Introduction

At Infusion Capital Group (the “Company” or “We”), we respect your privacy and are committed to protecting it through our compliance with this policy.

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This policy describes the types of information we may collect from you or that you may provide when you visit this website (our “Website”) and our practices for collecting, using, maintaining, protecting and disclosing that information.

This Policy Applies to Information We Collect:

• On this Website

• In e-mail, text and other electronic messages between you and this Website

• Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website

• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries)

• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age Of 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us via our contact us link.

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Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number or ANY OTHER INFORMATION THE WEBSITE COLLECTS THAT IS DEFINED AS PERSONAL OR PERSONALLY IDENTIFIABLE INFORMATION UNDER AN APPLICABLE LAW (“personal information”)

• That is about you but individually does not identify you, and/or

• About your internet connection, the equipment you use to access our Website and usage details.

We collect this information:

• Directly from you when you provide it to us

• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies

• From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material or requesting further services. We may also ask you for information when you report a problem with our Website

• Records and copies of your correspondence (including e-mail addresses), if you contact us

• Your responses to surveys that we might ask you to complete for research purposes

• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website

• Your search queries on the Website

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• Details of your visits to our Website, including traffic data, location data, and other communication data and the resources that you access and use on the Website.

• Information about your computer and internet connection, including your IP address, operating system and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.

• Store information about your preferences, allowing us to customize our Website according to your individual interests.

• Speed up your searches.

• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

• Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We do not collect personal Information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

Third-Party Use of Cookies and Other Tracking Technologies
Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
 

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you

• To provide you with information, products or services that you request from us

• To provide you with information about our services

• To provide you with notices about your account/subscription, including expiration and renewal notices.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection

• To notify you about changes to our Website or any products or services we offer or provide through it

• To allow you to participate in interactive features on our Website

• In any other way we may describe when you provide the information

• To fulfill any purpose for which you provide it

• For any other purpose with your consent

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
 

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates

• To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.

• To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.

• To fulfill the purpose for which you provide it. For example, if you give us an e-mail address to use the “e-mail a friend” feature of our Website, we will transmit the contents of that e-mail and your e-mail address to the recipients.

• For any other purpose disclosed by us when you provide the information.

• With your consent.

We may also disclose your personal information:

• To comply with any court order, law or legal process, including to respond to any government or regulatory request

• To enforce or apply our terms of use and other agreements, including for billing and collection purposes

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

• We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Accessing and Correcting Your Information
You may send us an e-mail via our contact link to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use.
Your California Privacy Rights

California 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 contact us via the Contact Us link.
 

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.

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.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
 

Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by e-mail to the e-mail address specified in your account and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this privacy policy to check for any changes.
 

Contact Information
To ask questions or comment about this privacy policy and our privacy practices, contact via our Contact Us link.

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Notice at Collection (California Residents)
Effective January 1, 2023, the California Privacy Rights Act(“CPRA”) provides specific rights to California residents related to their “personal information,” as defined under the CPRA. CPRA provides you with certain rights with respect to this information. This section enumerates the CPRA required disclosures and details those rights under the CPRA.  Personal information does not include information that is publicly available, deidentified, or aggregated.
This section only applies to California residents. The rights discussed in this section do not extend to individuals who are not California residents.

Information We Collect
Throughout your interactions with Infusion Capital Group LLC, we collect various types of information about you.  In the past 12 months, we have collected the following categories of personal information about California residents who are website visitors, users, and businesses that access Services provided by or through Infusion Capital Group LLC:

 

• Category

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• Examples

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• Identifiers

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• First and last name, mailing address, Internet Protocol (IP) address, email address, social security number, driver’s license number, or other similar identifiers

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• Categories of information described in the California Customer Records Statute

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• First and last name, social security number, address, primary telephone number, job title, bank account number, or any other financial information

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• Commercial or transactions information

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• Products or services purchased, obtained, or considered

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• Sensory data

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• Audio or similar information

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• Internet or other electronic network activity information

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• Information about your internet connection, including IP address, geographical location, operating system, browser type, referral source, time and length of visit, button clicks and/or page views, and your mobile device identifier (IDFA or AAID)

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• Professional or employment-related information

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• Job title

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• Income

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We collect the information listed above from the following categories of sources: (i) information provided by you, (ii) information we collected when you use our Services, or (iii) information received from third parties.  We may use information we collect for purposes set forth above.

