Atlantic Fox Technologies, Inc. Privacy Notice

User Privacy Notice

Last Updated: January 2, 2024

Atlantic Fox Technologies, Inc. (“Atlantic Fox”) provides Software as a Service (“SaaS”) solutions (“Services”) to our clients who are seeking better understanding of and engagement with their customers and potential customers.

Our core business involves application of technology solutions to help our clients manage and interpret their data, including Personal Information of our clients’ customers.  We also allow our clients with the opportunity to combine their pre-existing data with data they may have obtained from third-party sources.

What Information Does this User Privacy Notice Cover?

This User Privacy Notice covers Personal Information that Atlantic Fox collects about individuals who visit our website, use our Services, or otherwise engage with us directly through social media, email, telephone, and other methods of communication (“Users”). 

This User Privacy Notice does not cover Personal Information about individual consumers we process on behalf of our Clients within our SaaS Service offerings.  For information about how we process Personal Information within our SaaS Service offerings, please click here.

What is Personal Information?

Personal Information is information about a specific person or household.  This definition includes any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a specific person or household. 

Does Atlantic Fox Use Cookies or other Tracking Technologies?

Yes.  Atlantic Fox uses cookies and other similar tracking technologies (“Tracking Technologies”) in connection with operating our website and providing the Services.  These Tracking Technologies are used to collect information about the devices being used to access our website and Services, to determine our Users’ interest in specific areas of our website and Services, to customize the presentation of our website and Services and other similar internal business purposes.  We do not use Tracking Technologies to monitor User activities on other sites or for third party marketing purposes.

What Personal Information Does Atlantic Fox Collect about Users?

When a User visits our website, uses our Services, or engages with us through other online and offline methods, we may collect that User’s name, email, postal address, phone number, payment card information, and other information that User chooses to provide so that we may contact that User, respond to that User’s requests or perform the Services the User has requested. 

We also collect some information automatically when a User visits our website or uses our Services, including information about the specific device being used, including the device’s identifier (e.g., MAC address), IP address, operating system, and other similar information.  We also collect information about use of our website and Services, including information about the pages visited, the time spent on our website or using the Services, the Services used, and other similar information.

Specific categories of information we have collected regarding Users in the last twelve (12) months include:

Category	What is collected	How it is Collected
Identifiers	Name, Company Name, Title, address, email address, telephone number, and other similar identifiers	Directly from Users or automatically from our website or services
Personal Information listed in the California Customer Records Statute	Name, signature, address, telephone number	Directly from Users
Commercial information	Records of services purchased, or considered	Automatically from our website or Services
Internet or other similar network activity	Interaction with our website and online Services	Automatically from our website or Services
Geolocation data	IP address	Automatically from our website or Services

How Does Atlantic Fox Use Information It Collects?

We use Personal Information to operate our business.  Examples of the ways we use User Personal Information include:

• to respond to requests, comments, and questions
• to provide the Services
• to understand User preferences and enhance and personalize Users’ experience
• to maintain User accounts
• to respond to and prevent fraud and other information security risks
• to maintain and improve the Services
• to conduct research and development
• to market existing and new Services
• to provide information about our Services
• to maintain legal and regulatory compliance
• as part of the sale of all or substantially all of our business

Does Atlantic Fox Sell Personal Information about Users?

No.  We do not sell personal information about Users.

Does Atlantic Fox Share Personal Information about Users?

Yes.  Atlantic Fox collects User Personal Information for its own business purposes only.  Atlantic Fox only provides User Personal Information to Atlantic Fox service providers and vendors who have entered into a nondisclosure agreement or other agreement that protects the confidentiality of information provided and prohibits them from using User Personal Information except to provide services to Atlantic Fox and its Clients.

Atlantic Fox uses service providers to provide some Atlantic Fox services.  Atlantic Fox service providers receive information about Atlantic Fox Users solely for the purpose of providing products, services, and support to Atlantic Fox to allow Atlantic Fox to provide the Services and operate its business.  Examples of Service Providers used by Atlantic Fox include cloud storage providers, website and application developers, marketing and advertising companies working on our behalf, and other similar entities that provide services to Atlantic Fox.

In the past twelve (12) months, Atlantic Fox has shared the following categories of Personal Information with its Service Providers or Vendors in all the categories that it collects information, including identifiers, personal information listed in the California records statute, commercial information, Internet or other network information, and geolocation data (described more fully above).

