Privacy Policy

Updated: January 01, 2023

Connectome Inc’s mission is to connect the world’s professionals to allow them to be more productive and have a seamless networking experience. One of the key factors of our goal is our commitment to be transparent about the data we collect about you, how it is used and with whom it is shared. We offer choices in the data we collect and how we make it available to our users and stakeholders.

This Privacy Policy details how we collect business information, including personal information pertaining to businesses and people, and all other types of information through our Plugin as well as how we maintain, use, and share that information; and how you can manage the way information about you is handled.

I. How Information Is Collected

A. Where does Connectome Inc. get the information for its profiles?

Connectome Inc. creates profiles of professionals and companies using data collected from different sources. You and others may post content that includes information about you on Public networking platforms. We also may collect public information about you, such as professional-related news and accomplishments, and make it available as part of our Services. Once we have collected Business Information about a person or company, we combine collective mentions of the same person or company into a Profile.

The Business Profiles are then made available to the users of the Plugin and our customers and strategic partners. Business Information that may be provided in a Profile includes name, email address, job title and department, phone number, company name, postal address of company and business-related postal address of the person, employment history, and education history. Business Profiles may also include links to articles by, about, or quoting an individual and links to an individual’s social media profiles.

Connectome Inc. obtains the data for its Business Profiles in several ways, including:

  1. Gather publicly-available information on the web.
  2. Our customers/users contribute information about themselves or other people and companies.
  3. When our customers uses our browser extension while using LinkedIn, we read the minimum Data presented on the LinkedIn profile pages that the End User is browsing for providing the Service( e.g. name, position, company, contact details if public)

B. How the Connectome Inc. Plugin works to collect data?

Connectome Inc. offers a Plugin as well, you are required to install our Plugin, or otherwise provide Connectome Inc. with access to your email account. When you install our Plugin, you allow Connectome Inc. to access certain Business Information stored by the application that your computer uses to manage your email and contacts, known as an “email client” (e.g., Microsoft Outlook) or stored by a provider of cloud services for email (e.g., Google Apps). If required to access this Business Information stored on your computer’s email and contact application(s), you may need to provide Connectome Inc. with the necessary username and password information. We use this Business Information to improve the size and quality of our Data Database.

From the contacts within your email client and “signatures” within email messages, we collect the following Business Information, if available, for each person:

  • Name
  • Email address
  • Job title and department
  • Business phone numbers (general, direct, and fax)
  • Company name
  • Postal address of company
  • Business related postal address of person
  • Corporate website URLs
  • Social Networking URLs

From the headers of your emails, we collect the following Business Information, if available:

  • Metadata such as Internet Protocol addresses and the dates email messages are sent or received
  • Email addresses, names, and job titles of recipients and senders

To ensure the integrity of the Directory, we take the following steps:

  • Business Information Only – Connectome Inc. only wants business-related information. Therefore, any contacts that have an address from a consumer-oriented service are disregarded.
  • Unattributed – We do not disclose who contributed particular information using the Connectome Inc. Plugin or other contribution methods. (The only exceptions: See “Disclosures to Service Providers,” “Disclosures for Legal Reasons,” and “Disclosures to a Buyer of the Company,” below.)
  • Opt Out – Anyone added to the Data may request to be removed at any time, via email or web. We promptly honor such requests. However, if this information is crawled/contributed by a user again it will be read to the Database.

Information from your email client will continue to be shared as described above as long as the Plugin  remains installed. If you choose to stop sharing information from your email client with Connectome Inc., you can uninstall the Plugin at any time. You may not, however, retroactively “unshare” the Business Information you have already made available to Connectome Inc.

C. Customer Information

Customer Information Collected. Connectome Inc. may collect the following information from or regarding its customers: (1) personal contact information regarding users of the Services (“User Information”); (2) information uploaded to our system by a user of the Services (“Uploaded Information”); and (3) usage logs regarding the use of the Site and Services, including logins and other actions taken, time stamps, IP address, and other usage data (“Usage Logs”) (collectively, “Customer Information”).

You may be a user that has been provided access to the Site through your company license agreement. Your employer may require that one or more users have global rights to access any and all information of every user that has access through the company. If you have questions or concerns regarding the rights of other individuals in your company to access your User Information, Uploaded Information, or Usage Logs, you should raise those concerns with the appropriate person at your company.