How Infusion Capital Group LLC Discloses Personal Information
Infusion Capital Group LLC may share your personal information with third party service providers to help us conduct the business purposes listed above, including, but not limited to, sharing with service providers to assist us in providing the Services. Our service providers are authorized to use your personal information only as necessary to provide their services to us. Additionally, Infusion Capital Group LLC may share your personal information: (i) as required by law; (ii) in connection with an audit or the sale of Infusion Capital Group LLC to a third party; or (iii) with your consent. We do not sell or otherwise share your personal information.

Your Rights Under the CPRA

Right to Know/Right to Access.  Under the CPRA, California residents have the right to request that Infusion Capital Group LLC disclose what information we have collected, used, disclosed, or sold over the past 12 months. Once we receive and confirm your verifiable consumer request for such information, (see “How You Can Exercise Your Rights Under CPRA”), we will disclose to you:

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1. The categories and specific pieces of personal information we collected about you over the past 12 months

2. The categories of sources from which such personal information has been collected over the past 12 months

3. The business or commercial purpose for collecting, disclosing or selling such personal information over the past 12 months

4. The categories of third parties with whom we shared your personal information over the past 12 months; and

5. If we disclosed your personal information for a business purpose, the personal information categories that each category of recipients obtained.

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Your Rights Under the CPRA

 

Right to Know/Right to Access

Under the CPRA, California residents have the right to request that we 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 (see “How You Can Exercise Your Rights Under CPRA”), we will delete your personal information from our records, and direct our service providers to do the same, unless an exception applies.

Right to Opt-Out of Sale of Sharing of Personal Information

Under the CPRA, California residents have the right to direct us to not sell your personal information (the “right to opt-out”). Infusion Capital Group LLC does not and will not sell or otherwise share personal information of consumers.

Right to Non-Discrimination

Under the CPRA, California residents have the right not to be discriminated against for having exercised the rights established by the CPRA. We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not:

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• Deny you goods or services

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

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

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

We may, however, offer you certain financial incentives permitted by the CPRA that can result in different prices, rates, or quality levels. Such financial incentives may include gift cards, credits, and other monetary offerings; additional details related to the material terms of these financial incentives will be provided to you at the time the incentive is presented to you. Any CPRA-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.

How You Can Exercise Your Rights Under CPRA

In order to exercise the right to know/right to access information and the right to request deletion, you or your authorized agent may submit a verifiable consumer request either by contacting us by phone at (718) 852-2233 with a brief description of your request. Please note that we may request additional information from you or your agent as needed to authenticate your request. You may only make a verifiable consumer request to know or request for access twice within a 12-month period.

The verifiable consumer request must do the following:

• Provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information or that you are an authorized representative.

• Describe your request with sufficient detail so that we can properly understand, evaluate, and respond to it.
If we are able to verify your request, we will make our best effort to respond within forty-five (45) days of our receipt of your request. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing.

We will not disclose information to you or delete information if we cannot verify your identity.

How California Residents Can Designate an Authorized Representative

Only you as a California resident, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request to know/request for access, request for deletion, or request to opt-out. To appoint an authorized representative to submit requests on your behalf, please provide us with written instructions stating the identity of the authorized representative and your authorization to have the representative act on your behalf by emailing us. We may also request additional information from you as needed to authenticate your request. If an authorized representative is acting on your behalf, your representative may contact us by phone at (718) 852-2233 with a brief description of your request.  Please note that we may request additional information from your representative as needed to authenticate your request.

Changes to Privacy Policy

By visiting the Sites or using our Services, you accept the practices described in this Privacy Policy. We may update this Privacy Policy from time to time by making available a revised, dated version on the Sites. If the revised version includes a substantial change, we will provide a more prominent notice (including, for certain services, an email or other type of notification of Privacy Policy changes) prior to the change becoming effective. Your continued use of the Sites shall constitute your acceptance of such updated Privacy Policy. We encourage you to periodically review this page for the latest information on our privacy practices.