What Policies Govern Third Party Applications?

Our website and certain Services may include links to websites and applications maintained by third parties (“Third Party Applications”).  This Privacy Policy does not apply to Third Party Applications, which are governed by the privacy policies and practices of the Third Party Application providers.  We encourage you to review the privacy policies and practices of those third parties before providing any Personal Information to third parties or using Third Party Applications.

How Does Atlantic Fox Protect User Personal Information?

We take commercially reasonable steps to protect User Personal Information, which may include – depending on the nature of the information and how it is used – physical access controls, encryption, firewalls, intrusion detection systems, network monitoring, and other measures.  However, we cannot guarantee User Personal Information is 100% secure (especially when provided to us over the Internet) and you should exercise caution in providing Personal Information to us. 

Can I Opt-Out of Receiving Promotional Emails and Other Communications?

Yes.  You may opt out of receiving promotional emails from us by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. You may also send requests to opt out by clicking here.

Do You Honor Privacy Rights Provided under U.S. State and Federal Law?

Yes.  It is Atlantic Fox’s policy to comply with all requirements of U.S. State and Federal law regarding the processing of User Personal Information, including the California Consumer Privacy Act (as amended by the California Privacy Rights Act) (collectively, “CCPA”) and their implementing regulations, which Atlantic Fox voluntarily applies to all Users.

Consistent with the requirements of the CCPA, Atlantic Fox recognizes Users’ rights to know and access specific Personal Information about them and to request deletion of specific Personal Information about them.

Right to Know and Access to Specific Personal Information.  You have the right to request that we disclose to you information about our collection, use and disclosure of your Personal Information over the past twelve (12) months.  In response to your verifiable request, we will disclose:

• The categories of Personal Information we have collected about you
• The categories of sources of Personal Information we have collected about you
• Our business or commercial purpose for collecting and sharing your Personal Information
• The categories of third parties with whom we share that Personal Information
• The specific pieces of Personal Information we have collected about you
• If shared for a business purpose, the specific disclosures made for a business purpose made to a third party identifying the categories of information disclosed about you.

Right to Request Deletion.  You have the right to request that we delete your Personal Information subject to certain exceptions.  We may deny your request if retention of your information is necessary for any of the following reasons:

• To complete a transaction which you have requested, provide a service you have requested, or take other actions reasonably necessary in the context of our ongoing business relationship with you or pursuant to contract
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity
• To correct errors or improve our Services;
• To comply with applicable law or legal obligation; or
• To perform internal activities that are reasonably related to the purposes for which the information was collected.

Additional Rights.  You may have additional rights under the law of your state of residence. 

Exercising Your Rights.  To exercise your data privacy rights, you may submit a request to us using one of the following options:

• Please click on the following link so we can process your request
• By mail at Atlantic Fox Technologies, Inc., 1 Hewitt Square, Suite 108, East Northport, New York 11731

You may also have a third party make a request on your behalf.  However, such third party must provide a written, signed authorization from you before making the request.

Please note that we cannot respond to your request if we are unable to verify your identity or the authority of the person making the request.  We may request information from your or the person making the request to verify the request.  The type of information we may request will depend on the method by which you engage with us.  For example, if you have a User account with us, we may send you a confirmation request by email.  If you do not have a User account with us, we may request additional information from you to reasonably verify your identity.

Time to Respond.  We will respond to a verifiable data subject request within forty-five (45) days of receipt.  If we require additional time [up to ninety (90) days], we will inform you of the reason and extension period in writing.  We will typically respond to your request by the email address we have on file for you unless you specifically request that we use another method.  If we are unable to honor your request, we will explain the reasons why we are unable to comply.

Fees.  We do not charge a fee to process a request unless it is excessive, repetitive, or unfounded.  If we decide that a fee is required, we will notify you and provide you a fee estimate before completing your request.

Non-Discrimination.  We will not discriminate against you for exercising your data privacy rights.

Do You Honor Privacy Rights Provided under Non-U.S. Laws?

No.  Atlantic Fox is a U.S.-based entity and maintains its data on servers located in the United States.  Atlantic Fox also does not engage in any processing activity outside the United States.

Does Atlantic Fox Collect Information about Individuals Under the Age of 18?

No.  Atlantic Fox’s website and Services are intended for Users who are at least eighteen (18) years old.  We do not knowingly collect information regarding Users who are under the age of eighteen (18).  If we become aware that we are in possession of information of a user who is under the age of eighteen (18), we will delete that information promptly.