Use of Customer Information. Customer Information may be used for Connectome Inc’s legitimate business interests in connection with your use of the Site, including to respond to user inquiries and fulfill user requests, complete transactions, provide customer service, send administrative information, and to personalize user experience with the Site. We may use Customer Information to better understand our users in general and to improve the content and functionality of the Site. We may use Customer Information to contact you in the future to tell you about services, promotions, opportunities, and other general information about Connectome Inc. we believe will be of interest to you. We may use Customer Information to investigate and prosecute potential breaches of Connectome Inc’s security or license agreements.

Connectome Inc. will not disclose Customer Information to any third party except in connection with a legitimate use as set forth herein, in connection with a bona fide legal dispute to which such information is relevant, in response to valid, compulsory legal process, or as otherwise required by law. Connectome Inc. will, whenever possible, obtain confidentiality agreements from any person or entity to whom Customer Information is disclosed and ensure any recipients are committed to employing appropriate technological security measures.

Connectome Inc. employs reasonable security and back-up procedures to protect Customer Information. However, in the unlikely event there is a loss or corruption of Customer Information, Connectome Inc. is not responsible or liable for such loss or corruption. We encourage our users to retain copies of all Uploaded Information on their own system.

D. How else does Connectome Inc. Collect Information?

When you submit information through our Site. Visitors to our Site may choose to submit their name, email address, phone number, and/or other information so that they can learn more about our services among other things. By accessing, using, and/or submitting information through the Site, you consent to the practices described in this Policy with regard to the information collected thereby as described herein. If you do not agree with this Policy, you should not submit any information through our Site and you must delete all cookies from your browser cache after visiting the Site and refrain from visiting or using the Site.

When you manage your Business Profile. Connectome Inc. allows you to claim your Business Profile and to update the information listed about you in your Business Profile, including your name, job title, business email address, direct phone number, current and past employment information, and education history. We use the information you submit to update your Business Profile solely for purposes of verifying your identity, updating your Business Profile information, and honoring your privacy preferences. For additional information, see the “Your Choices” section below.

When you use our Services. In order to use certain Connectome Inc. Services, you may be required to register as a user. From time to time, we may use your email address to send you information and keep you informed of products and services in which you might be interested. You will always be provided with an opportunity to opt out of receiving such emails. Your contact information may also be used to reach you regarding issues concerning your use of our Services or Site, including changes to this Policy. A more detailed description of how we may collect and use customer information can be found in the “Customer Information Collected” section above.

When you provide information to our customers. We receive information about our customers’ end-users from or on behalf of our customers. Because of the nature of our Services, this information may contain any type of data, but typically includes name, contact information, and company information, such as company name. We may also collect data about you automatically through your use of our Services, as described in the “Cookies and Similar Technologies” section below. If you are a visitor to or user of a website, application, or service on which a customer uses our Services, then any information that you provide through our Services is subject to the customer’s privacy policy and applicable terms. When we provide our Services to a customer, we act as a “data processor,” and the customer is considered to be the “data controller,” as further described in the “When Connectome Inc. is a Controller” and “When Connectome Inc. is a Processor” sections below.

When you refer to a friend. If you choose to use our referral service to invite a friend to join Connectome Inc., we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Site. Connectome Inc. will use this information for the sole purpose of sending this one-time email and will store your friend’s name or email address.

When you use Connectome Inc. Integrations. As part of the Services, Connectome Inc. may make available to its customers certain “Integrations.” In using Connectome Inc’s Integrations, such as Connectome Inc’s web browser extensions, Business Information from customer’s CRM, MAT, or sales enablement software may be transmitted to Connectome Inc. for purposes of matching or cleansing the customer’s data against Connectome Inc’s database as a feature of the Services. In that event, Connectome Inc. may retain and store such Business Information for purposes of identifying potential contacts to supplement the Services, verifying the accuracy of such Business Information, removing out-of-date Business Information from the Services, or otherwise improving Connectome Inc’s research processes and the content provided through the Services. Information so received will not be attributable to the source. In the event that any customer wishes to opt out of Connectome Inc’s use of such information, they may do so by emailing us at support@reachiq.io.

