Last Updated: March 21, 2024

This Privacy Notice primarily explains how Equisolve Inc., (“Equisolve,” “we,” “us, or “our”) processes your information in connection with the public-facing portions of its corporate website, https://www.equisolve.com/ (the “Equisolve Website”). In a separate section, we explain how we process your information when providing our website and media development services to our customers (the “Services” and, such website, the “Customer Website”).

Important Notice for Individuals in the European Economic Area, United Kingdom, and Switzerland: If you are located in the European Economic Area, United Kingdom, or Switzerland, and either a customer who has purchased our Services or a user of Customer Website, please see the EU. U.S. Data Privacy Framework Disclosures section below for an important notice regarding Equisolve’s compliance with the EU-U.S. Data Privacy Framework.

1. Collection of Personal Data

We collect your information when you visit our Equisolve Website, such as information we collect from you or from third parties, including via automated technologies such as cookies and other online tracking technologies.

Information Directly From You

The types of information we collect from you include:

• Inquiry or Feedback Information: When you reach out to us on our Equisolve Website, or through the email or phone numbers provided on our Contact page, we may collect your full name, company name and job title, email address, phone number, what Services you may be interested in, and any other information you choose to provide to us (e.g., via free-text fields, on calls).
• Job Applicant Information: We may collect personal data about you when you apply for a job through our Website, such as name, address, email address, phone number, education or employment history, and other information you choose to provide to us through your cover letter or resume.

Information From Third Parties

The types of personal data we collect about you from third parties include:

• Service Providers: We may collect your information from service providers who perform services on our behalf such as third parties who conduct marketing, advertising, or analytics activities on our behalf.
• Referral Information: We may collect personal data about you from other customers or prospective customers, such as in the case of referrals or introductions. This information may include your name, company, job title, email address, phone number, or other information that the third party chooses to provide.
• Other Sources: We may collect your personal data from other sources including third-party information providers or through corporate transactions (i.e., mergers or acquisitions).

Information Collected Automatically

We, and our third-party partners, may collect personal data about you automatically. We, and our third-party partners, may collect this information from you via cookies, pixels, embedded scripts, or other similar technologies (collectively, “tracking technologies”). We use tracking technologies to maintain and improve our Website, communicate or remember you on our Website, or otherwise personalize your experience on the Website.

We may collect the following types of personal data:

• Browser and device information, such as IP address, device or other digital user IDs, browser or device type and version, other user agent string data, geolocation information, preferences, and other settings.
• Website analytics and usage data, such as the path taken to, through, or when exiting our Website, what page you are on or have visited, links clicked, white papers or other materials downloaded, videos or other content viewed, email open rates, mouse movements, scrolls, clicks, browsing or search activity, and chat function usage and logging of such conversations).

Google Analytics: To opt-out of Google Analytics (one of the third-party analytics providers we may utilize), you may download the Google-provided browser add-on here: https://tools.google.com/dlpage/gaoptout. You can learn more about Google’s general practices at http://www.google.com/policies/privacy/partners.

General Controls: Please consult your device’s or browser's documentation or settings menus for the choices you may have regarding blocking cookies or other tracking technologies. For example, some browsers allow you to block all third-party cookies on websites.

2. Uses of Personal Data

We may combine the information we collect from or about you. We use this information for purposes such as the following:

• To provide the Equisolve Website to you;
• To fulfil your requests for information or otherwise respond to inquiries or comments about the Equisolve Website or our Services;
• To personalize your experience on the Equisolve Website;
• For marketing and advertising purposes;
• To monitor, improve, and develop the Equisolve Website;
• For internal research purposes, including development of existing or new products and services;
• To protect the security and integrity of the Equisolve Website, Equisolve’s IT or other infrastructure, or other information processed by, or products/services provide by, Equisolve;
• Disclosures in response to requests by public authorities, including for the purpose of meeting national security or law enforcement requirements.
• To comply with legal requirements and obligations, enforcing our agreements, to establish, exercise, or defend legal claims;
• In the event of a merger, dissolution, reorganization, or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity;
• For any other purposes to which you consent, where directed by you, or as otherwise provided in this Privacy Notice or in another notice to you; and
• As otherwise permitted by law;
• In an ongoing effort to better understand the visitors to the Equisolve Website, we might also analyze your information in aggregate form to carry out, maintain, manage, and improve operations in connection with the Website. We may also disclose aggregated analytics to current and prospective business partners and to other third parties for other lawful purposes.

3. Disclosure of Personal Data

We may disclose your information with the following third parties:

• Service Providers: We may disclose your personal data with service providers who assist us with providing you with the Equisolve Website, such as IT infrastructure, web hosting, customer service, CRM providers, marketing and advertising activities, mailing or communications, fraud prevention, or analytics services.
• Law Enforcement, Regulators, or Other Parties for Legal Reasons: We may disclose information as required by law or subpoena, or if we believe that such disclosure is required to comply with applicable law including to meet national security or law enforcement requirements, to establish, exercise, or defend legal claims, enforcing our agreements, to protect the security and integrity of our Website, or to protect our rights, property, or personal safety of Equisolve, our visitors, or other persons.

4. Control Over Your Information

You may control your information in the following ways:

Email Preference: You may opt out of e-mail messages by unsubscribing through the link at the bottom of our e-mail messages. Please note that you may not be able to opt out of transactional or administrative notifications.

5. Children’s Personal Data

Our Website is not intended for individuals under 13 years old (“children”). We do not knowingly collect the personal data of children.

