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Politique de confidentialité

CINCO (collectively with its affiliates and subsidiaries, as relevant, hereinafter referred to as “CINCO”, “we”, “us”) respect and is committed to support rights to privacy and understand the importance of protecting personal information and complying with applicable data protection laws.
 

This Privacy Policy (“policy”) outlines how we collect, use, share, and safeguard your Personal Data (as defined below) when you interact with us, including through our websites/platform (including our AI Experience Room) (collectively “Platform”), mobile applications, products, and services (collectively, “Services”).
 

This policy applies to all users globally and applies to our affiliates and subsidiaries to the extent they have access to your Personal Data.
 

This policy provides information on the collection, use, and sharing of your Personal Data when CINCO acts, depending on the circumstances, either as (i)  a data controller (meaning where CINCO controls how and why your personal information is processed) or (ii)  a data processor (when processing your Personal Data on behalf of its clients who are the data controllers), unless otherwise provided in a separate agreement or mandated by any applicable law.
 

For the avoidance of doubt, when CINCO’s corporate clients license from CINCO the use of the Platform for the development of their respective businesses, they shall be deemed to be the data controller (and CINCO the data processor), with respect to the personal data they are collecting from individuals using the Platform.


Our Platform may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies or their processing of your data (including Personal Data). We do not control these third-party websites, and we encourage you to read the privacy policy of every website you connect to in order to understand your rights and obligations.


By accessing and/or using our Services, you agree to the terms of this policy.
 

1. Definitions
 

For the purposes of this policy:
 

  • Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to CINCO as the legal entity that collects Consumers' personal data and alone, or jointly with others, determines the purposes and means of the processing of Consumers' personal data, or on behalf of which such data is collected, that does business in the State of California. Business may also be CINCO’s corporate client when such client has acquired the right to use the Platform (on a White Label basis) for the development of its business and will therefore collect Consumers’ personal data for its own behalf.

  • Consumer, for the purpose of the CCPA, means a natural person who is a California resident.  A resident, as defined by relevant law applicable in California, includes (1) every individual who is in the USA other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA but who is outside the USA for a temporary or transitory purpose.

  • Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to us as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

  • Cookies, are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.

  • Do Not Track (DNT), is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

  • GDPR, means Regulation (EU) 2016/679 of the European Parliament and the Council of 27th April 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

  • Personal Data (or Personal Information) is any information that relates to an identified or identifiable individual.

 

More specifically, where GDPR applies to any processing, Personal Data means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

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More specifically, where the CCPA applies to any processing, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

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  • Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's Personal information to another business or a third party for monetary or other valuable consideration.

  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

  • Website/Platform refers to this website.

  • You, means the individual whose Personal Data we are collecting and processing. This includes individuals who are accessing or using one of our Platform (either directly or via one of our corporate client(s) to which we have licensed the right to use such Platform), individuals who contact us with a query, and contacts at organizations that we work with.

 

2.  What Personal Data we collect


We may collect the following types of Personal Data from You:
 

  • Contact Information: may include name, email address, phone number, and postal address where CINCO acts as controller (e.g., business contacts or account administration). Where CINCO acts as processor for a corporate client, the data collected depends on that client’s configuration and purposes.

  • Technical Data: IP address, browser type, device information, and usage data (e.g., interaction with our websites/plaforms).

  • Marketing Data: Your preferences in receiving marketing from us and your communication preferences.

  • Interaction Data: audio or voice inputs voluntarily provided when interacting with AI-enabled features of the Platform.

  • Transaction Data: Information related to your purchases, orders, or subscriptions.

 

3. How we collect your Personal Data
 

We collect Personal Data in several ways, including:
 

  • Directly from You: When You provide your data through emails, when completing forms and surveys from our Platform, or when you are creating an account with us. We may also collect information You have provided to us at meetings, exhibitions and events (both physical and digital). Your employer, as our client or partner may provide your contact information to us where you have consented to this, and as required to provide You our products and services.

  • Automatically: When You interact with our website or download mobile and desktop app from our Platform through the use of cookies, server logs, and similar technologies.

  • Third Parties: We may collect your Personal Data from third parties, such as marketing partners or publicly available sources, where legally permitted. For example, we may collect and receive Personal Data about You from companies that purchase or distribute CINCO’s products by way of co-branded or private/white-labeled websites/platforms.
     

