com.

What Public Information About You and Your Activity on the Services Can Others View?

In Short: Information you post about you on our Services may be viewed by others who access the Services.

Information you choose to include in your profile, or any PI you share about yourself on a user forum we may create, may be viewed by others who access the Services. This includes information you choose to provide openly, including your username, contact name, information about yourself, and links to your websites or social media profiles, which may be displayed to other users to facilitate user interaction within the Services. We will not directly reveal user email addresses to other users. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.

What Information Is Disclosed for Our Protection and the Protection of Others?

In Short: We may have to share your PI if legally required to do so.

We reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Privacy Policy, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

What Choices Do California Residents Have Regarding Their Information?

In Short: If you are a California resident, you have several options to control and manage the amount of PI you share with us.

In the following paragraphs, we seek to comply with the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA). Any terms defined in the CCPA and CPRA have the same meaning when used in this Privacy Policy.

Information We Collect

We collect information as defined under California law that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device, which we have been referring to as PI in this Policy. PI does not include:

Publicly available information from government records.
De-identified or aggregated consumer information.

In particular, we will collect or have collected over the past twelve (12) months through our Services the following categories of PI from California Users:

 Category
 Examples
 Collected

 A. Identifiers.
 A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
 YES

 B. PI categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
 A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some PI included in this category may overlap with other categories.

 YES

 C. Protected classification characteristics under California or federal law.
 Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
 NO

 D. Commercial information.
 Records of personal property, products or Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
 NO

 E. Biometric information.
 Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
 YES

 F. Internet or other similar network activity.
 Browsing history, search history, information on a consumer's interaction with a websites, Services, or advertisement.
 YES

 G. Geolocation data.
 Physical location or movements.
 YES

 H. Sensory data.
 Audio, electronic, visual, thermal, olfactory, or similar information.
 YES

 I. Professional or employment-related information.
 Current or past job history or performance evaluations.
 NO

 J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
 Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
 NO

 K. Inferences drawn from other PI.
 Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
 YES

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. PI categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some PI included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	YES
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a websites, Services, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other PI.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

Use of PI

In addition to the specific uses noted in the Privacy Policy, we may generally use or disclose the PI we collect for business purposes, including:

Auditing User interactions and concurrent transactions.
Detecting security incidents and preventing fraud.
Debugging.
Short-term transient use. For example, contextual customization of ads.
Performing our Services.
Advertising and marketing our Services.
Performing analytics and quality control.
Researching and testing to improve our Services.

We will not collect additional categories of PI or use the PI we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing PI for a Business Purpose

In the preceding twelve (12) months, CModel has disclosed the following categories of PI for a business purpose:

Category A: Identifiers.
Category B: California Customer Records PI categories.
Category E: Biometric information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category H: Sensory data.
Category K: Inferences drawn from other PI.

Your Rights and Choices as a California Resident

The CCPA and CPRA provide consumers (California residents) with specific rights regarding their PI. This section describes your rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your PI over the past 12 months, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), we will disclose to you:

The categories of PI we collected about you.
The categories of sources for the PI we collected about you.
Our business or commercial purpose for collecting or selling that PI.
The categories of third parties with whom we share that PI.
Upon request, the specific pieces of PI we collected about you (also called a data portability request).
If we disclosed your PI for a business purpose, a list disclosing:
- disclosures for a business purpose, identifying the PI categories that each category of recipient obtained.

Deletion Request Rights

Subject to certain exceptions under the law, you have the right to request that we delete any of your PI that we collected from you and retained. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), we will delete (and direct our Service Providers to delete) your PI from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:

Complete the transaction for which we collected the PI, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us at privacy@c-model.com.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your PI. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. We will only use PI provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA/CPRA rights. Unless permitted by the law, we will not do any of the following based on the exercise of your rights:

Deny you Services.
Charge you different prices or rates for Services.
Provide you a different level or quality of Services.

Other California Privacy Rights

We do not track users over time and across our Services; therefore, we do not respond to Do Not Track signals. California Civil Code Section § 1798.83 permits website users that are California residents to request certain information regarding the disclosure of personal data to third parties for direct marketing purposes. To make such a request, please contact us at privacy@c-model.com.

What Happens When There Are Changes to this Privacy Policy?

In Short: We may update this Privacy Policy from time to time, so you should review it periodically for updates or review it if you receive a notice of update from us.

The effective date of this Privacy Policy appears at the top of this page. However, we may update this Privacy Policy from time to time. It is our practice to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat your PI, we will notify you by email to the email address specified in your account or through a notice on the Services home page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Services and this Privacy Policy to check for any changes.

What If I Have Questions or Concerns?

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to privacy@c-model.com or by mail at 535 Whitecliff Dr, Vallejo, CA 94589. We will make every effort to resolve your concerns.