Last Updated: [date]  

ICaPath, Inc. (“ICaPath,” “we,” “our,” or “us”) values your privacy. This Privacy Policy (“Policy”) describes how ICaPath collects, uses, and discloses personal information we collect when you visit [Insert website URL] (the “Site”), and interact with the services available through our Site (collectively, the “Services”). 

By visiting the Site, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Services and any dispute over privacy, is subject to this Policy and our Terms of Use, available at [URL], including their applicable terms governing limitations on damages and the resolution of disputes.

Information We Collect About You

How We Use Your Information

How We Disclose Your Information

Cookies and Other Tracking Mechanisms

Your Choices

Children’s Information

External Links

Security

Changes to this Policy

Contact Us

Information We Collect About You

As further described below, we collect information directly from you, and automatically through your use of the Site and Services.

Information We Collect Directly From You

The information we collect directly from you depends on how you use our Services or otherwise interact or engage with us. The information we collect directly from you may include:

• Contact Information. If you contact us or otherwise communicate with us, including by email, or through our online web forms, we collect your name, email address, phone number, and other information you choose to provide. We also maintain a record of your contact details, communications, and our responses. 
• Preferences and Other Requests. We may collect information about your preferences, including communications preferences and other preferences you provide when interacting with us. 

Information We Collect Automatically

When you visit our Site, we and our service providers automatically collect certain information through cookies, java script, and other technologies. When you visit our Site, we automatically collect information including IP address, unique ID, access time, browser and device information, and general location information, such as your region. We also may collect information related to how you interact with the Services, such as page views, links and items clicked, referring URL, browsing history and other similar information. 

To the extent permitted by law, we may combine this information with other information that we have collected about you. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

How We Use Your Information

We collect, use, disclose and otherwise process the information we collect about you for the following purposes:

• Services and Support. To provide and operate our Services, communicate with you about your use of the Services, provide troubleshooting and technical support, respond to your inquiries, communicate with you about the Services, and for similar support purposes.
• Analytics and Improvement. To better understand how users access and use the Services, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our Services and business operations, to develop services and features, and for internal quality control and training purposes. 
• Marketing. For marketing purposes. For example, to send you information about our Services, such as newsletters and other marketing content, including information about ICaPath events, technologies, and new offerings, as well as any other information that you sign up to receive.
• Research and Surveys. To administer surveys and questionnaires, such as for market research or user satisfaction purposes.
• Security and Protection of Rights. To protect the Services and our business operations, and to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use. 
• Compliance and Legal Process. To comply with the law and our legal obligations, to respond to legal process and related to legal proceedings.  
• General Business and Operational Support. To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions. 

How We Disclose Your Information

We may disclose the information we collect for the purposes described above and as follows:  

• Affiliates. We may disclose information we collect about you to our affiliates.
• Vendors and Service Providers. We may disclose the information we collect to vendors and service providers who perform functions on our behalf, such as IT and website hosting, marketing and market research service providers, customer support, data storage, analysis and processing service providers, auditors, consultants and legal counsel.
• Marketing Partners and Analytics Providers. We may also disclose your personal information, such as name and contact information, to companies who provide marketing or analytics services on our behalf. For more information see the “Cookies and Other Tracking Mechanisms” section below.

We also may disclose your information in the following circumstances:

• In Support of Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may share or transfer the information we have collected from you with or to the other company. We may also disclose certain information as necessary prior to the completion of such a transaction or other corporate transaction such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.
• Compliance and Legal Obligations. We may disclose information to third parties to comply with our legal and compliance obligations and to respond to legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. 
• Security and Protection of Rights. We may disclose personal information where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property and safety of others. For example, we may disclose personal information to (i) prevent, detect, investigate and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety or legal rights of any person or third party, or (iii) enforce, detect, investigate and take action in response to violations of our Terms of Use. We may also disclose information, including personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
• Aggregate and Non-Identifiable Data. We may use and disclose aggregate and other data that is not personal information related to our business and the Services for quality control, analytics, research, development and other purposes.

Cookies and Other Tracking Mechanisms

We and our service providers use cookies and other tracking mechanisms to automatically collect information, including browsing activity, device and similar information within our Services. We use this information to, for example, analyze and understand how users access, use and interact with our Site, as well to identify and resolve bugs and errors in our Services and to assess secure, protect, optimize and improve the performance of our Services. 

Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within Service. To prevent cookies from tracking your activity on our Site, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Site who disable cookies will be able to browse the Site, but some features may not function.