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Civilio.AI Privacy Policy

Effective Date: March 1, 2026

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1. Introduction

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2. Scope

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3. What Information We Collect

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4. Use of Cookies and other Tracking Technologies

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5. Why We Collect Information

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6. When We Disclose Information

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7. Retention of Personal Information

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8. Your Choices About the Information We Collect

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9. Children’s Privacy

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10. Visitors to the Site Outside of the United States

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11. Links

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12. Security

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13. Your California Privacy Rights

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14. Your Privacy Rights under Other US State Laws

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15. Your Rights Under the General Data Protection Regulation

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16. Your Rights Under the UK GDPR

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17. Changes to This Privacy Policy

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18. Contact Us

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  1. Introduction

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Welcome to Civilio AI. You have arrived at a website provided by Civilio AI, Inc. (“Civilio,” “we,” “our” or “us”) and you are part of a revolution. Civilio is a B2B SaaS company committed to bringing massive efficiency to journalism and corporate content creation. Our CIVILIO AI is the first-of-its-kind, self-prompting, and fully autonomous AI SaaS content generation engine. You will be one of the first users of CIVILIO as we launch in Beta. 

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Even in Beta, at Civilio, we take your privacy seriously. We provide this Privacy Policy (“Policy”) to tell you what information we collect about you, how we obtain it, how we share it, and how you may limit the ways in which we use your Personal Information. If you have questions about this Policy after you review it, feel free to contact us at privacy@Civilio.ai.

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  1. Scope

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This Policy governs the Civilio.ai website, its subdomains (collectively referred to as the “Site”), and all portals, products, services, interactive features, and software (such as CIVILIO, Civilio’s SaaS AI Content engine) or other services controlled by us that post a link to this Policy, as well as any Personal Information provided by you or collected by us when you interact with us online, such as when you contact us with an inquiry via email or webform. We refer to all the above as our “Services.” For the purpose of this Notice, “Personal Information” means any Personal Information relating to an identified or identifiable individual that is protected by applicable privacy laws. The definition of Personal Information does not include publicly available information from federal, state, or local government records, such as real estate or property records, criminal or civil records, professional licenses or other public information.

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Among other places, we offer the Services on our Civilio Platform and via the CIVILIO SaaS (collectively, the “Platform”), allowing Platform users (“Users”) to leverage AI to create, generate, and produce written content to distribute information, boost traffic, conversion, and SEO rankings. Our Services are also used by our subscription partners (“Subscribers”), visitors to our Site (“Site Visitors”) and individuals applying for employment with us (“Employment Applicants”). All references to “you” or “your” in this Policy mean the person that registers for, accesses, or uses the Site, Platform, or Services. If you use or access any of the Services on behalf of an entity or other individual, you represent and warrant that you have the authority to bind that entity or individual. This Policy, as incorporated into the Terms of Service, forms a contract between you and Civilio, and if you are using the Site or Services on behalf of an entity or organization, such entity or organization will also be considered a party to this Policy.

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By using our Site, the Platform, or otherwise using our Services, you acknowledge this Policy and agree to our Terms of Service (“Terms”).

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  1. What Information We Collect

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As a rule, we limit the Personal Information we collect to that which is adequate, relevant and reasonably necessary for us to provide our Services to you. Because our Platform is constantly evolving, please be aware that inputs into our Platform will be used to improve our Platform and provide you with better results and content. We therefore urge you not to input confidential, sensitive, or other Personal Information when using the Platform.

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Information That You Provide to Us

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As you interact with our Site, Platform, or Services, we collect the following Personal Information via the webforms or inputs/uploads on our Site, via the online chat function and through communications with us, such as telephone calls, text messages, emails and other communications.

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Users and Subscribers

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  • Contact information such as your first and last name, username, job title, email address, home or business address, telephone numbers, or mobile numbers;

  • Entity information that may be associated with you, such as your employer or the organization on behalf of which you are using the Platform;

  • Financial information for payment for access to the Platform, such as a credit card or debit card number, bank account information and your payment, service and purchase history;

  • Any other identifying information that you provide via our Site.

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Site Visitors

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  • Contact information such as your first and last name, email address, job title, home or business address, telephone numbers, mobile numbers or any information that you have entered into a data collection field on our Site.

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Employment Applicants

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  • Contact information such as your first and last name, email address, home or business address, telephone numbers, mobile numbers;

  • Your current or past employment or educational information;

  • Relevant licenses and certifications; and/or

  • Other information contained within your application or supporting documents that could reasonably be used to identify you.

