Factoreon

SECTION 1. INFORMATION WE COLLECT

Factoreon collects information you provide directly when registering for or using the Platform, including identity and contact information, account credentials, payment details processed through our payment processors, assessment and research data, and communications you send us. Factoreon also collects information automatically when you access the Platform, including usage data, device and technical data, log data, and data collected through cookies and similar technologies. Where you provide or generate data that constitutes Sensitive Personal Information under applicable law, including psychometric and research data, Factoreon collects such data solely upon your explicit consent. Factoreon may also receive information about you from third parties including Business Users, integration partners, and payment processors including Plaid, in each case consistent with applicable law.

SECTION 2. HOW WE USE YOUR INFORMATION

Factoreon uses the information it collects to provide, operate, maintain, and improve the Platform and Services; to process payments and manage subscriptions; to generate and deliver assessment, research, and analytical outputs; to authenticate users and maintain account security; to communicate with users regarding their accounts; to comply with legal and regulatory obligations; to enforce the Terms and Conditions; to detect and prevent fraudulent or unlawful activity; and to protect Factoreon's legal interests. Factoreon may also use de-identified and aggregated data for research, product development, and benchmark purposes. For users in the EEA and UK, Factoreon processes personal data on the legal bases of contract performance, legitimate interests, legal obligation, and explicit consent for sensitive data, as applicable under GDPR.

SECTION 3. SHARING OF INFORMATION

Factoreon does not sell, rent, or trade your Personal Information to any third party. Factoreon shares information solely as necessary to operate the Platform, including with third-party service providers acting under written agreements, and with legal or regulatory authorities where required by applicable law.

SECTION 4. DATA RETENTION

Factoreon retains information for as long as necessary to fulfill the purposes for which it was collected, to comply with legal and regulatory obligations, to resolve disputes, and to enforce its agreements. Retention periods are determined by Factoreon in its sole discretion. Factoreon reserves the right to retain any information for as long as required by applicable law or as necessary to protect its legal interests.

SECTION 5. YOUR PRIVACY RIGHTS

Depending on your jurisdiction, you may have certain rights regarding your Personal Information under applicable law, including under the California Consumer Privacy Act (CCPA/CPRA) and the General Data Protection Regulation (GDPR). These may include rights to access, correct, or delete your data, to opt out of certain uses of your data, and to lodge a complaint with a relevant supervisory authority. Factoreon will respond to verified requests as required by applicable law. To submit a request, contact privacy@factoreon.ai or use the in-platform form at www.factoreon.ai/privacy-request. Factoreon may verify your identity before processing any request and reserves the right to decline requests to the fullest extent permitted by applicable law. Factoreon will not discriminate against you solely for exercising a legally protected privacy right.

SECTION 6. SECURITY

Factoreon implements commercially reasonable security measures to protect information against unauthorized access, loss, or misuse. No security system is impenetrable and Factoreon does not guarantee absolute security. Factoreon will notify affected users of any data breach as required by applicable law.

SECTION 7. MINORS

The Platform is restricted solely to individuals eighteen (18) years of age or older. No person under the age of eighteen (18) is permitted to access or use the Platform in any capacity. Factoreon neither solicits nor knowingly collects Personal Information from any individual legally defined as a minor under applicable law. If Factoreon discovers or has reasonable cause to believe that data is being collected from or about any individual who constitutes a minor under applicable federal, state, or local law — regardless of the method or context of collection — Factoreon will take all measures it deems necessary to comply with applicable law, up to and including immediate revocation of the relevant user's access without notice or refund and deletion of all associated data. If you believe any minor's data has been submitted to the Platform, contact privacy@factoreon.ai immediately.

SECTION 8. CHANGES TO THIS POLICY

Factoreon reserves the right to update this Privacy Policy at any time in its sole discretion. Material changes will be communicated by email or in-platform notice. Continued use of the Platform following any update constitutes acceptance of the revised Policy.

SECTION 9. CONTACT