6. Links to Third-Party Websites or Services

Our Services may provide links to other digital properties that are controlled by, or disclosures provided by, third parties. We are not responsible for the content, usage, terms, properties, or privacy policies of third parties.

7. Update to this Notice

We may update this Privacy Policy periodically to reflect changes to our privacy practices. If we make any material changes to our privacy practices, we will indicate at the top of the Privacy Policy the date when it was most recently updated and you shall be bound to such changes when accessing the Equisolve Website or our Services. We may also provide notice of such material changes in other manners at our discretion, such as by prominently noting next to the “Privacy Policy” link on the Equisolve Website that this Privacy Policy was updated or by posting a notice in your account. We encourage you to periodically review this page for the latest information on our privacy practices.

8. Contact Us

If you have any question about this Privacy Notice, please contact us at privacy@equisolve.com.

9. Equisolve’s Services

Equisolve provides website and media development services to its customers, which also includes add-on or other ancillary services in some cases. Equisolve retains and processes the personal information that it receives while providing these Services on behalf of its customers as a “processor” (or similar term, such as “service provider”) and as otherwise permitted under applicable privacy laws.

Though the information we process may differ based on the customer, generally speaking, this information includes (i) business contact information and related information of our customers, such as name, email address, login/password, job title, phone number, payment details, and company, (ii) customer’s prospective or current investor or website visitor contact information, such as name, email address, phone number, and any other personal information submitted through the Customer Website or otherwise via the Services; (iii) technical information, such as IP address, browser user agent string, and any other information required to provide the Services or otherwise related to the use of cookies, pixel tags, or similar technologies for analytics/marketing purposes (as directed by the customer), and (iv) other categories as instructed by customers, such as information in connection with teleconferencing, live broadcasts, and recordings.

This information is used to provide the Services and related components (e.g., as applicable, the content management system, sending of emails, embedding of scripts, provision of teleconferencing or other services, Customer Website hosting, payment processing, cybersecurity, fraud detection, compliance with applicable law).

We disclose the information to our various subprocessors, such as those listed here, or to third parties as otherwise directed by our customers.

All terms and conditions in relation to Equisolve’s provision of services to its customers is pursuant to Equisolve’s agreement with such customers. The information set forth herein is purely for informational purposes and for purposes of the Data Privacy Framework disclosures set forth below.

10. Data Privacy Framework

Equisolve complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”), as set forth by the U.S. Department of Commerce. Equisolve has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Equisolve has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (“DPF”) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Equisolve complies with the EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and the Swiss U.S. DPF regarding the collection, use, and retention of personal data transferred from to the U.S pursuant to such frameworks.

Equisolve is subject to the investigatory and enforcement powers of the Federal Trade Commission (the “FTC”).

Complaints per the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles, Equisolve commits to resolve complaints about your privacy and our collection or use of your personal data transferred to the United States pursuant to the DPF Principles. European Union, UK, or Swiss individuals with inquiries or complaints regarding this notice should first contact Equisolve at privacy@equisolve.com.

Equisolve has committed to refer unresolved privacy complaints under the Data Privacy Framework Principles to an independent dispute resolution mechanism, the BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See DPF Annex 1 at https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.

Onward Transfer to Third Parties

In the event that we disclose your personal data to third parties to perform certain business-related services on our behalf as our “agents” (as such term is utilized under the Data Privacy Framework), we will do so only for limited and specified purposes consistent with any notice provided to you, your choices regarding processing and disclosure, or as directed by our customers (in each case, as applicable). These companies perform services at our instruction and pursuant to contracts which require they provide at least the same level of privacy protection as is required under the Data Privacy Framework and notify us if they are no longer able to provide such protections, at which point we will take reasonable remedial steps.

Equisolve’s accountability for personal data that it receives under the DPF and subsequently transfers to a third party is described in the DPF Principles. In particular, Equisolve remains responsible and liable under the DPF Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Equisolve proves that it is not responsible for the event giving rise to the damage.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Option to Limit Certain Onward Transfers to Third Parties

Individuals have the opportunity to opt-out of sharing of their personal data with third parties other than our agents or before we use it for a purpose other than which it was originally collected or subsequently authorized. To limit the use and disclosure of your personal data under the Data Privacy Framework, please submit a written request to privacy@equisolve.com indicating as such. In some cases where our sharing of information is pursuant to our customers’ direction, you may be referred to such customer for processing of your request.

We will not disclose your sensitive personal data to any third party without first obtaining your opt-in consent. In cases where we provide Services to our customers, we rely on our customers to obtain such consent as the data “controller”.

In each instance, please allow us a reasonable time to process your response.

Your DPF Rights

Subject to the final sentence of this paragraph, upon request to privacy@equisolve.com, we will confirm whether we are processing your personal data pursuant to the DPF and provide you with the data within a reasonable time. Further, subject to the final sentence of this paragraph, you also have the right to correct, amend, or delete the personal data processed pursuant to the DPF where it is inaccurate or has been processed in violation of our privacy disclosures to you, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated. We may require payment of a non-excessive fee to defray our expenses in this regard. Please allow us a reasonable time to respond to your inquiries and requests. In some cases, please note that we will have to refer your request to a customer for further steps on how to process your request, such as in cases where we are processing your personal data in relation to a Customer Request. This is because, in such cases, our customer is the data “controller” and we serve as their “processor” and thus the customer determines whether to grant such request, to what extent we should collect and retain data, and how we should effectuate such request if at all.

How We Protect Your Data

We will implement reasonable and appropriate security measures to protect your personal data from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in processing and the nature of such data.