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Information That Is Automatically Collected

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Like many businesses, we and our service providers automatically collect and/or store certain information when you visit or interact with the Site, Platform, or Services (“Usage Information”), including via cookies and other tracking technologies (see Use of Cookies and Other Tracking Technologies section below). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Usage Information includes:

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  • Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;

  • Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);

  • Referring and exit web pages and URLs; 

  • The areas within the Site that you visit and your activities there, including remembering you and your preferences;

  • Your Device location or other location information, including the zip code, state or country from which you accessed the Services;

  • Your Device characteristics (such as device type (computer vs. mobile) and ID, operating system, hardware); 

  • Certain other Device data, including the time of day you visit our Site or other information used to provide analytics or other usage information;

  • Information about your engagement with our emails; and

  • Statistical information about how both unregistered and registered users, collectively, use the Site and Services.

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For location information, some of our Services include features based on users’ actual locations and may report on users’ current locations (“Location-Based Services”). If you use Location-Based Services, we collect and store information about your location at the time you use those Location-Based Services (in addition to some automatically collected geolocation data). This information comes from a variety of sources depending on the device you use to access the Services; for example, a mobile phone may report its GPS location at the time Location-Based Services are used. 

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If you do not wish for us or our service providers to collect and use location information, you may disable the location features on your device. Consult your device settings for instructions. Please note that if you disable such features, your ability to access certain features, Services, content, promotions, or products may be limited or disabled.

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Information Collected from Third Parties

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The Site includes functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we might obtain information about the traffic and usage of Civilio from third parties. We might also provide links to make it easier to send a communication from the Site, or we may use third parties to make it easier to send emails or post to social media (like a “Share” or “Forward” button). These third parties also use cookies and other tracking technologies to capture information about your interactions with Civilio. 

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Civilio does not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.

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Inferences and Automated Decision-Making

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We derive information or draw inferences about you based on information we collect about you. For example, based on your browsing or inputs, we may infer your gender, your interest in certain activities or subjects, or information about your preferred activity on our Platform over time. In addition, our AI text and content generation and our service chatbot may use automated decision-making to provide you with enhanced results. The law on automated decision-making is still evolving and we will update our policies with additional guidance as the law requires. 

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  1. Use of Cookies and other Tracking Technologies

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We use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies used on the Site, include, but are not limited to, the following (as well as future-developed tracking technology or methods that are not listed here):

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  • Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device. Our Site may use HTTP cookies, HTML5 cookies and other types of cookie technology to store information on local storage. 

  • Pixels: A pixel is a small graphic file that allow us and third parties to monitor the use of the Site and provide us with information based on your interaction with the Site

  • Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages.

  • Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. 

  • ETag, or entity tag. An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. 

  • Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.

  • Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user). 

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We may use the following types of cookies:

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  • Strictly necessary cookies. These cookies are essential for you to browse the Sites and use its features, such as accessing secure areas of the site. 

  • Functional cookies. Also known as “preference cookies,” these cookies allow the Sites to remember choices you have made in the past, like what language you prefer, or what your username and password are so you can automatically log in.

  • Analytics cookies. Also known as “performance cookies,” these cookies collect information about how you use a website, like which pages you visited, and which links you clicked on. Their purpose is to improve website functions. This includes cookies from third-party analytics services if the cookies are for the exclusive use of the owner of the website visited. We may use analytics services like Google Analytics in this manner.

  • Targeting cookies. These cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share that information with other organizations or advertisers. These are persistent cookies and almost always originate from third parties.  

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  1. Why We Collect Information

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We use the information we collect about you in a variety of ways, including the following:

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To Provide Our Services

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We process certain Personal Information when you access or use our services, including to:

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  • process your requests for our products and Services;

  • suggest improvements in your User experience; 

  • create and verify user accounts;

  • facilitate the functionality of our Site, including payment-related functionality and communications; and

  • customize experiences and personalization when you are on our Site.

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To Communicate with You

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We process certain information to communicate with you in relation to your accounts, our services, our marketing, and your requests, including to:

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  • communicate with you about orders, services and accounts;

  • respond to your customer service inquiries and requests for information;

  • post your comments or statements on our Site;

  • send you personalized promotions, content, and special offers;

  • communicate with you about our products and Services, or other promotional purposes;

  • implement your communications preferences, such as sharing information with selected third parties so that they may communicate with you; and

  • provide important product and Service information.

