Privacy Policy

This Privacy Policy was last updated on November 15, 2021

Who We Are

Exadel, Inc., a California corporation (“Exadel”, “we”, or “us”) provides software development services and is headquartered in Walnut Creek, California.

Exadel respects your right to privacy and your right to limit exchanges of information to only those you initiate. As explained in more detail below, we do acquire certain personal information from private individuals in the course of business, but we do not share this personal information with third parties. We do use this information to better serve you and facilitate your use of our services, applications, and website.

By using any of Exadel’s services, applications, website, mobile sites, and/or other goods or services (collectively, the “Services”), and by also consenting to provide your Personal Information (defined below) when you provide information to us, you acknowledge that you accept the practices and policies outlined in this privacy policy (“Privacy Policy”). If you do not agree with or cannot comply with this Privacy Policy, please do not use our Services. This Privacy Policy may change from time to time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

What This Privacy Policy Covers

This Privacy Policy describes Exadel’s practices with respect to Personal Information that we collect when you use our Services. This Privacy Policy does not apply to the use of your Personal Information that may be collected by third parties that Exadel does not own or control or that do not support Exadel in providing the Services. “Personal Information” is information that is personally identifiable like names, addresses, e-mail addresses, or phone numbers, as well as other non-public information that is associated with the foregoing, as described herein.

What Information Do We Collect?

Information you provide us: We may collect the following Personal Information when you voluntarily provide it to us through a number of features available on the Services and consent to this. For example:

• When you contact us through our application form on Services, we will collect any information that is contained in (and/or attached to) your form, so that we can process your application and invite you to an event or to an interview you have applied for. 
• Application form fields vary depending on the context, but in most cases they include all or some of the following information about you:
  • First and last name
  • Email
  • Phone Number
  • Country
  • City
  • Background
  • Tech stack
  • Desired position
  • Link to a public profile (e.g. LinkedIn or GitHub)
  • CV file

Your Personal Information submission is voluntary and we only use the personal information that you provide for the purposes for which it was collected.

Information we collect automatically: The Exadel web server also records visitor IP addresses and domain names for reporting and site usage analysis. This information is reported internally and then purged when necessary.

• Services usage information: Exadel and our third–party service providers may also use a variety of technologies that passively or automatically collect information about how our visitors are browsing the website, including your operating system, browser type, pages visited and your use of tools on the Services. This data helps us understand what content and services are most relevant to you, so we can customize our Services to your needs. This information is only statistical data and does not include Personal Information.
• Cookies: Like many websites, we use “Cookies” for our website, which are small text files placed on your browser to facilitate site navigation and to personalize your experience. Cookies allow us to select which ads or offers are most likely to appeal to you, based on your interests, preferences, location, or demographic information. There are a couple different types of cookies. A “session” cookie is stored only in your computer’s working memory (RAM) and only lasts for your browsing session. When you close all your browser’s windows, or when you shut down your computer, the session cookie disappears forever. A “persistent” cookie is stored on your computer’s hard drive until a specified date, which could be tomorrow, next week, or 10 years from now. Persistent cookies stay on your computer until either a) they expire, b) they are overwritten with newer cookies, or c) you manually remove them. If you would prefer not to accept cookies, you can change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; or set your browser to automatically not accept any cookies. While you will still be able to use the Services if you disable Cookies in your browser, certain parts of the Services may not function as effectively.
• Server log files: An Internet Protocol (IP) address is a number that is automatically assigned to the computer that you are using by your internet service provider and is identified and logged automatically in our server log files whenever you visit one of our Services, along with the time of the visit and the page(s) that were visited. We use IP addresses for purposes such as routing visitors to the appropriate website for the visitor’s country, calculating usage levels, helping diagnose server problems, and administering our Services. If you accessed one of our Services using a mobile device like a smartphone, we may also collect your phone’s unique device ID and other similar mobile device data.

