Privacy Policy

Last updated: July 21, 2025

The Data Company Technologies Inc. (D/B/A Nimble) (“Nimble”, “Company”, “we” or “us”) respects your right to privacy and is committed to protecting it. This privacy policy (“Privacy Policy”) is designed to explain to you, how we process and treat personal data.

1. Scope and applicability

• 1.1. What is covered by this Privacy Policy?
  This Privacy Policy applies only to data processing activities for which Nimble acts as a Data Controller, as defined under applicable data protection regulations. This means the following data subjects: (1) Visitors to our websites that link to this Privacy Policy (“Visitor” and “Website”, respectively). This category may include candidates that submitted their job application via the Website; (2) and/or a business customer, a business partner that has a contractual relationship with us, or a prospective customer that is yet to be engaged in a contract with us (“Customer”); and/or (3) Customers using our software, application, API and related Services (“User”); (4) and/or Members of our network that are engaged in a business collaboration with us (“Partners”); and/or Unless explicitly mentioned otherwise, the information in this Privacy Policy refers to all the above data subject types (“you” or “your’).
• 1.2. What is not covered by this Privacy Policy?
  This Privacy Policy does not cover any Personal Data that is collected or otherwise processed by our Customers or Partners, i.e., any data processing activities with regard to which we serve as a Data Processor, as the term is defined by the EU GDPR.
• 1.3. Is Nimble Controller or Processor?
  When providing the Services, Nimble serves as a Data Processor, and the controllers are the Partners on one hand and the Customers on the other. With respect to the API Application and Website, Nimble is a Data Controller. For the purpose of this policy, the “Service(s)” shall include any software licensed by us, application, API, SDK, platforms, or related services provided through such software or by utilizing it. This should include updates, enhancements, new features, support or communication.
• 1.4. Special jurisdictions and data protection regulations
  The Privacy Policy was designed with global standards and principles of transparency and choice in mind and is meant to include the main requirements established by the prominent global regulations, such as the EU and the UK GDPR and the CCPA and CPRA. If you are a resident of California, please refer to our CCPA Statement, in addition to this Privacy Policy.
• 1.5. Data Protection Officer and Contact Options
  • • If you have any requests regarding the data collected under this Privacy Policy, including but not limited to requests to remove, delete, amend, modify or transfer personal data processed about you, please contact us at: privacy@nimbleway.com.
    Please include sufficient details about your inquiry or request, in order to allow us to verify your request and address it.
  • • If you have questions, comments or complaints regarding the Privacy Policy or data practices, please contact us directly at: privacy@nimbleway.com.

2. Changes, updates and modifications

We are obliged, and reserve the right to modify this Privacy Policy at any time, to reflect updates to the Services, API Application, Websites or to reflect an applicable regulatory requirement. Such changes will be effective immediately upon the display of the revised Privacy Policy, or its delivery to you by email if that is a form of agreed communication between us. The last revision date will be reflected in the “Last Updated” heading. If we make material changes to this Privacy Policy, we will make our best efforts to notify you, by email or by means of a notice on our Website.

3. Personal Data we process

• 3.1. Type of data.
  Depending on your interaction with us, meaning, if you are a Visitor who just browsing our Website, or if you are a User who maintains an account with our Services, a business Partner or Customer, we may collect one of two types of information about you, your device or your chosen activities with us:
  