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For Improvement of Our Site or Services

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Because our Site and Platform are in beta, we want to ensure that our Site, Platform, and Services are continually improving. To do so, we may process certain Personal Information, including to:

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  • maintain, improve, and analyze our Site or Services; and

  • detect, prevent, or investigate suspicious activity or fraud.

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We welcome your feedback on ways that we can make our Platform better for everyone. We have provided a “Beta Feedback” button on the bottom right of the screen, and you may use it to provide suggestions or report any glitches within the Platform. 

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To Comply with Applicable Laws

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We may be required to process certain Personal Information under certain laws and regulations, such as tax laws, as well as to:

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  • maintain appropriate records for internal administrative purposes; and

  • comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.

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To Enforce our Terms, Agreements, or Policies

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To maintain a safe, secure, and trusted environment for you when you use our Site, Platform, and Services, we use your Personal Information to ensure our terms, policies, and agreements with you and any third parties are enforced.

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To Evaluate Applications for Employment

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We may use your Personal Information to evaluate your application for employment or to administer employment benefits for our employees, as applicable.

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With Your Consent

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We process certain Personal Information to fulfill any other business or commercial purposes at your direction or with your consent, which may be given based on your usage of the Site, Platform, or Services, or we may also collect affirmative consent at or before the time that you provide your Personal Information. 

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  1. When We Disclose Information

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To the extent permitted by law, certain Personal Information about you may be disclosed in the following situations:

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  • Service providers. To provide information to our affiliates and nonaffiliated third parties who perform services or functions for us in conjunction with our services to you, but only if we have a contractual agreement with the other party which prohibits them from disclosing or using the information other than for the purposes for which it was disclosed. Examples of such service providers include our payment processor, cloud services provider, customer service or helpdesk provider, email marketing provider, technical support, or other service providers.

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  • Legal process. To comply with a validly issued and enforceable subpoena or summons; as a part of any actual or threatened legal proceedings or alternative dispute resolution proceedings either initiated by or against us, provided we disclose only the information necessary to file, pursue, or defend against the lawsuit and take reasonable precautions to ensure that the information disclosed does not become a matter of public record. 

  • Business transactions. In conjunction with a prospective purchase, sale, or merger of all or part of our practice, if we take appropriate precautions (for example, through a written confidentiality agreement) so the prospective purchaser or merger partner does not disclose information obtained in the course of the review.

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Finally, we may aggregate, de-identify, and/or anonymize any information collected through the Site or Services such that such information is no longer linked to your personally identifiable information. We may use and share this aggregated and anonymized information (non-Personal Information) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.

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  1. Retention of Personal Information

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Civilio will retain your Personal Information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

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All information you provide to us is stored on our secure servers or those of our third-party data storage providers.

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We utilize the following criteria to determine the length of time for which we retain Personal Information:

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  • How long we have had a relationship with you or provided our Services to you; 

  • The business purposes for which the information is used, and the length of time for which the information is required to achieve those purposes;

  • Whether we are required to retain the information, or the information is otherwise necessary, in order to: comply with legal obligations or contractual commitments: defend against potential legal claims: detect or prevent potential illegal activity or actions in violation of our policies and procedures; secure our systems and online environment; or protect health and safety;

  • The privacy impact on individuals of ongoing retention; and

  • The manner in which information is maintained and flows through our systems, and how best to manage the lifecycle of information in light of the volume and complexity of the systems in our infrastructure.

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At present, we have only launched in Beta – we will continue to modify our retention policy as we learn the categories of Personal Information that are maintained, if any, on our Platform.

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  1. Your Choices About the Information We Collect

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Communications Preferences

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We request that you keep your Personal Information accurate and up to date. If you would like to change your contact information, please contact us using the information in the Contact Us section below. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). 

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You can opt out of receiving marketing emails from us at any time. You will still receive transactional messages from us. To manage your email preferences with us, please click on the Unsubscribe link in any email you receive from us or contact us using the information in the Contact Us section below. Your choice will not affect our ability to share information in the other ways described in this Policy.

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Controlling Your Cookies 

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You can opt-out of cookies by enabling an opt-out preference signal on your browser or opting-out of cookies in our Sites’ cookie preference centers.

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On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below to learn how to modify your web browser’s settings on the most popular browsers:

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Note that if you turn cookies off, you may be unable to access certain parts or benefit from the full functionality of the Site or Platform. To learn more about cookies and similar technologies or to opt-out of targeted advertising cookies, visit resources from the Digital Advertising Alliance (“DAA”) or the Network Advertising Initiative (“NAI”). We do not control these opt-out links or whether any organization chooses to participate in these opt-out programs. 