4. How We Use Your Data


We use your Personal Data for the following purposes:
 

  • Service Delivery: To provide and maintain our Services, including in order to operate fully white-labelled solutions for our corporate clients, agencies, and other commercial third parties, and for customer support.

  • Marketing: To send You relevant marketing communications, offers, and promotions, in compliance with your preferences and applicable law.

  • Analytics: To analyze user behavior, improve our website, and monitor usage trends.

  • Legal Compliance: To comply with legal obligations and protect our rights.

 

5. Choice/opting out of marketing 

 

We offer You the choice of receiving different types of communications and information related to our Services. You may subscribe to e-newsletters or other publications; You may also elect to receive marketing communications and other special offers from us via email. If at any time You would like to change your communication preferences, we provide unsubscribe links and an opt-out mechanism in all our marketing communications or You may contact us directly at the email provided below (under Section 18 – How to Contact Us).

 

Note that if You opt out of marketing, You may still receive service-related and market research messages from us (and You may still receive marketing messages for a short period after opting out while we update our records).

 

6. API Services
 

For certain limited services provided by CINCO, we use third-party API Services such as the YouTube API or Google API. Such third-party API services used in CINCO products only captures data You designate CINCO to access on third-party platforms. Such data may include your content stored on third-party sites, associated meta data, and account information related to those third-party sites. Data collected by CINCO using third-party API services may be used to archive content and certain associated meta data uploaded to those third-party sites by You.
 

Additionally, such data may be used by CINCO as part of an authentication and authorization framework to access your data on third-party sites. Third-party email, social media, and other communication services are not offered, controlled, or provided by CINCO. CINCO is not responsible for how a third party transmits, accesses, processes, stores, uses, or provides your data (including Personal Data) to CINCO. In addition, such third-party services are subject to the terms and conditions of such third-party providers and Google privacy policy and/or the YouTube terms of service may apply.
 

7. Artificial Intelligence


As part of certain Services, users may interact with AI-enabled conversational or voice-based functionalities designed to simulate product or service experiences and provide interactive responses.
 

These AI functionalities analyze user inputs, including voice or text interactions, solely to generate real-time responses and improve the user experience. The AI system is not used to identify individuals, perform biometric identification, or make automated decisions producing legal or similarly significant effects.
 

CINCO does not use Personal Data to train AI models. CINCO may use anonymized or aggregated usage data that does not identify individuals for service improvement, analytics, and machine learning purposes.
 

8. Legal Basis for Processing Personal Information


We process your Personal Data on one or more of the following lawful grounds:
 

  • Performance of a Contract: Processing is necessary for the performance of a contract to which you are a party. For example, to manage your account with us, to provide support You have asked for and to respond to questions You may have when using our services. We may also be requested by our corporate clients who have purchased the use of our solutions on a white labelled basis (such as a website/platform created by CINCO for them) to process your Personal Data under their instructions.

  • Legitimate Interests: Where it is necessary for our legitimate business interests, except where those interests are overridden by your privacy rights. For example, to develop and improve our Services, to monitor its usage, to analyse how our Services are being used, how users are interacting with the Services, prevent possible wrongdoing in connection with the use of our Services, and carry out satisfaction surveys.

  • Consent: Where we have obtained your explicit consent (e.g., for marketing communications when legally required).

  • Legal Obligation: To comply with a legal obligation (e.g., tax reporting, legal claims).
     

9. Data Sharing and Disclosure


We may share your Personal Data with the following parties:
 

  • Service Providers: We engage third-party service providers to help with our operations, such as hosting, data analytics, payment processing, or marketing services.

  • Affiliates and Business Partners: We may share data with our affiliated companies and trusted partners for business purposes.

  • Legal Compliance: We may disclose your personal information if required by law or in response to valid requests by public authorities (e.g., court orders, government agencies).
     

Where third parties are performing processing on our behalf, we will require these organizations to adopt adequate technical and organizational security measures to protect Personal Data and to ensure the processing of Personal Data is only performed as instructed by us and for no other purposes and in compliance with applicable data protection laws.
 

We do not sell your Personal Data to third parties.
 

10. International Data Transfers
 

As a global company, your Personal Data may be processed outside the country of your residence by us or our affiliates, partners, or service providers, and agents working on our behalf. The transfer to other countries by CINCO and its affiliates shall be in accordance with applicable data protection laws, which may include on the basis of an EU adequacy decision or other appropriate safeguards. Appropriate safeguards may include: CINCO and third parties entering into the Model Clauses approved by the relevant authorities (i.e., European Commission, Information Commissioner’s Office, Federal Data Protection, and Information Commissioner, etc.) or relying on any approved alternative mechanism to ensure lawful transfer and protection of Personal Data in accordance with applicable data protection law in the jurisdiction where data may be processed.
 