Will this Privacy Notice Change?

We may change this Notice from time to time. If we make any changes to this Notice, we will change the Last Updated date above. If such changes are material in nature, we will provide you with additional notice (such as adding a statement to the main website page or sending you an email notification).

How to Contact Atlantic Fox

If you have any questions about this Notice or other privacy-related issues, please contact us at:

Physical:
Atlantic Fox Technologies, Inc.,
1 Hewitt Square
Suite 108
East Northport, New York 11731

Consumer Privacy Notice

Last Updated: January 2, 2024

Atlantic Fox Technologies, Inc. (“Atlantic Fox”) provides Software as a Service (“SaaS”) solutions (“Services”) to our clients who are seeking better understanding of and engagement with their customers and potential customers.

Our core business involves application of technology solutions to help our clients manage and interpret their data, including Personal Information of their customers.  We also allow our clients with the opportunity to combine their pre-existing data with data they may have obtained from third-party sources.

What Information Does this Consumer Privacy Notice Cover?

This Consumer Privacy Notice covers Personal Information about Consumers that Atlantic Fox collects and processes on behalf of its clients. 

This Consumer Privacy Notice does not cover Personal Information we collect about individuals who visit our website, use our Services, or otherwise engage with us directly through social media, email, telephone, and other methods of communication (“Users”).  For information about our privacy practices concerning Personal Information of our Users, please click here.

What is Personal Information?

Personal Information is information about a specific person or household.  This definition includes any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a specific person or household. 

What Personal Information Does Atlantic Fox Process on Behalf of its Clients?

We process two main categories of Personal Information on behalf of our Clients.  The first category is Personal Information that our Clients provide to us.  The second category is Personal Information they obtain from third parties for our Clients’ specific use.

What Atlantic Fox Privacy Practices Apply to Information Our Clients Provide to Us?

We act as a “Service Provider” with respect to Personal Information that our Clients provide to Atlantic Fox (“Client Personal Information”).  Our Clients act as the data “Controller” with respect to this Personal Information, because they determine the method, means, and purpose of processing the data.  Our Clients’ privacy practices control how this Client Personal Information is processed.  We are required by contract to comply with our Clients’ privacy practices concerning Client Personal Information.

What Atlantic Fox Privacy Practices Apply to Information Obtained from Third Parties?

In the case of Personal Information of Consumers we obtain from our client’s (“Third Party Consumer Personal Information”), this Privacy Notice controls our processing of that Third Party Consumer Personal Information.

What Categories of Third Party Consumer Personal Information Does Atlantic Fox Collect?

Atlantic Fox does not collect  any third-party information, except where provided on behalf of our clients. Specific categories of information regarding Consumers in the last twelve (12) months include:

Categories	Examples
Identifiers	Name, physical address, email address, telephone number
Personal Information Listed in the California Consumer Records Statute	Name, physical address, email address, telephone number
Legally protected characteristics	Ethnicity, gender
Commercial information	Purchasing interests
Education information	Level of education
Inferences	Probabilistic modeling based on consumer interests

Does Atlantic Fox Use Cookies or other Tracking Technologies in Connection with Processing of Third Party Consumer Personal Information?

No.  

How Does Atlantic Fox Use Third Party Consumer Personal Information?

Atlantic Fox processes Third Party Consumer Personal Information solely according to our Clients’ instructions.  Our Clients may use Third Party Consumer Personal Information in our SaaS Services for their own business purposes, which are controlled by their privacy practices.

Does Atlantic Fox Share Third Party Consumer Personal Information?

Yes.  Atlantic Fox provides Third Party Consumer Personal Information to Atlantic Fox service providers who have entered into a nondisclosure agreement or other agreement that protects the confidentiality of information provided and prohibits them from using Third Party Consumer Personal Information except to provide services to Atlantic Fox and its Clients.

Examples of Service Providers used by Atlantic Fox include cloud storage providers, website and application developers and other similar entities that provide services to Atlantic Fox.

In the past twelve (12) months, Atlantic Fox has shared the following categories of Personal Information with its Service Providers including identifiers, personal information listed in the California records statute, legally protected characteristics, commercial information, education information, and inferences (as described more fully above).

How Does Atlantic Fox Protect Third Party Consumer Personal Information?