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Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, ads based on the website you are viewing (e.g., contextually based ads), or ads that are not targeted at you and may be less relevant. Also, if your browser (like some Safari browsers) is configured to reject opt-out cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective. 

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Do Not Track

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Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally agreed upon standard for what an organization should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here

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  1. Children’s Privacy

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Our Site is not intended for use by children under the age of 16. We do not request, or knowingly collect, any personally identifiable information from children under the age of 16. If you are the parent or guardian of a child under 16 who you believe has provided her or his information to us, please contact us using the information in the Contact Us section below to request the deletion of that information.

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  1. Visitors to the Site Outside of the United States

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If you are visiting the Site from a location outside of the U.S., your connection will be through and to servers located in the U.S. All information you receive from the Site will be created on servers located in the U.S., and all information you provide will be maintained on web servers and systems located within the U.S. The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Site or Platform or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information in the United States and in other countries, as set forth in this Policy.

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  1. Links

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For your convenience, the Site and this Policy may contain links to other websites. Civilio is not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Site should be deemed to imply that Civilio endorses or has any affiliation with the links.

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  1. Security

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We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from the Site, and you provide us with your information at your own risk. 

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Any payment transactions are processed through a third-party processor, in accordance with their respective terms and security protocols. You should review the third party’s policy for their privacy practices.

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  1. Your California Privacy Rights

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This section of the Policy applies solely to California residents. While we do not currently meet the threshold for application of the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”), we adopt this Section to provide you with certain inquiry and other rights typically provided under the CCPA. Any terms defined in the CCPA or CPRA have the same meaning when used in this Section.

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California residents have the following rights:

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  • To know the categories of Personal Information being collected about you, the purposes for which the categories of Personal Information are collected or used, and whether that information is sold or shared;

  • To know the length of time we intend to retain each category of Personal Information; 

  • To know whether your Personal Information is sold or disclosed and to whom;

  • To access your Personal Information;

  • To delete the Personal Information you have provided to us, with certain exceptions; 

  • To correct your Personal Information;

  • To opt out of the sale of Personal Information; 

  • To know if Sensitive Personal Information (“SPI”) is being collected about you, the categories of SPI being collected, the purposes for which the categories of SPI are collected or used, and whether the SPI is sold or shared; 

  • To limit the use of your SPI if it is used for cross-contextual behavioral advertising or for the purposes of inferring characteristics about you; and

  • Not to be discriminated against, even if you exercise your privacy rights.

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Request for Information, Correction, or Deletion

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California residents have the right to request, under certain circumstances, that a business that collects Personal Information about them disclose the information listed below for the preceding 12 months:

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  • The categories of Personal Information collected about you;

  • The categories of sources from which the Personal Information is collected; 

  • The business or commercial purpose for collecting, selling or sharing Personal Information;

  • The categories of third parties to whom the business discloses Personal Information; and

  • The specific pieces of Personal Information collected about you.

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Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

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You can also request that we correct or delete your Personal Information. There may be certain exceptions to our obligation to correct or delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information. 

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Personal Information Collected 

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We have collected the following categories of Personal Information from consumers within the last twelve (12) months:

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Category of Personal Information

Examples of this Category

Sources of Personal Information

Business Purpose for Collection

Identifiers

Real name, alias, postal address, unique personal identifier, online identifier, Internal Protocol address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers.

YouAutomaticallyThird Parties

To provide, improve and market our products and ServicesTo provide information you requestedTo identify potential customersTo verify identityTo prevent fraudTo comply with law

Personal information described in California Civ. Code § 1798.80(e)

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.

You

To provide, improve and market our products and ServicesTo provide information you requestedTo identify potential customersTo verify identityTo prevent fraudTo comply with law

Characteristics of protected classifications under California or federal law

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or credit, marital status, medical condition (AIDS/HIV status, cancer), 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), political activities or affiliations, familial status, source of income status, status as a victim of domestic violence, assault, or stalking. 

You

To provide, improve and market our products and ServicesTo provide information you requestedTo identify potential customersTo verify identityTo prevent fraudTo comply with law

Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

You

To provide, improve and market our products and ServicesTo provide information you requestedTo identify potential customersTo verify identityTo prevent fraudTo comply with law

Biometric information

An individual’s genetic, physiological, biological or behavioral characteristics, including information pertaining to an individual’s deoxyribonucleic acid (DNA) or activity patterns.  