Information we collect through Third Parties: We also collect the following information from third parties:

• Third Party Applications: We also offer and deliver services, content or interactive features through and/or using third party application programming interfaces (API), gadgets, extensions that are hosted on our Services or through other third party websites, or social networking platforms. When you participate in these services, products, applications, or otherwise connect with, or “accept” or “allow” third party applications, networks, platforms or services through our Services and/or one of our services or products, you are authorizing those third parties to receive your information and additionally to potentially share any or all of your information with us, based on your privacy or other settings on the particular third party network or platform. Any personal or other information we receive by these means will be treated and/or processed according to this Privacy Policy.
• Location data: Some of our Services may allow you to submit information about your general location, such as your ZIP code or address, in order to locate stores that sell our products or provide other location-related services. With your consent, some of our Services also may capture and record certain geo-location or global positioning data in order to provide location-related functionality. We may link such location data to other information that you provide to us or that may be accessed in connection with your use of our Services.

Online Advertising

To provide you a more relevant and interesting experience, we may work with third party companies to display ads elsewhere on the Internet. These companies may use cookies (a small text file), pixels, or similar technologies that are placed in browsers to gather information about your visits to the Exadel website, your use of the Services, and your visits elsewhere on the Internet. These companies use this information to provide you more relevant advertising known as interest-based advertising. Some of these companies may be participants in the Digital Advertising Alliance (“DAA”). The DAA offers a choice mechanism with respect to certain types of data collection and use. Visit www.aboutads.info to exercise choice with respect to participants of the DAA. If you change computers or browsers, use multiple computers or browsers, or delete your cookies, you may need to repeat this process for each computer and each browser.

How Do We Use The Information We Collect?

In general, we use the information (including Personal Information) you submit to us or third parties who work on behalf of or with us to respond to requests you make or to improve our Services and better meet the needs of our consumers. Only those Exadel employees who require this information will have access to it. Examples of how we might use this information include:

• To review your professional background and skill set for a decision if to invite you to a job interview
• To review your background for a decision if to invite you to an educational event held by Exadel (e.g. internship or meetup)

Exadel will not intentionally disclose a private individual’s Personal Information to any third parties for marketing or promotional purposes or for any other purpose unless a court orders us to do so or unless the private individual authorizes us to do so, in which case we may disclose Personal Information to the extent of the authorization.

If you supply Exadel with your e-mail address, postal address, and/or phone number through our website, you may receive promotional or informational communications from Exadel. If you prefer not to receive these communications, or if you have any questions about how we use the information you provide, please send an e-mail message to us at info@exadel.com.

What Information Do We Share?

We are using a third-party solution (CRM) for processing the applications received via Website via its application form. A copy of the Personal Information you submitted will be recorded in that CRM solution for further processing by Exadel personnel.

Except as otherwise stated in this Privacy Policy, we do not disclose to or share your Personal Information with third parties, unless you ask or authorize us to do so.

We may provide your Personal Information to third party service providers and suppliers who work on behalf of or with us to provide you with some of the services and features of the Services and to help us communicate with our users (including in connection with payments). However, these service providers and suppliers do not have any independent right to use this information except to help us provide the Services.

In the event Exadel goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Information will likely be among the assets transferred. You acknowledge that such transfers may occur, and that any acquirer of Exadel or its assets may continue to use your Personal Information as set forth in this Privacy Policy. You hereby consent to Exadel sharing your Personal Information under the above circumstances.

We may (and you authorize us to when you first consented) disclose information we have collected from and about you (including Personal Information) if we believe in good faith that such disclosure is necessary to: (a) comply with relevant laws or to respond to subpoenas or warrants served on us; (b) to enforce any agreement we may have entered into with you and to enforce this Privacy Policy; or (c) to protect and defend the rights of other users of the Services, or third parties.