  • • Non-Personal Information/Data: The first type of information is non-personal and non-identifiable information that cannot personally identify or lead to identifying a natural person. For example, statistics or aggregated information, or any other type of data that can no longer be attributed to you. Non-Personal Information which is processed may include aggregated usage information and technical information transmitted, such as (but not limited to): the type of operating systems, type of browsers, language preferences, and approximate geo-location (country level).
  • • Personal Information/Data: The second type of information is information that identifies you as a natural person, or that may be used, either alone or in combination with other information, to personally identify you as a natural person. Such information may include, for example, a first and last name, an email address, phone number, a home or other physical address, and other contact information. In addition, in some jurisdictions (such as the EU for example), and given the specific use we make with the information, an IP address, device ID and cookies are considered Personal Information as well (“Personal Information”). The table below details the Personal Information processed by us.
• You are not obliged by law to provide us with any information. You can always avoid providing us with certain Personal Information, and if you gave your consent to process certain Personal Information, you cannot always ask to withdraw such consent. However, you acknowledge that it may prevent us from providing certain Services.
• 3.2. Personal Data of Visitors of the Website
  • a. Contact details: if you contact us for support, feedback or other inquiries, requests, or questions either through an online form available on the Website, by sending us an email or by other means of communication we make available (such as submitting a bug report or filling in a survey) you will be requested to provide us with your name, your email address, and the subject matter of your inquiry.
  • If you want to become a business Partner or Customer through our Website, you will be asked to provide us with your full name, business email address, company, website URL, phone number and country. We will use this information for our legitimate interest and for the purpose of responding to your inquiries and providing you with the support or information you have requested. We retain such information for as long as needed to provide you with the inquiry requested or as required under applicable law.
  • b. Subscription: If you voluntarily subscribe to our beta programs, our newsletter, blog, email communications or other service offerings, you will be asked to provide us with your email address. You can unsubscribe at any time using the unsubscribe option within the body of the email sent to you or rather by contacting us directly at: privacy@nimbleway.com.
    We will use your email address in order to send you information related to our Services, our beta program or the subject matter regarding which you reached out to us or submitted your email address.
  • c. Online Identifiers: We process IP addresses, cookies, pixel tags and a user agent (namely, your browser’s type, version, language, and country).
  • We may either directly or indirectly collect our Visitors’ Online Identifiers. Such processing is subject to your consent which is obtained through the cookie notice displayed on our Website in which you can accept, decline or set your preference. Necessary cookies will be used as part of our legitimate interest and for purposes of the Website’s functionality.
  • In certain cases, and upon your consent, third-party cookies and tags will be used for advertising, marketing and retargeting purposes of the site or Services.Device Information: we may collect certain information about the device from which you access the Website or Services, such as type (mobile/desktop).
  • e. Online activity: We also collect certain technical information which relates to your use of the Website such as your clicks, type of browser, time and date. We use this technical data in order to operate and manage the Website.
  • f. Job Application: In the event that you are interested in joining our team, and wish to submit your CV, you will be required to provide us with your name, email address, phone number and your CV file. Options to submit links to your website or LinkedIn profile are also available.
  • Your provision of personal information in connection with recruiting is voluntary, and you determine the extent of information you provide us. We do not request or require sensitive personal information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. We will use the information you have provided solely to communicate with you, manage our recruiting and hiring processes, and comply with corporate governance and legal and regulatory requirements. If you are hired, the information may be used in connection with employment and corporate management. Please note that we use trusted third-party platforms, including Comeet and HiBob, to support our recruiting and HR processes. These platforms may process your personal information on our behalf, solely for the purposes described above and subject to contractual obligations regarding confidentiality and data protection.

3. Personal Data of Customers, Users and Partners

In addition to the Visitor information described above, the following may be processed about Users or Customers:

• a. Work contact details. If you are a Customer or a prospective one, we may retain your full name, contact details and work information (such as role, title and company) for purposes of communicating with you, and at times, for the preparation of a contract and a Customer account maintenance.
• b. Authentication and authorization. If you are an approved Customer you will receive access to our API Application or any other portal through which you can manage the Services and your account. For authentication purposes, you will have to set up your own password. Your work email address is used as your username.
• In addition, you can choose to use your Google account for authentication purposes, in which case, the only retained data will be the authentication token provided by Google (you can read more in Google’s privacy policy).
• For safety reasons, authentication and authorization data will be processed and retained by a third party, JWT (by Auth0), which their privacy policy and information security details can be found here. You thereby represent and warrant that you are responsible for maintaining the confidentiality of your details and password. You represent and warrant that you will not provide us with inaccurate, misleading or false information.
• c. Account information. When you open an account with us, to access the API Application and/or the Services, you will be requested to provide us with certain information such as your full name, email address and any other information you choose to make available in your user account.
• d. Analytics and Dashboard. The Services include a dashboard via which you can track and manage your activity with the Services. This information is presented in a statistics manner, based on the activity logs’ aggregation.
• e. Usage data. In order to provide the Services, operation, maintenance and improvement of the Services, so as to monitor, screen and protect against abusive use of the Servies, we will process an online activity log, metadata of your activities via the Services (such as timestamps, target and origin IP addresses, (root)domain and geo-information), and metadata that is otherwise required, such as segment, country, length, size of data packets.