N/A

N/A

Internet or other electronic network activity information

Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.

Automatically

To provide, improve and market our products and ServicesTo provide information you requestedTo identify potential customersTo verify identityTo prevent fraudTo comply with law

Geolocation data

Physical location and/or movements.

YouAutomatically 

To provide, improve and market our products and ServicesTo provide information you requestedTo identify potential customersTo verify identityTo prevent fraudTo comply with law

Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information.

N/A

N/A

Professional or employment related information

Current or past job history or performance evaluations 

YouThird Parties[for job applicants and employees only]

To evaluate employment applications, make hiring decisions, determine eligibility for benefits.  To determine eligibility for employee benefits and provide such benefits to employeesTo verify identityTo prevent fraudTo comply with law

Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. § 1232g, 34 CFR 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. 

N/A

N/A

Inferences drawn from other Personal Information

Information used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YouAutomaticallyThird Parties

To provide, improve and market our products and ServicesTo provide information you requestedTo make our results more tailored to youTo identify potential customersTo verify identityTo prevent fraudTo comply with law

Sensitive Personal Information

Social security number, driver’s license number, account log-in, debit, or credit card number in combination with password or PIN, precise geolocation (less than 1850 sf radius), racial/ethnic origins, religious or philosophical beliefs, union membership, contents of e-mails or texts to others, genetic/biometric data, health information, sex life/sexual orientation data

You(financial information)

To process paymentsTo provide information or services you requestedTo verify identityTo prevent fraudTo comply with law

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Information related to how long we retain each category of Personal Information is included in the Retention of Personal Information section above. 

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No Personal Information Sold or Shared

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Because we are just launching, we have not sold or shared (as those terms are defined in the CCPA) to third parties any Personal Information in the last twelve (12) months.

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Personal Information Disclosed for Business Purposes

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We may disclose all of the categories of Personal Information collected above to our service providers for the following business purposes:

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  • Helping to ensure the security and integrity of Personal Information

  • Debugging to identify and repair errors

  • Performing services on behalf of the business

  • Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services

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Do Not Sell My Personal Information

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As a California resident, you also have the right, at any time, to tell us not to sell Personal Information – this is called the “right to opt-out” of the sale of Personal Information. We do not sell Personal Information, but we recognize that some privacy laws define “Personal Information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale,” such as cookie tracking. To opt-out of this, please click on the link in our footer for Your Privacy Choices and make your elections.

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Right to Limit Use of Sensitive Personal Information

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California residents have the right to limit the use of each type of Sensitive Personal Information for each purpose with each type of third-party partner. Currently, we only collect financial card information for purposes of facilitating your payment for our Services. We do not provide your Sensitive Personal Information to any third parties other than those service providers that are necessary for us to provide our Services to you. 

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Right Not to Be Discriminated Against

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We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by California law, we will not:

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  • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you with a different level or quality of goods or services.

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

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Third Party Marketing

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California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. We do not currently disclose Personal Information protected under this section to third parties for their own direct marketing purposes and we have not provided any such information to third parties in the prior 12 months. 

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Exercising Your California Privacy Rights 

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You or your authorized agent may make a request to access, correct, delete, opt-out of the sale of your Personal Information, or limit the use of your Sensitive Personal Information by contacting us using the information in the Contact Us section below.

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If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency to obtain the information, and you are only entitled to make this request twice in a 12-month period. For emails, please include “California Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a California resident. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

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  1. Your Privacy Rights under Other US State Laws

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If you are a resident of Colorado, Connecticut, Utah or Virginia, you may have the right, upon a verified request, to:

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  • To confirm whether a controller is processing your personal data and to access such personal data; 

  • To correct inaccuracies in your personal data (not Utah); 

  • To delete your personal data; 

  • To obtain a copy of your personal data that you previously provided to us in a portable, and if technically feasible, readily usable format, if processing is carried out by automated means; 

  • To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. 

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To exercise these rights, you or your authorized agent may make a request to confirm, access, correct, delete, obtain a copy, or opt-out of the processing of your personal data for targeting advertising, sale, or profiling by using the Your Privacy Choices link or contacting us using the information in the Contact Us section below.

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If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency in order to obtain the information. For emails, please include “Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a resident of Colorado, Connecticut or Virginia. We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period. 