When you connect the Services to your email or calendar. In order to provide certain Services, Connectome Inc. may require access to your email account and/or calendar (e.g., through G-Suite or Office 365). Depending on the specific Services being used, we may collect email header information, email subjects, email bodies and attachments, and calendar meeting information such as meeting participants, meeting description, subject, and date and time of the meeting. Customers have control over what data is collected, including which mailboxes are connected, whether message attachments or content is collected, and which emails or email domains should not be collected. Connectome Inc. use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

From third parties. Connectome Inc. may obtain information about you from third-party sources such as our service providers and strategic partners. We may use this information to enhance the information that we already maintain about you and to improve the accuracy of our records, in addition to other purposes described in this Policy.

Creation of aggregated information. Connectome Inc. may aggregate collected information about our users in a form that does not allow users to be personally identified for the purpose of understanding our customer base and enhancing the Site and the Services that we and our strategic partners and customers can provide you.

Creation of information from inferences. We may use the information we already have about you in order to draw inferences about you or to produce scores or ratings such as the Likely to Listen score. We use scoring models and algorithms that evaluate selected data points to produce a score predicting the likeliness of a candidate to respond to a recruiter’s outreach efforts. We do not make any decisions about individuals, and we do not tell our customers whether to reach out to a particular candidate or not.

Automated information collection. We also collect information using cookies, as described below under the “Cookies and Similar Technologies” section.

II. How We Use Information

In addition to the uses described in the section above, we may also use this information for one or more of the following purposes:

  • Provide, maintain, and improve the Site.
  • Verify, cleanse, update, and maintain Business Information and other information provided through the Site.
  • Provide and deliver the Services you request, process transactions, and send you related information, including communications and invoices.
  • Send you technical notices, updates, security alerts, and support and administrative messages.
  • Respond to your comments, questions, and requests, and provide customer support.
  • Create your Connectome Inc. account and identify you when you sign in to your account.
  • Communicate with you about products, services, offers, promotions, rewards, and events offered by Connectome Inc. and others, and provide news and information we think will be of interest to you.
  • Monitor and analyze trends, usage, and activities in connection with the Site.
  • Detect, investigate, and prevent fraud and other illegal activities.
  • Protect the rights and property of Connectome Inc., our customers, and others.
  • Personalize and improve the Site.
  • Notify you about important changes to the Site, including changes or updates to this Privacy Policy.
  • Facilitate contests, sweepstakes, and promotions, process entries, and deliver rewards.
  • Consider you for possible employment with Connectome Inc. in connection with an application that you submit through the Site, and communicate with you about your application.
  • Create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners or customers may use to provide and improve our respective services.
  • Comply with our contractual and legal obligations, resolve disputes with users, and enforce our agreements.
  • Carry out any other purpose described to you at the time the information was collected.

III. How We Share Information

Disclosures of Business Profiles: We may make any Business Information that our users contribute for inclusion in our Database, that we collect from public web sources, that we collect through market research surveys and phone interviews conducted by our in-house research team, or that we license from third parties, available to users of the Site, to our strategic partners, and to our customers. If you provide information, including Business Information, in creating or updating your Business Profile, that information will be included in the Database and thus can be viewed by third parties.

Disclosures via Public Database: Connectome Inc. makes certain limited Business Information from its Business Profiles publicly available in our Public Database on our Site. The categories of Business Information that may be made available in the Public Database include past or current name, company, company headquarters telephone number, office address, job title, and/or education information. Information in the Public Database is publicly available to visitors who visit our Public Database web pages on our Site.

Our Site offers publicly accessible blogs or community forums. You should be aware that any content you provide in these areas may be read, collected, and used by others who access them. You can request the removal of your personal information from our blog or community forum by contacting us at privacy@reachiq.io. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Disclosures to Affiliates: We may share Business Information with our affiliates who may act for us for any of the purposes set out in this Privacy Policy, including our current and future parents, subsidiaries, and other companies under common control and ownership with Connectome Inc.