We take commercially reasonable steps to protect Third Party Consumer Personal Information, which may include – depending on the nature of the information and how it is used – physical access controls, encryption, firewalls, intrusion detection systems, network monitoring, and other measures. 

Does Atlantic Fox Use Third Party Consumer Information to Send Promotional and Marketing Communications? 

Atlantic Fox does not use Third Party Consumer Personal Information to send marketing communications on its own behalf.  To opt-out of the use of Third Party Consumer Personal Information by our clients, you must contact our clients directly. 

Do You Honor Privacy Rights Provided under U.S. State and Federal Law?

Yes.  It is Atlantic Fox’s policy to comply with all requirements of U.S. State and Federal law regarding the processing of Third Party Client Personal Information, including the California Consumer Privacy Act (as amended by the California Privacy Rights Act) (collectively, “CCPA”) and their implementing regulations, which Atlantic Fox voluntarily applies to all Third Party Consumer Personal Information.

Consistent with the requirements of the CCPA, Atlantic Fox recognizes Consumers’ rights to know and access specific Personal Information about them and to request deletion of specific Personal Information about them. 

Right to Know and Access to Specific Personal Information.  You have the right to request that we disclose to you information about our collection, use and disclosure of your Personal Information over the past twelve (12) months.  In response to your verifiable request, we will disclose:

• The categories of Personal Information we have collected about you
• The categories of sources of Personal Information we have collected about you
• Our business or commercial purpose for collecting and sharing your Personal Information
• The categories of third parties with whom we share that Personal Information
• The specific pieces of Personal Information we have collected about you
• If shared for a business purpose, the specific disclosures made for a business purpose made to a third party identifying the categories of information disclosed about you.

Right to Request Deletion.  You have the right to request that we delete your Personal Information subject to certain exceptions.  We may deny your request if retention of your information is necessary for any of the following reasons:

• To complete a transaction which you have requested, provide a service you have requested, or take other actions reasonably necessary in the context of our ongoing business relationship with you or pursuant to contract
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity
• To correct errors or improve our Services;
• To comply with applicable law or legal obligation; or
• To perform internal activities that are reasonably related to the purposes for which the information was collected.

Additional Rights.  You may have additional rights under the law of your state of residence. 

Exercising Your Rights.  To exercise your data privacy rights, you may submit a request to us using one of the following options:

• Please click on the following link so we can process your request
• By mail at Atlantic Fox Technologies, Inc., 1 Hewitt Square, Suite 108, East Northport, New York 11731

You may also have a third party make a request on your behalf.  However, such third party must provide a written, signed authorization from you before making the request.

Please note that we cannot respond to your request if we are unable to verify your identity or the authority of the person making the request.  Because Third Party Consumers do not have accounts with us, we may request information from your or the person making the request to verify the request.  For example, we may ask you to confirm certain elements of your Personal Information that likely would be known only to you.

Time to Respond.  We will respond to a verifiable data subject request within forty-five (45) days of receipt.  If we require additional time [up to ninety (90) days], we will inform you of the reason and extension period in writing.  We will typically respond to your request by email unless you specifically request that we use another method.  If we are unable to honor your request, we will explain the reasons why we are unable to comply.

Fees.  We do not charge a fee to process a request unless it is excessive, repetitive, or unfounded.  If we decide that a fee is required, we will notify you and provide you a fee estimate before completing your request.

Non-Discrimination.  We will not discriminate against you for exercising your data privacy rights.

Do You Honor Privacy Rights Provided under Non-U.S. Laws?

No.  Atlantic Fox is a U.S.-based entity and maintains its data on servers located in the United States.  Atlantic Fox also does not engage in any processing activity outside the United States.

Does Atlantic Fox Collect Information about Individuals Under the Age of 18?

No.  Atlantic Fox does not knowingly collect information regarding users who are under the age of eighteen (18).  If we become aware that we are in possession of information of a user who is under the age of eighteen (18), we will delete that information promptly.

Will this Privacy Notice Change?

We may change this Notice from time to time. If we make any changes to this Notice, we will change the Last Updated date above. If such changes are material in nature, we will provide you with additional notice (such as adding a statement to the main website page or sending you an email notification).

How to Contact Atlantic Fox

If you have any questions about this Notice or other privacy-related issues, please contact us at:

Physical:
Atlantic Fox Technologies, Inc.,
1 Hewitt Square
Suite 108
East Northport, New York 11731