4. How we collect or process Personal Data

Depending on the nature of your interaction with us and the Services, we may collect information as follows:

• 1. Automatically – When Visitor or Users use or access the Services. we may use Cookies, tags or log files, as described in this Privacy Policy, to gather some information automatically. This processing may be done directly by us or by our third-party Partners, such as Google Analytics for analytics purposes.
• 2. Provided by you directly – we will collect information if and when you choose to provide us with the information, such as through a registration process, form submission, authentication, contact us communications, payment process, etc.
• 3. Publicly available or received by third parties. If you are a Customer (or a prospective one), we might use information manifestly made publicly available by you to contact you, at times, received by third-party service providers such as Sopro, which privacy policy is available at: https://sopro.io/legal/#privacy-policy, or Belkins, which privacy policy is available at https://belkins.io/legal/privacy-policy. 

5. Lawful basis for processing

In addition to the lawful basis explained respectively to each data processing activity above, we would like to explain the general lawful bases for processing your personal data (as defined under the General Data Protection Regulations “GDPR”):

• 1. When Visitors access our Website, we collect certain online identifiers for purposes of Website and services functionalities, and at times, for purposes of advertising and marketing our Services; such online identifiers are processed subject to the Visitors’ consent to our Cookie Notice, otherwise, we will process data only under legitimate interest basis.; We will process necessary cookies regardless of a Visitor active consent, as part of our legitimate interest and Website’s functionality necessities.
• 2. When a Visitor or a User signs up for our Services and opens an account with our API Application or other Services, we process personal data associated with such account management and protection. In which case, we will do so based on the User’s or Visitor’s consent, given at the point of account registration and based on contract with you. We will also use the email address for purposes of updates, notification and information regarding the Services based on consent, or, our legitimate interest as the case may be.
• 3. Upon consent or legitimate interest, as the case may be, we will use certain contact information for purposes of direct marketing.
• 4. If you are a Customer, we will process your personal data to fulfill our contractual agreement, or, to prepare for such, including, reaching out to you as a potential Customer for purposes of offering our Services and negotiating terms and conditions with you. This would be based on our legitimate business interest, and later, contract-based.
• 5. In certain cases, we may have to process personal data to prepare for a legal claim, or as otherwise be required by applicable laws, including data retention for demonstrating compliance with regulatory requirements.

In any other case, we will also process your personal data where you have provided us with consent to do so, or, where we have a legitimate interest and are not overridden by your data protection interests or fundamental rights and freedoms, such as when we use the data in order to provide the Services, or when used for anti-fraud purposes.

6. Cookies and web technologies

• 1. When you access or use the Website, or interact with any digital aspect of the Services, we may use cookies, tags, pixels (or similar technologies), which store certain information on your device (i.e., locally stored) and which allow web functionalities to be adaptive to your use.
• 2. A Cookie is a small piece of a file that a website assigns and stores on your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes such as allowing you to navigate between pages efficiently and making the interaction between you and our Services quicker and easier.
• 3. We may permit third parties to use cookies or similar technology to collect information about your online and application usage activities across our Services, this data may include Online Identifiers, therefore we recommend you review our cookie policy carefully.
• 4. We may link this automatically-collected data to other information we collect about you. We may also combine this automatically-collected log information with other information we collect about the Services we offer you. Further, we may use the information collected through the cookies for marketing and promotional service therefore we recommend you review the cookie policy and manage your preference through our cookie manager.