Disclosures to Service Providers: Connectome Inc. may from time to time disclose Business Information or other collected information to service providers, solely for providing functions related to our operation of the Site and for no other purpose. For example:

  • Connectome Inc. uses service providers to process credit card payments on our Site. When you use a credit card to pay for Connectome Inc. Services, information such as your name, billing address, phone number, email address, and credit card information will be submitted to service providers for verification and to manage any recurring payments.
  • Connectome Inc. uses software hosted by a service provider to provide us with information regarding our visitors’ activities on our Site. When you visit our Site, that service provider may set cookies on our behalf and may receive information about your browsing activity on our Site.

Disclosures to Integration Partners: In using Connectome Inc’s Integrations, such as Connectome Inc’s  web browser extensions, Business Information from Connectome Inc. may be disclosed to a customer’s CRM, MAT, or sales enablement software as requested or directed by our customers.

Disclosures for Legal Reasons: We may disclose collected information, including Business Information, to a third party if we believe in good faith that such disclosure is necessary or desirable: (i) to comply with lawful requests, subpoenas, search warrants, or orders by public authorities, including to meet national security or law enforcement requirements; (ii) to address a violation of the law; (iii) to protect the rights, property, or safety of Connectome Inc., its users, or the public; or (iv) to allow Connectome Inc. to exercise its legal rights or respond to a legal claim.

Disclosures to a Buyer of the Company: If our company or substantially all of our assets are acquired, or in the event of a merger or bankruptcy, information about you and/or information you provide to Connectome Inc. may be among the transferred assets. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Other Disclosures

If you register for a Connectome Inc. event with a third-party speaker, your information will generally be shared with the speaker and any third-party sponsors or partners of the event.

We post customer testimonials on our Site which may contain the customer’s name. We always get consent from the customer prior to posting any testimonial. If you wish to update or delete your testimonial, you can contact us at support@reachiq.io

IV. Cookies and Similar Technologies

Most websites, including our Site, use a feature of your browser to set a small text file called a “cookie” on your computer. The site placing the cookie on your computer can then recognize the computer when you revisit the site to allow auto login and track how you are using the site.

When you visit our Site, our servers and/or those of our service providers automatically record certain information that your web browser sends, such as your web request, Internet Protocol address, browser type, referring/exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, time and date of use, and other information. We may link this information to information that you submit while on our Site, which does allow you to be personally identified.

You are free to decline cookies. You can configure your browser to accept all cookies, reject all cookies, erase cookies, or notify you when a cookie is set. Electing to reject or disable cookies may substantially limit your ability to use our Site.

Connectome Inc. may adopt other technologies that serve similar functions as cookies. If we do so, we will disclose it in this Policy.

A. Third Party Cookies

The use of cookies and similar technologies by our partners, affiliates, tracking utility companies, and service providers is not covered by this Policy. We do not have access to or control over these cookies. Our partners, affiliates, tracking utility company and service providers may use session ID cookies in order to:

  • personalize your experience.
  • analyze which pages our visitors visit.
  • provide website features such as social sharing widgets.
  • measure advertising effectiveness.
  • track which areas of our site you visit; in order to remarket to you after you leave.

To disable or reject third-party cookies generally, please refer to the third-party’s relevant website. You can also reject third-party analytics cookies by clicking the “Close” button on the cookie banner when visiting our Site.

B. Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc., on our Site. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Site, compile reports on the Site’s activity, and provide other services related to Site activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. The Site does not use Google Analytics to gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking analytics by Google click here.

C. Web Beacons

Our Site contains electronic images known as “web beacons” (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our site is used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns.

V. Your Choices

A. How Can You Change or Delete Your Professional Information?

To find out if you are in the Connectome Inc. database, search for your first name and last name on the Connectome Inc. home page. If you have a common name, you can limit your search based on geographical location or companies where you have worked.

Once you have located one or more Connectome Inc. profiles in your name, consider these options for managing your professional profile on Connectome Inc.:

Update Your Own Professional Connectome Inc. Profile. Make sure your Connectome Inc. profile is up to date for recruiters and others who may want to reach you. Simply verify your Connectome Inc. profile and you can update your work history, education history, and contact information. You can also consolidate multiple Connectome Inc. profiles in your name to create a comprehensive snapshot of your professional background.

Remove Your Connectome Inc. Profile Completely. If you wish to completely remove your existing individual profile from the Database, please visit Remove Your ReachIQ Professional Profile or email support@reachiq.io. If you make this choice, your name, employment history, education history, web references, and contact information (including email address) will be removed from our search results as soon as possible.

