Culmen International, LLC Privacy Policy
Effective Date: 02/20/2024

A. Privacy Statement

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Your privacy is respected at Culmen International, LLC (“Culmen”, “we”, “our”, “us”). This Privacy Policy (“Privacy Policy”) describes the types of information, including Personal Data, that we gather from you when you use our websites (https://www.culmen.com/ and https://www.centrifuge.tech/try-it), apps (https://culmen.audit360.app/), and services (collectively, our “Service”), as well as your choices regarding use and disclosure of your Personal Data.

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As used in this Privacy Policy, “Personal Data” means information that identifies you or your household, directly or indirectly, by reference to identifiers such as your name, identification number, location data, online identifier, or one or more factors specific to your physical, physiological, genetic, mental, economic, cultural, commercial, professional, or social identity, or any other such data defined under applicable state law as “personal data.”

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By accessing our Service, you agree to be bound by this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use our Service. Each time you use our Service, the current version of the Privacy Policy will apply. Whenever you use our Service, you should check the data of this Privacy Policy and review any changes since the last version. This Privacy Policy is applicable to all Service visitors, registered users, and all other users of our Service.

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You acknowledge that this Privacy Policy is part of our Terms of Service, which is incorporated by reference, and by accessing or using our Service, you agree to be bound by the Terms of Service. If you do not agree to our Terms of Service, do not access or use our Service.

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If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.

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B. Personal Data Collected by Culmen

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When you use our Service, Culmen collects information that (i) you knowingly and voluntarily provide when you use our Service (such as through forms or profile screens), (ii) that we are able to collect based on your use (such as analytics details), and (iii) that we are able to collect using cookies and other similar technologies.

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1. Personal Data that you knowingly and willingly provide.

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Culmen collects the information that you knowingly and voluntarily provide when you use our Service (such as through web forms or profile screens), including account set up information, profile details, and payment information. You can choose not to provide us with certain Personal Data, but you may not be able to take advantage of our Service or other available features that we offer. We collect and use the following kinds of Personal Data:

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• First and Last Name

• Alias(es)

• Email Address

• Phone Number

• Professional and Employment Information

• Country of Residence

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We may also collect and store Personal Data about other people that you provide to us, as well as information about you provided by others. If you or other users use our Service to upload, share, and/or distribute content, and such content contains Personal Data about you or others, such information may be stored in order to allow for such uploading, sharing, and/or distribution. We may also receive your Personal Data from trusted third parties (including, for example, business partners, subcontractors in technical, payment, and delivery of membership services, advertising networks, analytics providers, search information providers, or credit reference agencies. For individuals in the European Union (EU), we will notify you when we receive such information about you from such third parties and the purposes for which we intend to use such information.

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    2. Personal Data that you knowingly and willingly provide.

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Culmen collects information that is sent to us automatically by your web browser. Culmen may use this information to generate aggregate statistics about visitors to our Service. This information typically includes details about your:

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• IP Address

• Browser Type

• Browser Plug-In Details

• Operating System

• Local Time Zone

• Date and Time of Each Visitor Request (e.g., web pages selected, and time spent on each page)

• Referring Site and/or Search Engine

• Device Type (e.g., desktop, laptop, tablet, phone, etc.)

• Screen Size, Color, Depth, and System Fonts

• Language Preference

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Culmen may use non-Personal Data for different business purposes, such as providing customer service, fraud prevention, market research, and improving our Service. The information we receive depends on the settings on your browser. Please check your browser settings if you want to learn what information your browser sends or how to change your settings.

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      3. Personal Data Collected by Cookies and Similar Technologies.

Culmen may obtain information about you by installing “cookies” on your computer’s hard drive. We use cookies to collect statistical information about the ways visitors use our Service including which pages they visit, which links they use, and how long they stay on each page. Culmen may also use cookies to create a database of your previous choices and preferences, saving you time and effort.

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If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. If you limit or disable the use of cookies when you visit Culmen’s Service, you may be unable to use the full functionality of our Service.

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We may also permit select third parties to use cookies to collect information about our Service visitors’ online activities across other websites or over time to assist us with advertising or analytics. The use of cookies by any third parties is not covered by our Privacy Policy, as we do not have access to or control over their cookies. Tracking data collected by these advertisers and third parties can be used to decide which advertisements you see on our Service, and on third-party sites and applications, but does not identify you personally and is not associated with your registration account.