7. Retention of Data

• 1. Generally followed by retention principles. As a general rule, we strive to follow the following retention principles, wherever possible or allowed:
  • • Storage Limitation, meaning we retain Personal Data for no longer than necessary to achieve the purpose for which it was originally processed/or collected.
  • • Local storage accessing vs. server transfers.
  • • If the retained data pose any long-term risk to individuals’ privacy we may use pseudonymization forms, or designed our retention structure in a decentralized manner.
  • • We delete Personal Data that is no longer necessary, or that is subject to an executable and verifiable erasure request by the data subject.
  • • We use secure hosting, processing and securing vendors which specialize in data protection and information security.
• 2. Visitors. Retention of cookies and online identifiers varies between the type, purpose and entity that use the cookie. Unless we do not need the information for fraud investigation, detection or prevention, the retention period of each cookie will be available for review in our Cookie Policy.
• 3. Users. We retain your Personal Data as long as you maintain the account (and respective engagement) with us. In some cases, and subject to local applicable legislation, we may have to retain some information for a longer period.
• 4. Customers and Partners. We retain your Personal Data for as long as you didn’t ask us to delete such data, via third-party CRM vendors.

8. Third-Parties

• 1. As a Data Processor, we may serve a third party in an engagement between data subjects and Data Controllers. In which case, the latter will make a notice in their Privacy Policy about our role and the data they may share with us.
• 2. As a Data Controller, we use it as a principle, to share Personal Data only as required to operate, maintain, provide and secure the Services. Below you can find the categories of third parties with whom we share Personal Data (whether directly, or using them to process Personal Data as part of a service they render to us). If you are a resident of Canada, California, the UK, the EU or the EEA, you may also reach out with a direct request to learn more about the third parties who process your Personal Data on the virtue of providing us their services.
• a. Service providers: we may share your information with third parties that perform services on our behalf, such as storage, host, features providers, payment processors, analytics services, servers, service functionality, customer support, marketing and advertising. These third parties may be located in different jurisdictions; We require each to maintain adequate measures of information and privacy protection as required by applicable law. Examples:
  • • Cloud hosts
  • • Analytics tools
  • • Authentication and authorization vendors
  • • Consultants and advisors
  • • Marketing and advertising services
  • • Recruiting and HR management platforms (e.g., Comeet for recruitment workflows, and HiBob for employee lifecycle and HR data management)
  • • These platforms process personal data strictly on our behalf and under contractual safeguards aligned with applicable privacy requirements.
• b. Business Partners who combine their technological features with us may have access to certain Personal Information about your usage, as collected from you. In these cases, you will always be able to check their privacy policies before using the combined services.
• c. Our affiliated companies. We may disclose Personal Information to any current or future affiliated company, parent companies, or subsidiaries to process for the purposes described in this Policy. Affiliated companies are companies controlling, controlled by, or under common control with us.
• d. Legal Disclosure, Policy Enforcement, Third Party Rights: We reserve the right to disclose your personal information if required by law and/or to comply with a court order or similar legal process or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
• e. Business Transitions: if we become involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

9. Security

• 1. We implement organizational and technical measures to protect the Personal Data of Visitors, Users, Customers, and Partners, both in transit and at rest. We also adhere to the principles of data minimization and storage limitation, in line with industry best practices and applicable regulations.
• 2. We periodically review our data handling practices to ensure continuous monitoring and protection. We use trusted third-party processing and hosting providers that comply with recognized information security standards, and we apply strict internal access controls to limit data exposure to authorized personnel only.
• 3. While our systems and procedures are designed to reduce the risk of security breaches, no system is entirely immune. Therefore, we cannot guarantee that our Website, servers, or Services are fully protected against unauthorized access or other security risks inherent to internet-based operations.
• 4. As part of our commitment to security and transparency, Nimble has successfully completed a SOC 2 Type 2 audit, conducted by an independent third-party auditor. This audit assessed the effectiveness of our internal controls over a defined period, based on the Trust Services Criteria developed by the American Institute of Certified Public Accountants (AICPA). The SOC 2 Type 2 report provides assurance that our systems are designed and operated effectively to safeguard customer data. Our SOC 2 report is available to enterprise customers under NDA. For access, please contact: security@nimbleway.com. 
  