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Right to Opt Out Under Applicable State Laws 

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Residents of Colorado, Connecticut, Utah (in some circumstances) and Virginia have the right to opt out of the sale of their Personal Information and targeted advertising. To exercise your right, please click on the Your Privacy Choices link  in the footer of our Site. 

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California residents may have additional rights, as shown in the “Your California Privacy Rights” section above.

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Opt-Out Preference Signals

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Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. In certain regions, when we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.

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Appeals of Our Decisions

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In some states, you may appeal to us if we refuse to take action on your exercise of certain choices described above. To appeal such a refusal, please contact us using the information in the Contact Us section below with the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email. If your appeal is denied, residents of certain states can contact their attorney general as follows:

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  1. Your Rights Under the General Data Protection Regulation 

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This section of the Policy applies if you are a data subject who resides or is located in the European Economic Area (“EEA”). We adopt this section to comply with European privacy laws, including the General Data Protection Regulation (“GDPR”). Any terms defined in the GDPR have the same meaning when used in this section. 

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Under applicable law, we are considered the “data controller” of the Personal Information we handle under this Policy. In other words, we are responsible for deciding how to collect, use and disclose this information, subject to applicable law.

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We want to ensure that the Personal Information we possess is always accurate and therefore we encourage you to update your information in your own account in case any changes have occurred. We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Information, subject to applicable law. We take reasonable steps to ensure that the Personal Information that we process is limited to the Personal Information that is required in connection with the purposes set out in this Policy.

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If you are a resident of or located within the EEA, you have certain data protection rights. These rights include:

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  • The right to access, update or delete the information we have collected from you. 

  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

  • The right to object. You have the right to object to our processing of your Personal Information.

  • The right of restriction. You have the right to request that we restrict the processing of your Personal Information.

  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.

  • The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information.

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Legal Basis for Processing Personal Information

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We rely on the following legal bases for processing your Personal Information:

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  • Contract: To conclude or perform a contract with you; for example:

    • To provide our Services;

    • To manage our accounts and records;

    • To handle your inquiries and requests;

    • When you apply for employment through our Site, processing of your contact details and data about your employment history and education (as needed to evaluate your job application, to conduct job interviews, and as is otherwise needed for recruitment) is necessary to respond to your request to process your application for employment. If you do not provide this data, we will not be able to process the application that you send through our Site.

  • Legitimate Interests: When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you unless we have your consent or those activities are otherwise required or permitted by law. You have the right to object to processing that is based on our legitimate interests, as further described below. Examples of legitimate interests include:

    • To respond to your customer service inquiries and requests for information;

    • To maintain, improve, and analyze our Site and Services;

    • To conduct marketing activities;

    • To detect, prevent, or investigate security breaches or fraud; and

    • To facilitate the functionality of our Site;

  • Legal Compliance: To comply with our legal obligations; for example:

    • To maintain appropriate records for internal administrative purposes and as required by applicable law, and

    • To provide important product safety information.

  • Consent: We will send you information by email on our Services or other promotions only with your consent or if you otherwise opt-in to receiving those communications. If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent at any time as described below.

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How to Exercise Your Rights Under the GDPR

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If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the contact details below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA to obtain the information. We will respond to your request within 30 days or let you know if we need additional time. 

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Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.

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Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us as follows:

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Email: privacy@Civilio.ai 

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  1. Your Rights Under the UK GDPR 

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If you are based in the United Kingdom, the following provisions also apply:

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If we share your personal data within Civilio or with third parties located outside the United Kingdom, we take steps to ensure that appropriate safeguards are in place to guarantee the continued protection of your personal data, such as by entering into the international data transfer addendum to the European Commission’s Standard Contractual Clauses, adopted by the UK Government under section 119A of the Data Protection Act 2018.

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You have the same data subject rights as those for the EU listed above, except that references to the “GDPR” should be read as references to the “UK GDPR” and complaints should be filed with the UK supervisory authority, the Information Commissioner’s Office.

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  1. Changes to This Privacy Policy

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We may change this Privacy Policy at any time. We will post all changes to this Policy on this page and will indicate at the top of the page the modified policy’s effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy policy. If required by the applicable law, we will notify you of the changes. 

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By continuing to use the Site or Services or providing us with information following such a replacement Policy being uploaded, you agree that you will be bound by the Privacy Policy as changed.

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  1. Contact Us

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If you have any questions or suggestions regarding this Policy, please contact us by using the Chat function on our Site or by Email to: privacy@Civilio.ai.

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