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C. How is Your Personal Data Used?

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We will only process your Personal Data, including sharing it with third parties, where:

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• You have provided your consent, which can be withdrawn at any time;

• Processing is necessary for the performance of a contract to which you are a party;

• We are required by law;

• Processing is required to protect your vital interests or those of another person; or

• Processing is necessary for the purposes of our legitimate commercial interests, except where such interests are overridden by your rights and interests.

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We may use Personal Data we collect about you on its own or combine it with other information we have about you to:

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• Create user accounts and/or profiles through registration;

• Perform internal operations, such as tracking and improving the effectiveness of our website, mobile experience, and marketing efforts;

• Provide product and/or Service fulfillment, such as creating and maintaining accounts, managing purchases, payments, and more;

• Personalize user experiences, such as remembering your settings and preferences for things like language, font size, etc.;

• Provide information to our business partners or suppliers;

• Provide information to our representatives and/or advisors, such as our attorneys, accountants, and others to help us comply with legal, accounting, or security requirements; or

• Comply with legal requirements, such as in response to a subpoena or similar investigative demand.

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We may also disclose your Personal Data as otherwise set forth in this Privacy Policy, as permitted by law, or with your consent.

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D. Who Can Access the Personal Data We Collect?

We will only transfer your Personal Data to third parties who provide sufficient guarantees in respect of the technical and organizational security measures governing the processing to be carried out and who can demonstrate a commitment to compliance with those measures.

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Where third parties are processing Personal Data on our behalf, they will be required to agree, by contractual means or otherwise, to process the Personal Data in accordance with the applicable law and to act only on our instructions, or as permitted by law.

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Culmen may disclose your Personal Data to the following entities and for the listed purposes:

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1. Agents. We employ other companies and individuals to perform functions on our behalf. Examples of such functions include fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analyzing data, providing technical support, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, and providing customer service. We share our users’ Personal Data with agents as we deem necessary for such third parties to perform their functions.

2. Employees. Only authorized Culmen employees have access to your Personal Data.

3. Affiliates. When you are asked for information while on our Service, you are sharing that information with Culmen and our various affiliates, unless stated otherwise. As a result of this sharing, you may receive communications from any of our affiliates.

4. Authorized Business Partners. These include agents, contractors, vendors, licensors, resellers, system integrators, etc. Culmen, our affiliates, and our business partners may share Personal Data with each other and use it consistent with this Privacy Policy. Culmen and our authorized business partners may also combine Personal Data with other information to improve our products, the Service, content, and advertising.

5. Advertisers. Third-party advertisers and advertising platforms may also serve targeted advertisements as part of the Service. Please be aware that information practices of third-party advertisers or platforms collecting data on our Service are not covered by this Privacy Policy.

6. Authorized Business Partners, Advertisers, Agents, and Promotional Offers. We may enter into alliances, partnerships, or other business arrangements with third parties to share Personal Data for the purpose of providing you with information regarding products and services that we think may be of interest to you. We may also share your information with third-party partners for them to better target products and services to their customers.

7. Other Users. Please remember that any information you share in public areas of the Service, such as message boards or feedback sections, becomes public and anyone may take and use that information. Please be careful about what you expect to keep private. If your Personal Data is posted in any public areas of the Service, you may contact us through our customer service representatives to have such information removed.

8. To Comply with Legal Process, Protect Culmen, or Enforce our Rights. We may disclose your Personal Data when necessary to conform to legal requirements or comply with legal process; enforce or apply our conditions of use and other agreements; protect the rights, safety, or property of Culmen, our affiliates, service providers, our users or the public; or to prevent a crime or protect national security (including exchanging information with other companies and organizations for fraud protection and credit risk reduction).

9. As Part of a Merger or Sale of Business. We may disclose your Personal Data in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

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E. Your Rights Regarding Personal Data and Choices

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If any of the information that we have about you is incorrect, or you wish to have information (including Personal Data) removed from our records, please contact us at privacy@culmen.com. We will respond to such inquiries within thirty (30) business days.

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F. Rights for California Users

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1. Your California Privacy Rights. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits individuals with whom we have a business relationship who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make a request, please contact us at privacy@culmen.com.