If you have any questions about the security of the Site or Services, please contact us at support@nimbleway.com

10. Data Transfers

• 1. We may store or process Personal Information in a cloud or on servers based in the United States and/or Canada or other countries, as operation of the Services may require. If you visit our Website or use our Services from locations outside these regions, please note that any information you provide to us through your use of our Website or Services may be transferred to and processed in countries other than the country from which you accessed our Website or Services.
• 2. We will take the necessary steps to ensure that international transfers of Personal Information meet all requirements under applicable data protection laws. When Personal Data collected within the European Economic Area (“EEA”) is transferred outside these jurisdictions, we will take the steps necessary to ensure that the transfer of such data provides sufficient safeguards, and you may exercise your rights, where applicable, to receive information on such transfer mechanisms.
• 3. Personal Information transferred outside the EEA is transferred for processing by AWS on its servers in the United States, and among the Company’s affiliates, in both cases pursuant to standard contractual clauses published by the European Union in June 2021, and any standard agreed-upon solution post Schrems II.
• 4. If you would like to understand more about these arrangements and your rights
  in connection therewith, please contact our Data Protection Officer at: privacy@nimbleway.com.

11. Data Subjects Rights

• 1. If you are a resident of California (or the USA in general), the relevant section in our CCPA Statement applies to you.
• 2. If you are a resident of the EU, EEA or the UK, the following applies to you: Individuals have the following rights, when we are the Data Controller of their data, as per this privacy policy. Otherwise, for cases we are the Data Processor, please seek to exercise your privacy rights directly with your data controller.
  • a. Right of access: You may ask us to access any Personal Data held about you.
  • b. Right to rectification: You have the right to ask us to correct the information we hold about you. This option will be available to Users via their account settings.
  • c. Right to erasure: You may ask us to delete your information or to stop using it. We can only do this when possible, and as allowed by applicable laws. Sometimes we need your information to complete a transaction based on an action you made, comply with the law (such as tax laws) or simply provide you with the Services.
  • d. Right to the restriction of processing: You may ask us to temporarily cease the processing of your Personal Data, or, for a specific purpose or function. Please note that this too might cause us to not be able to provide you with the Products and Services or part thereof.
  • e. Objection to processing: You may request us to stop processing your Personal Data. Similar exceptions as mentioned above will apply to such a case as well.
  • f. Right to data portability: You may contact us to request an export of your Personal Data in a reusable format, or to directly transfer such data to another vendor offering related services.
  • g. Right to withdraw consent: Where you have given us your consent to use your information for a specific purpose, you may, at any time, decide to withdraw your consent and we will then stop using your information for that purpose, under the exceptions listed above.
  • h. Right to lodge a complaint: If You live in a country where the EU or UK GDPR applies (e.g. the EU, EEA or UK), you may lodge a complaint with the authority responsible for protecting Personal Data in your country of residence, if you believe that your rights have not been respected by us. In such a case, you are welcome to reach out to us first so we will be able to help you with such a matter, at dpa@nimbleway.com.
• 3. Exercising your rights. For more information about your rights regarding your privacy, and in order to exercise your choices and controls in connection with our treatment of your Personal Information, please reach out by email for more information or requests regarding your Personal Information, at privacy@nimbleway.com. 
• If we are unable to provide you with the information you asked for, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor’s authority.
• Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

12. Children

If you are under 16 years of age, you are not permitted to use this Website or our Services. If you are a minor, or a parent of a minor, who has a good reason to believe that we process the Personal Information of a Minor as a Data Controller, or a Data Processor, please reach out to us with the necessary verification information so we will take an action to immediately resolve and remove any such information from our systems.

13. Contact

For questions and inquiries, you can reach out ot us by email at: info@nimbleway.com.

California Notice (CCPA and CPRA)

Last Updated: July 21, 2025

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This privacy notice for California residents supplements the information contained in the Privacy Policy (the “Policy”) of The Data Company Technologies Inc. (D/B/A Nimble) and (“Nimble”, “we” or the “Company”) and applies to our Visitors, Users, Customers and Partners residing in the State of California (“you”).

We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”) and other applicable California privacy laws. Any terms defined in the CCPA or CPRA,  have the same meaning when used in this notice.

This statement refers to the information collected, either automatically or as submitted by you, when you access, use or visit our Website, consume the Services, are an end-user of one of our Partners, or otherwise engage with us

1. Categories of Personal Information collected about you

As described in our general Privacy Policy.