We may offer community features and public interactive forums through our Services, like discussion boards, product reviews, chat rooms, forums, wikis, social networking platforms and blogs. When you participate in such offerings, your username and other Personal Information you choose to provide or communicate in these public spaces may be seen by others, and you should exercise caution when disclosing such information and realize that information you post could remain viewable in cached or archived webpages or copied and stored by other users even after you remove it. We cannot control the actions of other users of our Services, and we are not responsible for the results of your postings. Furthermore, when you participate in these interactive features, you may be agreeing to terms of use that, among other things, allow us to use your name and other information in our marketing and advertising.

If, despite our security precautions, Personal Information about a private individual is inadvertently disclosed, to the extent permitted by law, we will do everything reasonable to limit and remedy the disclosure. However, to the extent allowed by law, Exadel accepts no liability for any unintentional disclosure.

What Choices Do You Have Regarding Your Personal Information, and How To Correct Information.

You have the right to request a copy of the Personal Information that we hold about you. If you would like a copy of some or all of this information, please email us at info@exadel.com.

We want to make sure that your Personal Information is accurate and up to date. You may ask us to correct or remove information that is inaccurate.

We will include unsubscribe instructions in each newsletter or promotional communication you receive from us.

We may send you service-related announcements (such as, but not limited to, notice that we have changed the Services or this Privacy Policy) when we believe it is necessary to do so. If you do not wish to receive these announcements, you have the option to terminate your status as a Exadel newsletter subscriber. You understand that any such termination of your Exadel newsletter subscriber status may involve deletion of your Personal Information from our live databases. Exadel will not have any liability whatsoever to you for any termination of your account or related deletion of your information.

When we delete information that we have collected from or about you, it will be deleted from our active databases, but may remain in our archives.

Links to Other Websites

The Services, including our website, may contain links to other websites that are not owned or controlled by Exadel. This includes links from advertisers, sponsors and/or partners that may use our logo(s) as part of a co–branding or co–marketing agreement. The provision of such links does not signify our endorsement of such websites, location or its contents. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites. Please be aware that the terms of this Privacy Policy do not apply to any outside websites (including, but not limited to, any of our e-commerce providers).

Privacy of Minors

Our Terms of Use prohibit individuals under age 13 from using our Services. We do not intentionally collect or maintain information from persons under the age of 13. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian’s consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 13, we will make reasonable efforts to delete such information from our records. We also recommend that parents monitor their children’s Internet activities and learn and employ software or other tools that can help their children enjoy their online experience without compromising their personal safety or allowing them to use the Internet in a manner inconsistent with their parent/guardian’s preferences.

Security and Confidentiality

Exadel has put in place commercially reasonable and appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. However, no company, including Exadel, can fully eliminate security risks associated with Personal Information.

Exadel restricts authorized access to your Personal Information to those Exadel personnel who have a legitimate purpose to know that information to provide products or services to you and those persons you have authorized to have access to such information. We also require that third parties providing services on our behalf protect Personal Information and not use it for purposes other than providing assistance to Exadel. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

International:

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers. By using our Services and providing us with information, you consent to the transfer of information to countries outside your country of residence, including the United States, which may have different data protection rules than in your country, provided, however, that we will comply with those rules that have extra-territorial application.

Changes To This Privacy Policy

We may amend this Privacy Policy from time to time. If we make material changes to this Privacy Policy, we will notify you through one of our Services or, if you have provided your e-mail address, by e-mail.

How To Contact Us

If you have any questions or suggestions regarding our Privacy Policy please contact us by sending us an e-mail to info@exadel.com.

Exadel Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in Exadel Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

Our website may collect Personal Information. In particular, Exadel has collected the following categories of Personal Information from its consumers within the last twelve (12) months:

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

Personal Information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  – health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  – personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

‌ ‌

Exadel obtains the categories of Personal Information listed above directly from you. For example, from forms you complete or products and services you purchase.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Exadel disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you (also called a data portability request).
• If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: sales, identifying the Personal Information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Exadel delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

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

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at 1-866-304-7961.

Visiting www.exadel.com.

Emailing us at info@exadel.com.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

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

• 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 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.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to info@exadel.com or write us at: 1340 Treat Blvd. #375, Walnut Creek, CA 94597.