11. Data Retention
 

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements or performing any obligation to You or any regulatory authority. Under some circumstances we may anonymize your Personal Data so that it can no longer identify, or be associated with, You. We reserve the right to use such anonymous and de-identified data for service improvement, analytics, and security purposes or any legitimate business purpose.
 

Once your Personal Data is no longer needed, we will securely delete or anonymize it.


12. Your Privacy Rights


If your Personal Data has been submitted to us by or on behalf of a corporate client of our Services who is the controller of that Personal Data and we are the processor, you will need to contact them directly if you wish to exercise any rights you may have under applicable data protection laws. If you make your request to us, we will need the name of the client who submitted your Personal Data to us, and we will refer it on to them.
 

Your local applicable law may provide certain rights regarding the collection, use, and sharing of your Personal Data. As a minimum standard, we aim to enable all individuals to exercise the privacy rights set out below, but please note that these rights and the conditions for exercising and processing them (including response times) may vary depending on the jurisdiction in which you reside.
 

Additional Information Where You have GDPR-based Privacy Rights
 

Under the European Union (EU) data protection laws, and notably the GDPR, where these apply to You (notably, based on your being resident in a EU country), You have rights we need to make You aware of. The rights available to You depend on our reason for processing your Personal Data:
 

  • Your right of access. This enables You to receive a copy of the Personal Data we hold about you. This right always applies. There are some exemptions, which means You may not always receive all the information we process.

  • Your right to rectification. You have the right to ask us to rectify Personal Data you think is inaccurate. You also have the right to ask us to complete Personal Data you think is incomplete. This right always applies.

  • Your right to erasure. You have the right to ask us to erase your Personal Data in certain circumstances.

  • Your right to restriction of processing. You have the right to ask us to restrict the processing of your Personal Data in certain circumstances.

  • Your right to object to processing. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes You want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.

  • Your right to data portability. This only applies to Personal Data you have given us. You have the right to ask that we transfer the Personal Data you gave us from one organization to another selected by you or give it to You, and in a structured, commonly used, machine readable format. The right only applies if we are processing Personal Data based on your consent or under, or are in discussions with You about entering into a contract and the processing is automated.
     

To exercise any of these rights where applicable, please contact us at the addresses indicated in Section 18 (How To Contact Us) below.


13. Cookies and Tracking Technologies
 

We use cookies and similar tracking technologies to enhance your user experience, analyze trends, and gather information about how our Platform and relevant Services are used. You can control the use of cookies through your browser settings or our cookie management tool.
 

For more details, please refer to our Cookie Policy set out below.


14. Data Security
 

We take adequate measures to protect your Personal Data from unauthorized access, alteration, or destruction (both online and offline). These include encryption, secure servers, and access controls. However, no security system is completely impenetrable, and we cannot guarantee the absolute security of your Personal Data. Furthermore, You should note that when we host a Platform on behalf of a client (such as AI Experience Room), and such client acts as data controller (and we are a processor), such data will be returned to the applicable client at the end of our relationship with that client or other lawful reason.


15. California: Your Rights under the CCPA (where applicable to You)
 

Under this policy, and by law if You are a resident of California, You have the following data privacy rights in respect of a controller of relevant Personal Data (whether CINCO or our corporate client for whom we are operating the Platform on a white labelled basis):
 

  • The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

  • The right to access/the right to request. The CCPA permits You to request and obtain from CINCO, information regarding the disclosure of your Personal Data that has been collected in the past 12 months by CINCO or its subsidiaries to a third-party for the third party's direct marketing purposes. Be aware that we are transferring your Personal Data to our client (for which we build the AI Experience Room or Platform for).

  • The right to know about your Personal Data. You have the right to request and obtain from us information regarding the disclosure of the following:

    • The categories of Personal Data collected

    • The sources from which the Personal Data was collected

    • The business or commercial purpose for collecting or selling the Personal Data

    • Categories of third parties with whom we share personal data

    • The specific pieces of Personal Data we collected about You

  • The right to delete Personal Data. You also have the right to request the deletion of your Personal Data that have been collected.

 

Exercising your CCPA Data Protection Rights

In order to exercise any of your rights under the CCPA, and if You are a California resident, You can email us the details to our contact email below (Section 18 – How To Contact Us).
 