2. Sharing Information

• a. We do not sell your Personal Information or share it for monetary gain. We also do not share your Personal Information for cross-context behavioral advertising, as defined under the CPRA. We may disclose your Personal Information to a third party for legitimate business purposes. When we do so, we enter into contracts that describe the purpose and require the recipient to both keep that personal information confidential and not use it for any purpose except for performing the contract.
• b. In the preceding twelve (12) months, we have shared the following categories of personal information for a business purpose:

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3. Your Rights

The California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), provides California residents with specific rights regarding their personal information. Below we describe your privacy rights under California law and explain how to exercise them.

• 3.1. Access to Certain Information and Data Portability Rights
  You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and verify your request, we will disclose:
  • • The categories of personal information we collected about you;
  • • The categories of sources for the personal information;
  • • The business or commercial purpose for collecting or sharing that personal information;
  • • The categories of third parties with whom we disclose that personal information;
  • • The specific pieces of personal information we collected about you (also called a data portability request);
  • • If we sold or disclosed your personal information for a business purpose.
  • • The categories of personal information we disclosed for a business purpose.
  • • You also have the right to request correction of inaccurate personal information we maintain about you.
• 3.2. Deletion Request Rights
• You have the right to request that we delete personal information we collected and retained about you, subject to certain exceptions. When applicable, once we receive and verify your  request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
• We may deny your deletion request if retaining the information is necessary for us or our service providers to:
  • • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with a customer/you;
  • • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • • Debug products to identify and repair errors that impair existing intended functionality;
  • • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  • • Comply with the California Electronic Communications Privacy Act (CalOPPA);
  • • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
  • • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
  • • Comply with a legal obligation;
  • • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
• 3.3. Right to Opt Out of Sale or Sharing of Personal Information
• You have the right to opt out of the sale or sharing of your personal information with third parties for cross-context behavioral advertising.
  We do not sell or share your personal information as defined under California law. If that changes in the future, we will provide you with notice and the ability to opt out.
• 3.4. Exercising your rights and choices
• To exercise your access, correction, data portability, deletion, or other rights described above, please submit a verifiable request to privacy@nimbleway.com or via your account, if you are a business customer.
  • • Only you or someone legally authorized to act on your behalf may make a verifiable request.
  • • You may also submit a request on behalf of your minor child.
  • • You may make a request up to twice within a 12-month period.
  • • The request must include sufficient information to verify your identity and describe your request in detail.
  • • We will only use the information in the request to verify your identity or authority and process the request.
• 3.5. Response Timing and Format
• We aim to respond within 45 days of receiving a verifiable request. If more time is needed (up to 90 days), we will notify you of the reason and extension.
  • • If you don’t have an account, we will respond via email.
  • • Our response will cover the 12-month period preceding your request.
  • • For data portability requests, we will provide your data in a readily usable format.
  • • We do not charge a fee to process your request unless it is excessive, repetitive, or manifestly unfounded. In such cases, we will inform you in advance and provide a cost estimate.

4. Non-Discrimination

We will not discriminate against you for exercising any of your rights under the CCPA or CPRA. Unless permitted by law, we will not:

• • Deny you goods or services;
• • Charge you different prices or rates for goods or services, including
• • through through granting discounts or other benefits, or imposing penalties;
• • Provide you with a different level or quality of goods or services;
• • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

5. Do not Track Signals

Do Not Track (DNT) is a privacy preference that can be configured in certain web browsers. When enabled, it signals websites that you do not want your online activity tracked.  We do not currently respond to DNT signals. However, California law requires us to disclose whether we honor opt-out preference signals (such as a browser-based Global Privacy Control (GPC)). We currently do not recognize GPC signals but provide other mechanisms to exercise your rights as described in this notice.

6. Changes to this Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes, we will update the effective date at the top of the notice and, where required by law, provide you with appropriate notice or obtain your consent. This may include email notifications, in-product messages, or website banners, in accordance with the mechanism described in our general Privacy Policy.

Contact Information

If you have any questions or comments about this privacy notice or Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: privacy@nimbleway.com.