PRIVACY POLICY

Valicor US LLC values and is fully committed to the protection of user privacy at all times. This Privacy Policy (this “Policy”) describes how Valicor US LLC (together with its subsidiaries and affiliates (collectively, “our Affiliates”), (“VUS”, “we”, “us” or “our”) gather and use personal information and data about individuals who access or use the Sites  (“user”, “users”, “you” and “your”) when users communicate with us or visit our websites that link to this Policy (collectively, the “Sites”); how we protect and share this information; and the rights users may have in relation to this information.  Please read this Policy carefully and consult our Terms and Conditions of Use (collectively, the “Terms”) for more information about the general terms and conditions regarding use of the Sites before accessing or using the Sites. If you do not accept and agree with this Policy then you must not access or use the Sites. All capitalized terms not defined in this Policy are as defined in the Terms.We reserve the right, in our sole and absolute discretion, to change this Policy at any time and from time to time and without prior notice upon our posting of the revised Policy, and use of the Sites following such revisions constitute acknowledgement and agreement to the revised Policy. If you don’t agree to any changes to this Policy, do not continue to access and use  the Sites.  We suggest you periodically review this Policy for changes because they are binding on you. The date of the latest version of this Policy will be identified at the bottom of this Policy.  To the extent that information and data that we collect could be considered health data, or another category of Personal Data (defined below), we ask for your explicit consent to process the data. When you access and use the Sites, you agree to this Policy and are deemed to provide your consent to our collection, storage, use and disclosure of Personal Data as described in this Policy. 
Information Users Provide to Us. We gather and collect Personal Data about individuals for purposes disclosed or otherwise known to them at the time they provide their information to us.  “Personal Data” means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.We may obtain and use the following types of Personal Data about individuals who use the Sites:

• Name
• Email address
• Postal address
• Telephone number
• Facsimile number
• Date of birth
• Social security number
• Driver’s license number
• Passport or other governmental identification number
• Other personal information

You covenant and agree that you are solely responsible for obtaining all required consents, authorizations and permissions from users and third parties and providing all required notifications to users and third parties (where applicable) to enable you to grant users access to the Service to collect Personal Data in connection with the use of the Sites. It is your sole and absolute responsibility to ensure that all such users and third parties are aware of and accept the terms of this Policy, and that you have obtained explicit and informed consent of users to our using their Personal Data in accordance with this Policy and the Agreement.
Information We Collect Automatically. We also collect certain information about users automatically when users access or use the Sites. We collect user IP address, user geolocation, user browser software type, user operating system, the pages users view on the Sites, the duration of user visit, the pages users visit immediately before and after users access the Sites, and the search terms users enter on the Sites. We collect this information using “cookies” and similar technological tools.  “Cookies” are small files that a website sends to a user’s computer or device while the user is viewing the website, or other technical methods to track visitor usage.
Information We Collect From Third-Parties.  As described in the Terms, our Sites may display, provide information regarding, or provide links to third party websites, content, applications, tools, services data, content or materials (collectively, “Third-Party Websites and Content”) and may facilitate communications between users and third parties regarding Third-Party Websites and Content. If a user decides to access and use Third-Party Websites and Content, our Terms and this Policy do not govern, the user’s Personal Data may be collected by those Third-Party Websites and Content and users should carefully read and review their privacy and data gathering policies practices. If a user decides to access and use Third-Party Websites and Content the user does so at the user’s sole risk. If we receive Personal Data from Third-Party Websites and Content, our use of information received from such a third party is governed by the Third-Party Website and Content’s privacy policy and practices and not this Policy.
How We Use Personal Data.  The Personal Data users provide us is based on the consent given when users access and use the Sites.  The Personal Data may be used in any of the following ways:

• To respond to contact requests and requests for information;
• To administer and provide users with access to and use of the Sites, and operating our business and running our daily business operations; 
• To manage our relationship with users and the organization users represent;
• To manage and provide support for the access and use of the Sites, and respond to user inquiries;
• To analyze, evaluate, personalize and improve the Sites and our business, and develop new products and services;
• To enforce compliance with the Terms and our policies;
• To investigate and protect against misuse, fraud or other unlawful activity, unauthorized access, disclosure, alteration or destruction, cybersecurity and other security threats, espionage, and enhance security for users of the Sites and our staff;
• To comply with applicable Laws, court orders, government and law enforcement agencies’ requests, and to address and resolve dispute and enforce the Terms, our other policies, and to exercise our legal rights and remedies;
• To provide users with notification about any changes to the Sites;
• To support the sale or transfer of all or a portion of our business or assets, including in connection with any bankruptcy or similar proceeding.

We may use information for any purpose if the information does not identify the user and cannot be combined with other information accessible to us to identify a user. 
Where We Transfer and Store Personal Data. The Sites are administered by us from our offices in the United States.  We engage companies that have worldwide locations that assist the operations of the Sites. Such companies may deliver products or services, improve the functionality of the Sites, collect information about users, communicate with users, or store information for us.  For example, they may be involved in providing website hosting, payment processing, web analytics, and data processing. In some cases, these service providers may need to access information about users for the efficient management of our business and for developing new products and services. In addition, we may share user information with our Affiliates or with our attorneys, banks, auditors or other service providers in connection with the purposes describe above in the section “How We Use Personal Data”. Accordingly, we or such entities may transfer user Personal Data from one country to another and maintain and process user Personal Data in countries other than the one in which it was collected including, at a minimum, the United States, member states of the European Union, the United Kingdom, Canada and other countries.  We will transfer user Personal Data consistent with applicable legal requirements.  Our service providers are obligated to follow our express instructions when processing Personal Data that users provide and are required to have in place appropriate technical and organizational security measures designed to safeguard user Personal Data. We do not permit them to use this information for their own commercial purposes other than in connection with their providing or assisting in providing of services for us.
How We Protect Personal Data. We will take reasonable steps to maintain appropriate technical and organizational security measures designed to protect user Personal Data provided to us against accidental or unlawful loss or unauthorized disclosure of, or access to the Personal Data provided to us. No set of safeguards is perfect or can anticipate all cyberattacks, however, and we do not guarantee the security of Personal Data.
Contacting Us. If there are questions about this Privacy Policy, or a user wishes to access, amend or delete any Personal Data we hold about the user, please email us at: contact@Valicor.us
How Long We Keep Personal Data. We will keep a user’s Personal Data for as long as we have a relationship with the user and for a period after our relationship with the user has ended including, without limitation, to fulfill the purposes for which the Personal Data is kept, to comply with our legal obligations, and to investigate or defend any potential legal claims where legal actions may be brought.
Last Updated: February 25, 2023
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