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
 

Do Not Sell My Personal Data
 

We do not sell personal information but we are transferring it to our client. However, our client and service Providers we partner with.
 

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that you use.


Website
 

You can opt out of receiving ads that are personalized as served by our service providers by changing your preferences in our Cookie Policy. The opt-out will place a cookie on your computer that is unique to the browser You use to opt out. If You change browsers or delete the cookies saved by your browser, You will need to opt out again.


Mobile Devices


Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to your interests:
 

  • "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices

  • "Limit Ad Tracking" on iOS devices


You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.


"Do Not Track" Policy as required by California Online Privacy Protection Act (CalOPPA)
 

Our Service does not respond to Do Not Track signals.
 

However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
 

Your California Privacy Rights (California Business and Professions Code Section 22581):
 

California Business and Professions Code section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
 

To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below, and include the email address associated with your account.


Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.


16. Children’s Privacy

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Our Service does not address anyone under the age of 16. We do not knowingly collect Personal Data from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If We become aware that we have collected Personal Data from anyone under the age of 16 without verification of parental consent, we take steps to remove that information from our servers.
 

17. Changes to This Privacy Policy
 

We may update this policy from time to time to reflect changes in our practices or legal requirements. If we modify this policy, we will post the revised version here. You should review this page periodically for updates.
 

If we make a change that significantly affects your rights or, to the extent we are permitted to do so, significantly change how or why we use personal information, we will notify you by way of a prominent notice or pop-up on our applicable Platform.
 

18. How To Contact Us
 

If you have any questions or concerns about this Privacy Policy or our Personal Data processing practices or wish to exercise a relevant data privacy right under applicable law, you can contact us at the following address:
 

CINCO, 139 Saint-Paul West, Suite 5, Montreal, Quebec, H2Y 1Z5, Canada or, 
 

by email at the following Email Address: [email protected]
 

 

COOKIE POLICY

 

Introduction
 

In addition to any information that you choose to submit to us, we or selected third parties may use a variety of technologies that store or access information already stored on your personal computer, laptop, tablet or mobile phone (each a device) whenever you visit or interact with our website (may be referred to as “Platform” or “AI Experience Room”).
 

We use various technologies to collect and store information when you use the Platform. These may include using cookies or other tracking technologies (including web beacons) to identify your browser or device and give you a personalized experience when using our Services.


Where required by applicable law, including in the European Economic Area and the United Kingdom, non-essential cookies (including performance, analytics, and advertising cookies) are only placed on a user’s device after the user has provided their consent through our cookie consent management tool.
 

Users may accept or reject non-essential cookies at any time through the cookie preference center available on the Platform.

 

1. The Information Collection Technologies (Cookies/Web Beacons)


A few of the methods that may be used to store or access information already stored on your device include the following (and in future, other technology and methods will be developed).

 

A. Cookie Type: Required Cookies (often “called “Strictly Necessary cookies”)
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Description: Required cookies make it possible for you to access our Platforms, navigate within the Platforms, and access information related to your account if applicable. Each time you log into the Platforms, a cookie containing an encrypted, unique identifier that is tied to your account is placed on your browser. These cookies allow the AI Experience Room to uniquely identify you when you are logged into the Platforms and to process your online transactions and requests.
 

These cookies are not used for marketing or tracking purposes and are strictly necessary for the operation of the Platform.
 

Management Settings: Required cookies are necessary to operate the Platforms, so you can’t opt out of them.

 

B. Cookie Type: Functionality Cookies
 

Description: Functionality cookies allow the Platforms to remember information you have entered or preferences you select, and provide enhanced, more personal features. These cookies allow you to optimize your use of the website Platforms after logging in. These cookies can also be used to remember changes you have made to text size, fonts, and other parts of web pages that you can customize.
 

Management Settings: You can use your browser settings to opt out of functionality cookies. Note that opting out may affect the functionality of our Site or Platforms for you.

 

C. Cookie Type: Performance Cookies
 

Description: These cookies collect data about how visitors use the Platforms. This includes data like which pages visitors go to the most. These cookies do not directly identify users but may collect information such as online identifiers and usage data, which is used in an aggregated form to improve Platform performance.
 

The data these cookies collect is aggregated and intended to be anonymous and used to improve how the site functions and performs.
 

Management Settings: You can use your browser settings to opt out of performance cookies.