2. Notice to California Residents

   • We will comply with your instructions to fulfill requests from individuals exercising their data protection rights under all applicable data protection laws. For users in the state of California, the California Consumer Privacy Act as amended by the California Privacy Rights Act (the “CCPA”) provides you the following rights:

     1. Right of Disclosure: you have the right to ask for disclosure of

        1. the categories of Personal Data that we collect about you;

        2. the categories of sources from which your Personal Data is collected;

        3. the business or commercial purpose for the collection, sale, or sharing of your Personal Data;

        4. the categories of third parties to whom we disclose your Personal Data; and

        5. copies of the specific pieces of your Personal Data that we collected about you during the prior twelve (12) months, or at your option, since January 1, 2022.

     2. Right of Correction: you have the right to ask us to correct Personal Data that you think is inaccurate.

     3. Right of Deletion: you have the right to ask us to delete your Personal Data in certain circumstances.

     4. Right to Opt-Out of the Sale of Your Data: you have the right, at any time, to direct us not to sell your Personal Data.

     5. Right to Opt-Out of the Sharing of Your Data: you have the right to opt out of having your Personal Data shared with others for cross-context or behavioral advertising purposes.

     6. Right to Restrict Certain Processing: you have the right to ask us to restrict the processing of your Sensitive Personal Data for any purpose other than the purposes permitted under the CCPA, or as disclosed at or before the time we originally collected it.

     7. Right to Withdraw Consent: you have the right to withdraw your consent at any time when we are processing your Personal Data based on consent. Note that this will not affect the lawfulness of the processing up to the point that consent is withdrawn.

   • Exercising Your Rights to Request Disclosure, Portability, Deletion, or Correction

     1. You may make a request for disclosure or portability up to twice in a twelve (12) month period. You may make a request for deletion or correction at any time.

     2. To make a request for the disclosure, portability, deletion, or correction of your Personal Data, contact us at privacy@culmen.com. We will ask for your information that allows us to reasonably verify your identity and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. We cannot respond to your request nor provide you with Personal Data if we cannot verify your identity and confirm that the Personal Data relates to you. We will acknowledge receipt of your request within ten (10) business days and will endeavor to respond within forty-five (45) days of receipt of your request, but if we require more time (up to an additional forty-five (45) days), we will notify you of our need for additional time. Any disclosure we provide will only cover the twelve (12) month period preceding receipt of your request, but you may request that we expand the twelve (12) month period to cover information collected since January 1, 2022, and we will honor that request unless doing so would involve a disproportionate effort.

   • Exercising Your Opt-Out Rights.

     1. To opt out of the sale of your Personal Data or the sharing of your Personal Data for cross-context behavioral marketing purposes, or to ask us to limit the processing of your Sensitive Personal Data, you may subject a request to us by clicking the following link: “Do Not Sell or Share My Personal Data” [insert link]. You may also email us at privacy@culmen.com.

     2. You may also opt out by activating a user-enabled global privacy control, such as a plug-in or privacy setting, device setting, or other mechanism that communicates or signals your choice to opt out of the sale or sharing of your Personal Data. When we receive such a signal, we will disable third-party analytics or advertising relating to that specific device through cookies to our advertising or analytics partners. This option does not stop all sales or sharing of your information because we cannot match your device’s identification or internet protocol address with your personally identifiable information like your name, phone number, email, or ZIP code. If you delete cookies from your browser, any prior do-not-share signal is also deleted, and you should make sure that your user-enabled setting is always activated.

     3. You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent if (a) the person is registered with the Secretary of State to do business in California, (b) you provide the authorized agent with signed, written permission to make the request, (c) you verify directly with us that you have authorized the person to make the request on your behalf, (d) you verify your own identity directly with us, and (e) your agent provides us with proof that they are so authorized.

   • Information Collected, Sources, Disclosures for Business Purposes, Sale, and Sharing of Data. During the past twelve (12) months, we collected the following categories of information about California residents, including employees, customers, vendors, and others. Not all information is collected about individuals. Information is collected directly from the individual, from third parties such as staffing partners or references, or by us for security or employee/vendor oversight purposes. During the past twelve (12) months, we may have disclosed the following categories of information about California residents for a business purpose, or sold or shared information to the following categories of third parties:

     1. Identifiers (such as name, alias, postal address, email address, phone number, fax number, account name, Social Security number, driver’s license number, passport number, unique personal identifier, and IP address). These are shared with service providers such as payment processors, employee benefits service providers, shipping partners, mail houses, marketing partners, legal and accounting partners, or affiliated companies; these may be shared with government regulators or law enforcement agencies upon legal request.

