Privacy Policy

Last Updated: 05/23/2024

Respecting and protecting investor privacy has always been vital to our business. This Privacy Policy describes how Clariti Customer Experience LLC (together with its subsidiaries and affiliates, “Clariti”, “Clariti CX”, “Palomarr”, “we”, “us” and “our”) gathers and uses personal information about you when you communicate with us, when you visit Palomarr’s websites that link to this Privacy Policy (including clariticx.com and palomarr.com, and any sites that are automatically redirected to them, collectively, the “Sites”); how we protect and share this information; and the rights you may have in relation to this information. Please read this Privacy Policy carefully, and consult our Terms and Conditions of Use for more information about the general terms and conditions regarding your use of the Sites.

In the event that you have any questions or concerns about this Privacy Policy, or if you object to our uses of your personal information, please contact our Privacy Office by using “Contact Us” section of the Sites.

A. The Types of Information We Collect

When you visit and browse the Sites, you may provide us with information, and we will collect certain information automatically.

We collect different categories of information about you and the way you use our Sites. We collect identifiers (first name, last name, email address, company name, company size, etc.), commercial information (interest in buying software products and/or services), internet or other electronic network or device activity information (search history, information on interactions with a website, or application), inferences (activity on site), and sensitive personal information (account login and password information).

1. Information You Provide to Us

In order to access certain services provided via the Sites or to request certain information from Palomarr via the Sites, you will be required to provide certain personal information.

2. Information We Collect Automatically

We also collect information about you automatically.

We collect this information using cookies, which are small files that a website sends to your computer or device while you are viewing the website, or other technical methods to track visitor usage, including web beacons, which are small pieces of data that are embedded in images on the pages of a website.

We and other companies use cookies and web beacons for a variety of purposes. For instance, when you return to our Sites after logging in, cookies provide information to the Sites so that the Sites will remember who you are. We use web beacons and other technologies to analyze the traffic patterns on the Sites, such as the frequency with which our users visit various parts of the Sites.

3. Additional Information Collection Practices

The Sites may contain links to websites operated by third-parties, and your personal information may be collected by those third-parties when you use their websites.

Some of our third-party partners may ask you to provide personal information on their websites and may share such personal information with us, as governed by their respective privacy policies.

We will link the information that we collect automatically with the information you provide us, and we will combine the information we collect online with information we collect offline or that is collected by third-parties.

B. How We Use the Information We Collect

We use information we collect about you primarily to: provide services to you in accordance with any contract with you, communicate with you, and manage and improve our services for you and our other investors, as permitted by applicable laws.

We may use information for any purpose if the information does not identify you and cannot be combined with other information accessible to us to identify you. For example, we may prepare aggregated reports about how visitors tend to interact with the Sites for research about the use of the Sites and how the Sites could be improved, from which your interactions with the Sites cannot be singled out.

C. How We Share the Information We Collect

1. In Connection with Third Party Offers

We may share information about you with third-parties when you engage in certain activities on the Sites that are sponsored by third-parties. For example, you may choose to purchase products or services offered by a third-party or elect to receive information or communications from a third-party. If you engage in such third-party offerings, we may share information (e.g., your e-mail address) with third-parties in association with the offerings.

2. Service Providers

Sometimes we engage companies that act on our behalf in association with the operation of the Sites. For example, such companies may deliver products or services, improve the functionality of the Sites, collect information about you, communicate with you, or store information for us. In some cases, these companies may need to access information about you.

3. Analytics Providers

We engage third-party analytics providers to help us understand how users engage with the Sites. These third-parties may use cookies and similar technologies to collect information about your use of the Sites as well as information about your use of other websites over time.

4. Additional Sharing Practices

From time to time we share your information with our affiliates and subsidiaries, or with our attorneys, banks, auditors, securities brokers and other service providers in connection with the purposes described above. From time to time, we partner with other organizations or companies to provide co-sponsored or co-branded promotions, services, or events, and we will share your information with our co-sponsor(s) and partners to the extent necessary for the partnership to function.

We may also share information about you to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our business, or a sale, liquidation, or transfer of some or all of our assets.

Additionally, we reserve the right to share with third-parties information that does not identify you (and cannot be combined with other information accessible to us to identify you) for any purpose.

We do not sell your personal information and have not done so in the last 12 months from the effective date of this policy.

D. The Security Measures We Take to Safeguard Information

The security and confidentiality of the information we collect or receive is extremely important to us, and we take our responsibility to protect this information very seriously. We have implemented commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive. From time to time, we review and consider updates for our security procedures. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.

E. Updating Your Contact Information

You may update your contact information and/or modify your communication preferences by sending us an e-mail by using “Contact Us” section of the Sites. Additionally, we may provide tools on the Sites that facilitate such updates or modifications.

F. Children’s Information

The Sites are intended for use by those over 18, and minors under the age of 18 may not use the Sites.

G. Do Not Track

Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. We do not currently respond to such signals.

H. Your Choices and Rights

If you no longer wish to receive marketing materials from us, you can let us know by using “Contact Us” section of the Sites or using other unsubscribe features that we provide in our marketing communications.

Subject to local law, you may have certain additional rights regarding your personal information.

1. How to Exercise Data Subject Rights

If you would like to discuss or exercise the rights you may have, contact us by using “Contact Us” section of the Sites. We will review your request and respond accordingly. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard.

If you make a request related to your rights, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. For requests related to particularly sensitive information, we may require additional proof of identification.

If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf.

We will process your request within the time provided by applicable law.

I. Shine the Light Disclosures

If you are a California resident, you have the right to request certain information from us regarding the manner in which we share with third-parties certain categories of information that identifies you for the third-parties’ direct marketing purposes. If you wish to exercise this right, please email by using “Contact Us” section of the Sites. For additional information about your rights under the CCPA and how to exercise those rights, refer to “Your Choices and Rights” in Section H above.

J. Where Is Information Processed?

We process information collected via the Sites in and subject to the laws of the United States, which may not provide the same level of protection for your information as your home country. The information may be available to the United States government or its agencies under a lawful order made in the United States. In addition, we may transfer your information outside the United States to our affiliates, business partners, and service providers located in other countries.

K. How Long Is Information Retained?

We retain your personal information for as long as we have a relationship with you and for a period after our relationship with you has ended.

L. CCPA Categories of Personal Information Collected

The CCPA requires us to provide additional information about the personal information we collect with reference to specific categories of information. For additional information about our sources of personal data, how we use personal data, and how we disclose personal data, refer to Sections A-C above.

M. Amendments to this Privacy Policy

We may change this Privacy Policy from time to time. Should we do so, we will post the changes to this page. We suggest that you periodically consult this Privacy Policy to review any changes. Your continued use of the Sites after the effective date of any modification to the Privacy Policy will be deemed to be your agreement to the changed terms.

This policy is effective from May 23, 2024.

N. How to Contact Us

If you have any questions regarding this policy or our privacy or data protection practices, please feel free to contact us by using “Contact Us” section of the Sites.