 

D. Cookie Type: Targeting or Advertising Cookies
 

Description: Advertising cookies are placed by third-party service providers operating through our Platform. These cookies may collect information about users’ interactions with the Platform, such as browsing activity, pages visited, and engagement with content, in order to measure advertising performance, analyze traffic, and deliver relevant marketing communications.

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Where required by applicable law, including in the European Economic Area and the United Kingdom, these cookies are only activated after users have provided their consent through our cookie consent management tool.

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For more information about how these third-party providers process personal data, users may consult the respective privacy policies of such providers.

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Management Settings:  Certain advertising partners may provide their own opt-out mechanisms or preference management tools. These tools are operated by the relevant third parties and are subject to their own privacy policies and practices.

 


CINCO does not control or operate these third-party opt-out tools. However, users may manage or withdraw their cookie consent at any time through CINCO’s cookie preference settings available on the Platform.
 

Our Platform may use advertising and analytics services provided by third-party partners such as Google, Meta (Facebook), LinkedIn, and similar providers. These technologies help us measure the effectiveness of our marketing activities and better understand how users interact with our Platform.
 

The third-party providers listed below may place cookies or similar tracking technologies through our Platform and may collect information such as IP addresses, device identifiers, and interaction data. Where required by applicable law, including in the European Economic Area and the United Kingdom, such technologies are activated only after users have provided their consent through our cookie consent management tool. The collection and use of information by these third parties are governed by their respective privacy policies.

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  • Facebook Custom Audience - We may use Facebook Custom Audience to track how you use the Platforms and target ads to you on Facebook.

 

  • Google Adwords Conversion - We may use Google Adwords Conversion to track our support conversion metrics for our search engine marketing campaigns.

 

  • Google Dynamic Remarketing - We may use Google Dynamic Remarketing to target search engine marketing to users of the Google search engine.

 

  • LinkedIn Ads - We may use LinkedIn Ads to track how you use the Platforms and target ads to you on LinkedIn.

 

  • LinkedIn Marketing Solutions - We may use LinkedIn Marketing Solutions to track how you use the Platforms and target ads to you on LinkedIn.

 

  • X Advertising - We may use X (ex-Twitter) Advertising to track the success of and target social ads placed on x.com.

 

The above list of third-party Service providers that place cookies is subject to change and the above list may not include all such providers at any given time.

 

What’s a Web Beacon?
 

We may use web beacons along with cookies to gather data about use of the Platforms and interaction with emails from CINCO (or our corporate client). Web beacons are clear electronic images that can recognize certain types of data on your computer, like cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon. For example, we may put web beacons in marketing emails that notify us when you click on a link in the email that directs you to the Platforms or one of its pages. We may use web beacons to operate and improve the Platforms and email communications.

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2. Third Party Collection of Information
 

We have provided you with information above about the types of third party information storage or gathering techniques on our website. This policy does not apply to applications (apps), technologies or sites that are owned and/or operated by other parties (such as app developers, third party advertisers or third party ad servers), even if they use our technology to store or collect data. This includes third parties that embed our technology in their apps or advertisements to facilitate download tracking or advertisement serving. We do, however, work with third parties to ensure that you are provided with the necessary information and are provided with the opportunity to make your choice. The relevant third party’s terms of use, privacy policy, permissions, notices and choices should be reviewed by yourself regarding their collection, storage and sharing practices since they may be different from ours.

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3. What We Do With IP Addresses
 

When you visit the Platforms, or use our products and services, like our APIs, we may collect your IP addresses to track and analyze information about the devices that are connecting to our systems and about where those devices are located. For example, we may use IP addresses to (i) troubleshoot technical concerns, (ii) maintain website safety and security, (iii) restrict access to our websites to certain users, and, (iv) better understand how our websites are utilized  and track which regions visitors to our Platforms or Customers logging into our Platforms come from.

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An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet.

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4. How We Treat Do Not Track Signals/California Do Not Track Disclosure
 

Various browsers allow a “do not track” (DNT) setting that relies on a technology known as a DNT header, which sends a signal to websites visited by the individual about the individual’s browser DNT setting. At this time, there is no general agreement on how companies like CINCO should interpret Do Not Track signals. Therefore, CINCO does not currently commit to respond to DNT signals, whether that signal is received on a computer or on a mobile device. We will make efforts to monitor developments around DNT browser technology and the implementation of a standard.

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5. Contact Us


If you have any questions about this Cookie Policy, You can contact us by email at: [email protected]

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