Privacy Policy

This Privacy Policy (the "Policy") explains how CRE CLARITY, INC (dba Cardinal), a Delaware Corporation ("Company," "we," or "us") collects, stores, uses, and discloses personal information from our users ("you", "user") in connection with our service and website located at www.withcardinal.com including mobile or localized versions and related domains / sub-domains (the "Platform").

Please read and make sure you understand this Policy. If you do not agree with this Policy, the Addendum or our practices, you may not use our Platform or our services (the "Services"). This Policy and the Addendum may change from time to time and as an inseparable part, is incorporated into our Terms of Use. Your continued use of our Platform and Services constitutes your acceptance of those changes. We encourage you to review this Policy periodically.

In respect of Californian individuals, Company complies with the Senate Bill No. 1121 California Consumer Privacy Act of 2018 ("CCPA").

What does this Privacy Policy cover?

This Policy covers Company's treatment of information that Company gathers when you are accessing Company's Platform as a user and when you use Company's Services. Also, this Policy covers Company's treatment of your information that Company shares with Company's business partners. This Policy does not apply to the practices of third parties that Company does not own or control (such as third-party Platforms that you may access from the Platform), or to individuals that Company does not employ or manage.

What information does Company collect?

The information we gather from users enables the Company to personalize and improve our Services and to allow our users to set up accounts on the Platform. We collect the following types of information from our users and their customers:

2.1 Information You Provide to Us:

We receive and store any information you as our user enter on our Platform or provide to us in any other way. The types of information collected include, without limitation, your full name, email address, mailing address of billing party, phone number of billing party, password, contact information and content consumed on the Platform. Some of this information is not mandatory but may be necessary to use all of our functions.

In addition, we may collect the following financial data: account holder name, bank name, account number, currency of account. For taxation reasons, we may need to collect Tax ID (US: tin: SSIN/EIN), citizenship, country of residence. In some cases, we'll need to ask for a government ID, Green Card, or other proof of address or proof of residency status as regulated by taxation law.

2.2 Information Collected Automatically:

We receive and store certain types of information whenever you as our user interact with our Platform or Services. Company automatically receives and records information on our server logs from your browser including your IP address, unique device identifier, browser characteristics, domain and other system settings, search queries, device characteristics, operating system type, language preferences, referring URLs, actions taken on our Platform, page requested, content consumed (e.g., viewed, uploaded, and shared), dates and times of Platform visits, and other information associated with other files stored on your device.

2.3 Information we receive from you regarding your users and from third parties:

By providing our Services we receive and collect certain personal data on the customers of our users that is provided to us by third parties (e.g. Helpdesks, CRMs, Surveys, Email) and we also receive personal data for the purpose of processing directly from our users including, but not limited to the uploaded or shared personal data of our user's customers, like name, e-mail, phone number, address, gender, age or IP address.

3. What About Cookies?

We use a single, essential cookie to manage user authentication after login. This cookie is required to securely maintain your session and verify your identity as you use the application.

• Purpose: Authentication and secure session management.
• What it stores: A unique, internal user identifier (not your name or email address).
• Use of identifier: This identifier is used to associate your in-app actions (such as creating, editing, or deleting data) with your account for audit logging, security, and collaborative functionality.
• No tracking: We do not use cookies for advertising, analytics, or cross-site tracking.
• Opt-out: Disabling this cookie will prevent access to the app, as it is required for secure login and usage.

4. How Does Company Use My Information?

We may use your information, including your personal information, as follows:

We process the following personal data for the purpose and on the legal basis of the performance of the contract, product and service fulfillment:

• Full name
• Email address
• Phone number
• Mailing address
• Financial data: account holder name, bank name, credit card, account number, currency of account

The information you provide is used for purposes such as responding to your requests for certain products and services, customizing the content you see, communicating with you about specials, sales offers, and new features, and responding to problems with our Services. It is also used to fulfill and manage payments or requests for information, or to otherwise serve you, provide any requested services and administer contests.

We process the following personal information based on your consent (as the legal basis of this processing) for marketing purposes, newsletters, receipt messages, e-mails, and mobile messages. We may also send marketing communications and other information regarding services and promotions based on your consent:

• Full name
• Email address
• Phone number
• Mailing address

You shall always have the right to withdraw your consent at any time by cancelling your account.

We process personal data for the purpose and on the legal basis of compliance with legal obligations to prevent fraudulent transactions, monitor against theft and otherwise protect our customers and our business. We also process personal data for the purpose and on the legal basis of legal compliance and to assist law enforcement and respond to subpoenas.

This means that in some cases the data processing is stipulated by the applicable laws and we have an obligation to process and keep this data for the required time. This includes employment data, billing data, data which is necessary to assist law enforcement etc.