B. How Can You Change or Delete Your Company Information?

To find out if your company is in the Connectome Inc. database, search for your organization on the Connectome Inc. home page. Once you have located the Connectome Inc. profile, consider these options for managing your company profile on Connectome Inc.:

Update Your Company Profile on Connectome Inc.. Simply verify your Connectome Inc. company profile to update your company description, industry, company location, and more. You can also consolidate multiple Connectome Inc. profiles to create a comprehensive snapshot of your company.

Remove Your Company Connectome Inc. Profile Completely. Connectome Inc. is a specialized web search engine, similar to Google but focused on finding information about companies and professionals. We gather all information about companies from corporate web sites, press releases, public company profiles and/or SEC documents filed with the US government. The company summaries are created automatically by Connectome Inc’s software based on the information we find on those documents.

As a company policy, Connectome Inc. does not remove company information from our search engine. If any of the company information is incorrect, please update your company profile.

C. How Can You Opt-Out of Certain Uses of Your Information?

Connectome Inc. gives you the opportunity to “opt out” of having your information used for certain purposes.

If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by visiting /unsubscribing. After we receive your request, we will send you an email message to confirm that you have been unsubscribed.

Connectome Inc. will not share information about you that you submit when you register for our Services with third parties for promotional uses unless you opt in to such sharing within your Connectome Inc. account or Connectome Inc. has separately acquired such information from other sources, in which case Connectome Inc. will give you the opportunity to opt out via email.

VI. How Do We Keep Your Information Secure?

The security of your information is important to us. When you enter sensitive information (such as a credit card number) on our registration forms, we encrypt that information using secure socket layer technology (SSL).

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. However, no method of Internet transmission or electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

VII. Data Retention

We will retain your information for a period of time consistent with the original purpose(s) for which we collected it, as described in this Privacy Policy. We will retain your information (i) for as long as we have an ongoing relationship with you and as needed to provide you Services; (ii) as necessary to comply with our legal obligation(s); (iii) as necessary to resolve disputes or to protect ourselves from potential future disputes; or (iv) as necessary to enforce our agreements. Retention periods will be determined taking into account the amount, nature, and sensitivity of your information and the purpose(s) for which it was collected. After the retention period ends, we will delete your information. Where we are unable to do so, we will ensure that appropriate measures are put in place to prevent any further use of your information.

VIII. Links to Other Sites

This Site contains links to other sites that are not owned or controlled by Connectome Inc. We are not responsible for the privacy practices of such other sites. When you leave our Site, we encourage you to be aware and to read the privacy statements of each and every website that collects personally identifiable information. This Policy applies only to information collected by this Site or in the method(s) otherwise discussed herein.

IX. Social Media Widgets

Our Site includes social media features, such as the Facebook “Like” button and “Widgets,” such as the “Share” button or interactive mini-programs that run on our Site. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.

X. Information for Users in Europe and Elsewhere Outside the U.S.

If you use our Site outside of the United States, you understand that we may collect, process, and store your personal information in the United States and other countries in which we or our affiliates or subcontractors maintain facilities. The laws in the U.S. regarding personal information may be different from the laws of your state or country.

A. Users in the European Union (EEA), the UK, and Switzerland 

If you are a resident of the EEA, the UK, or Switzerland, the following information applies.

Purposes of processing and legal basis for processing: As explained above, we process personal information in various ways depending upon your use of our Sites. We process personal information on the following legal bases:

  1. with your consent;
  2. as necessary to perform our agreement to provide Services;
  3. as necessary for compliance with a legal obligation to which we are subject; and
  4. as necessary for our legitimate interests in providing the Sites where those interests do not override your fundamental rights and freedom related to data privacy.

Connectome Inc’s collection of Business Information, and the creation and licensing of Connectome Inc’s Business Profiles and Database, are within Connectome Inc’s legitimate interests to organize and make available business contact information given the limited impact of this data on an individual’s private life and that this information, unlike personal contact details, is widely disclosed. Connectome Inc. has put in place safeguards to protect personal privacy and individual choice, including disclosures of its data processing activities, the use of consent or opt-outs wherever possible, and the implementation of a privacy center:

https://reachiq.ai/do-not-sell-my-information

Right to lodge a complaint: Users that reside in the EEA, the UK, or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.