     2. Protected information (such as name with financial account, medical, health, and health insurance information, username, and password). These are shared with service providers such as payment processors, security partners, and employee benefits providers.

     3. Commercial information (such as transaction history, products/services purchased, obtained, or considered, and product preference). These are shared with affiliated companies for fulfillment purposes, service providers such as shipping partners, payment processors, mail houses, legal and accounting providers.

     4. Electronic network (browsing or search history, website interactions, advertisement interactions, activity using company computers, devices, or systems). These are shared with webhosting provider(s) and security providers; these may also be shared with law enforcement agencies upon legal request.

     5. Audio, video, or similar information (customer service calls, or security monitoring). These may be shared with security providers and with law enforcement agencies upon legal request.

     6. Geolocation data

     7. Professional, education, or employment related information. This is shared with employee benefits providers and staffing provider(s) and may be shared with government regulators or law enforcement agencies on legal request.

     8. “Sensitive Personal Information” (Social Security number, driver’s license number, state identification card, passport number, account log-in information, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership, genetic data, biometric information, health, sex life, or sexual orientation). The Sensitive Personal Information of employees, applicants, or vendors may be shared with benefits providers, staffing providers, legal and accounting providers, government regulators, or law enforcement agencies on legal request for legal compliance as permitted by the CCPA.

     9. Inferences from the above categories except Sensitive Personal Information (concerning preferences, characteristics, behavior, attitudes, abilities, etc.).

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G. Notice to Nevada Residents

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We do not transfer personal information for monetary consideration. If you would like to tell us not to sell your information in the future, please email us at privacy@culmen.com with your name, postal address, phone number, and email address with “Nevada do not sell” in the subject line.

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H. Notice to Colorado, Connecticut, Utah, and Virginia Residents

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We are currently not subject to the Colorado Privacy Act, Connecticut Personal Data Privacy Act, the Utah Consumer Privacy Act, or the Virgina Consumer Data Protection Act. If we become subject to any of these laws in the future, we will update this Privacy Policy accordingly.

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I. Rights for European Union Users

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Under the General Data Protection Regulation 2016/679, you have the right to ask us not to process your Personal Data for marketing purposes. We will usually inform you (before collecting your Personal Data) if we intend to use your Personal Data for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your Personal Data. You can also exercise the right by contacting us using the Contact Us section of our Service.

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1. In certain circumstances, you have the rights to:

   1. Request access to any Personal Data we hold about you (“Subject Access Request”) as well as related information, including the recipients or categories of recipients to whom the Personal Data has been shared;

   2. Obtain without undue delay the completion of any incomplete Personal Data or the rectification of any inaccurate Personal Data we hold about you;

   3. Request Personal Data held about you to be deleted provided the Personal Data is not required by Culmen for compliance with a legal obligation under European or Member State law or for the establishment, exercise, or defense of a legal claim;

   4. Prevent or restrict processing of your Personal Data, except to the extent processing is required for the establishment, exercise, or defense of legal claims; and

   5. Request transfer of Personal Data directly to a third party where this is technically feasible.

2. In addition, where you believe that Culmen has not complied with its obligations under this Privacy Policy or European law, you have the right to make a complaint to an EU Data Protection Authority.

3. You can exercise any of these rights by contacting us using the Contact Us section on our Service.

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J. International Users

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We are headquartered in the United States. Your Personal Data may be accessed by us or transferred to us in the United States or to our affiliates, partners, merchants, or service providers who are located worldwide. If you are visiting our Service from outside the United States, be aware that your information may be transferred to, stored, and processed in the United States where our servers are located, and our central database is operated. By using our Service, you consent to any transfer of this information.

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We will protect the privacy and security of Personal Data according to this privacy statement, regardless of where it is processed or stored; however, you explicitly acknowledge and consent to the fact that Personal Data stored or processed in the United States will be subject to the laws of the United States, including the ability of governments, courts of law, or enforcement or regulatory agencies of the United States to obtain disclosure of your Personal Data.