We process the following personal data for the purpose and on the legal basis of the legitimate interests of the Company, to improve the effectiveness of the Platform, our Services, and marketing efforts, to conduct research and analysis, including focus groups and surveys and to perform other business activities as needed, or as described elsewhere in this Policy:

• IP address
• Browser information
• Password
• Contact information
• Content consumed on the Platform
• Content contributed to the Platform
• Unique device identifier
• Browser characteristics
• Domain and other system settings
• Search queries
• Device characteristics
• Operating system type
• Language preferences
• Referring urls
• Actions taken on our Platform
• Page requested
• Content consumed (e.g., viewed, uploaded, and shared)
• Dates and times of Platform visits
• Other information associated with other files stored on your device

Where it is feasible, we anonymize personal data or use non-identifiable statistical data. We do not collect personal data in advance and store it for potential future purposes unless required or permitted by the applicable laws.

Data integrity and purpose limitation: Company will only collect and retain personal data which is relevant to the purposes for which the data is collected, and we will not use it in a way that is incompatible with such purposes unless such use has been subsequently authorized by you. We will take reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete and current. We may occasionally contact you to determine that your data is still accurate and current.

5. How Long We Retain Your Personal Data?

We will retain your personal data for so long as it is needed to fulfill the purposes outlined in this Policy or until you withdraw your consent, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no longer or no legal basis to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. Will Company share any of the information it receives?

Information about our users is an integral part of our business, and we may share such information with our affiliated entities. Except as expressly described below, we neither rent nor sell your information to other people or nonaffiliated companies unless we have your permission.

6.1 Third Party Service Providers:

List of Third Party Service Providers can be found here.

6.2 Company may release your information:

• in response to subpoenas, court orders or legal process, to the extent permitted and as restricted by law;
• when disclosure is required to maintain the security and integrity of the Platform, or to protect any user's security or the security of other persons, consistent with applicable laws;
• when disclosure is directed or consented to by the user who has input the personal information; or
• in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of its assets, your information will, in most instances, be part of the assets transferred.

6.3 Opt-In for Promotions:

We do not share personally identifiable information with other third-party organizations for their marketing or promotional use without your consent or except as part of a specific program or feature for which you will have the ability to opt-in.

6.4 With Your Consent:

Except as set forth above, you will be notified when your information may be shared with third parties and will have the option of preventing the sharing of this information.

6.5 Data retention and aggregated data processing

Please note that we may retain certain personal information after your account has been terminated. We reserve the right to use your information in any aggregated data collection after you have terminated your account, however we will ensure that the use of such information will not identify you personally.

7. Is information about me secure?

We take commercially reasonable measures to protect all collected information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Please understand that you can help keep your information secure by choosing and protecting your password appropriately, not sharing your password and preventing others from using your computer. Please understand that no security system is perfect and, as such, we cannot guarantee the security of the Platform, or that your information won't be intercepted while being transmitted to us. If we learn of a security systems breach, then we may either post a notice, or attempt to notify you by email and will take reasonable steps to remedy the breach.

8. Children's Privacy

Our Platform is not directed to children under 16 and we do not knowingly collect personal information from children under 16. If we learn that we have collected personal information of a child under 16 we will take steps to delete such information from our files as soon as possible. If you are aware of anyone under 16 using the Platform, please contact us at support@withcardinal.com.

9. Links to Third Party Sites and Services

This Platform may contain links to third party Platforms operated by individuals or companies unrelated to us. Please be aware that we are not responsible for the privacy practices of such third party Platforms and services. We provide links to these Platforms for your convenience only and you access them at your own risk. We recommend that you review the privacy policies and terms of use posted on and applicable to such third party Platforms prior to utilizing them.

10. Your Privacy Rights

10.1 Access and Retention:

We encourage you to contact us at support@withcardinal.com with your questions or concerns, or to request edits to your personal information, or to have it removed from our database. Requests to access, change or remove your personal data will be handled within 30 days.

11. Recourse, Enforcement and Liability

11.1

Company is committed to protecting your personal data as set forth in this Policy. If you think we are not in compliance with our Policy, or if you have any question or if you wish to take any other action concerning this Policy, contact us at support@withcardinal.com. You can also contact us at our mailing address: 5440 SW Westgate Drive, Suite 250, Portland OR 97221. We will investigate your complaint, take the appropriate action and report back to you within 30 days.

These recourse mechanisms are available at no cost to you. Damages may be awarded in accordance with the applicable law.

12. Modifications to this Policy

We will modify this Policy if our privacy practices change. We will notify you of such changes by posting the modified version on our Platform and indicating the date it was last modified, and, if the changes are significant, we will provide a more prominent notice (including by email in certain instances). The date this Policy was last modified is at the top of this page. Please periodically review this Policy so that you are familiar with the current Policy and aware of any changes.

13. For users in California

We will not share any personal data with third-parties for their direct marketing purposes to the extent prohibited by California Consumer Privacy Act of 2018 (CCPA). If our practices change, we will do so in accordance with applicable laws and will notify you in advance.

14. Questions

If you have any questions concerning this Policy or the Services, please contact us at support@withcardinal.com. You can also contact us at our mailing address: 5440 SW Westgate Drive, Suite 250, Portland OR 97221.