Transfers: Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. Per the applicable requirements of the General Data Protection Regulation (“GDPR”), we will ensure that transfers of personal information to a third country or an international organization are subject to appropriate safeguards as described in Article 46 of the GDPR, such as the EU Standard Contractual Clauses. Please see “Privacy Shield Frameworks” below regarding our compliance with the EU- and Swiss-US Privacy Shields.

Individual Rights: If you are a resident of the EEA, the UK, or Switzerland, you are entitled to the following rights under the GDPR. Please note: In order to verify your identity, we may require you to provide us with personal information prior to accessing any records containing information about you.

  • The right to access, correction, and restriction of processing. You have the right to request access to, and a copy of, your personal information at no charge, as well as certain information about our processing activities with respect to your data. You have the right to request correction or completion of your personal information if it is inaccurate or incomplete. You have the right to restrict our processing if you contest the accuracy of the data we hold about you, for as long as it takes to verify its accuracy.
  • The right to data portability. You have the right to ask for a copy of your data in a machine-readable format. You can also request that we transmit your data to another entity where technically feasible.
  • The right to request data erasure. You have the right to have your data erased from our Site if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
  • The right to object to our processing. You have the right to object to our processing if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.

When Connectome Inc. is a Controller: Connectome Inc. acts as a data controller when we collect and use information about data subjects who are visitors to our Site, as well as when we collect and use information about data subjects for purposes of creating and maintaining our Business Profiles and providing the Services. Connectome Inc’s Data Protection Officer can be contacted by email at support@reachiq.io.

When Connectome Inc. is a Processor: When our customers use our Services, they are acting as the data controller and are responsible for ensuring that personal information collected about data subjects is being processed lawfully. In those circumstances, we are acting as the data processor, and receive personal information as agents of our customers merely for processing as instructed by our customers. Our customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all third-party individuals that are a visitor to or user of a website, application, or service on which a customer uses our Services have been provided with adequate notice regarding the processing of their personal information, have given informed consent where such consent is necessary or advised, and that all legal requirements applicable to the collection, use, or other processing of personal information through our Services have been met by such customers. Our customers are also responsible for handling data subject rights requests under applicable law, by their users and other individuals whose data they process through the Services. Connectome Inc’s obligations with respect to personal information for which we are solely a data processor are defined in our agreements with our customers and are not covered by this Policy.

B. The General Data Protection Regulation (“GDPR”) 2016/679

Connectome Inc. endeavors to comply with the provisions of the GDPR as to any information in its possession regarding European Union-based persons (“data subjects”). As such, Connectome Inc. only processes personal information on data subjects where it has a lawful basis to do so, which may include the consent of the person (especially in the case of website visitors who provide their information), performance of a contract, compliance with a legal obligation, or the legitimate interest of the controller or a third party. Connectome Inc. provides notice to all data subjects as required by GDPR Article 13 or 14, as appropriate, and honors the rights of data subjects provided in Articles 12-23, including the right to be forgotten. For any opt-out requests or other inquiries related to privacy, please visit our privacy center at https://reachiq.ai/do-not-sell-my-information or email support@reachiq.io.

In the course of obtaining data to be included on the Site, if Connectome Inc. obtains Business Information regarding an individual that Connectome Inc. has reason to believe is based in the European Union, Connectome Inc. will provide such individual with a notice detailing the information Connectome Inc. has on such person, the purpose for which it will be used, and informing such person of their rights with respect to such information, including the right to know what information Connectome Inc. possesses on them, to correct such information, or to opt out of data collection entirely. Such persons may opt out of the Connectome Inc. database by visiting https://reachiq.ai/do-not-sell-my-information or emailing support@reachiq.io.

XI. Changes to this Policy

Connectome Inc. reserves the right to modify this Policy from time to time, so please review it regularly. If we make material changes to this policy, we will notify you here, by email, and/or by means of a notice on our homepage prior to the changes becoming effective. Your continued use of the Site after any updates to this Privacy Policy constitutes your acceptance of the updated Privacy Policy.

“Connectome Inc. use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.”