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K. Security

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We maintain reasonable industry security measures to safeguard against loss, theft, interference, and misuse, as well as unauthorized access, disclosure, alteration, or destruction of your Personal Data. We also maintain procedures to help secure online sessions and to protect Culmen accounts and systems. This approach helps secure online sessions and to protect Culmen accounts and systems. This approach helps ensure that information remains safe and private, however, you should understand that no data storage system or transmission of data over the internet or any other public network can be guaranteed to be 100% secure, accurate, complete, or current.

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L. Storage and Retention

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The Personal Data that you provide us is generally stored on servers located in the United States. If you are located in another jurisdiction, you should be aware that once your Personal Data is submitted through our Service, it will be transferred to our service in the United States and that the United States currently does not have uniform data protection laws in place.

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Culmen will retain your Personal Data for as long as needed to provide you with the Service. If you wish to request that we no longer use your Personal Data to provide you with the Service, you may contact us at privacy@culmen.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

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[We retain information that certain users provide in connection with requests made under the CCPA for a period of two (2) years.]

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M. Site-Specific and Additional Terms

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1. Do Not Track Policy. Except as otherwise provided in this Privacy Policy, we use technology that recognizes a do-not-track signal from your web browser. [This technology allows us to exclude you from any analytics that collect information about your online activities over time and across third-party websites.]

2. Marketing. By consenting to this Privacy Policy, you agree to receive marketing materials from us. If Personal Data is collected by us for marketing purposes, we will usually inform you before collecting your data or sharing it for third party purposes. You can prevent the processing of your Personal Data for these purposes by checking certain boxes on the forms we used to collect your personal data. Additionally, if you prefer not to receive marketing messages from us, please let us know by clicking on the unsubscribe link within any marketing message that you receive, or by sending a message to us at privacy@culmen.com.

3. Links to Third Party Services. Our Service may contain links to third-party websites, applications, and services not operated by us. These links are provided as a service and do not imply any endorsement by Culmen of the activities or content of these sites, applications, or services nor any association with their operators. Culmen is not responsible for the privacy policies or practices of any third party including websites or services directly linked to our Service. You should review any such linked site’s privacy policies before submitting any of your personal information to such third parties, as we are not responsible for and have no control over information that is submitted to, or collected by, these third-party sites.

4. Minors and Children’s Privacy. Our Service is not designed for or intended to be used by children under the age of 16, nor do we knowingly collect or receive Personal Data of children under 16. If you are not 16 years or older, do not use our Service, including any sites or pages which are integrated into our services, at any time or in any manner. If we learn that Personal Data of persons less than 16 years-of-age has been collected through our Service, we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child or a minor under the age of 13 has posted, submitted, or otherwise communicated Personal Data to our Service without your consent, then you may alert us at privacy@culmen.com so that we may take appropriate action to remove the minor's Personal Data from our systems.

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N. Changes to this Privacy Policy

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We reserve the right to update or modify this Privacy Policy from time to time. If we make any material changes to this Privacy Policy or the way we use, disclose, or collect Personal Data, we will notify you by revising the “Effective Date” at the top of this Privacy Policy, prominently posting an announcement of the changes on our Service, or sending an email to the email address you most recently provided us (unless we do not have such an email address) prior to the new policy taking effect. Users are bound by any changes to the Privacy Policy when they use our Service after notice of such changes has been communicated. We encourage you to review this Privacy Policy regularly to ensure that you are familiar with Culmen’s current practices.

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O. Privacy Inquiries

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If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us as follows:

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• By emailing the Privacy Department at privacy@culmen.com

• By mail post to:

  Privacy Department
  Culmen International, LLC
  99 Canal Center Plaza, Suite 125
  Alexandria, VA 22314

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For the purposes of the General Data Protection Regulation 2016/679 (the “GDPR”), the Data Controller is Culmen International, LLC registered in the United States with a registered address at 99 Canal Center Plaza, Suite 125 Alexandria, VA 22314.

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• Our nominated representative for the purposes of the GDPR is Diane Cooper.

• Our Data Protection Office is Diane Cooper who can be contacted by sending an email to diane.cooper@culmen.com or by post to:

  Privacy Department
  Culmen International, LLC
  99 Canal Center Plaza, Suite 125
  Alexandria, VA 22314