Legal
Privacy Policy
Last updated October 21, 2026

This Privacy Notice for New CAS LLC (doing business as Cloud Accountant Staffing) ("we," "us," or "our") describes how and why we collect, store, use, and share ("process") your personal information when you use our services ("Services"), including when you:

This notice covers visitors to our website and the people who use the Portal on behalf of their firms ("Firm Users").

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we receive information from third parties? Yes. We may receive business contact details from data enrichment and visitor identification services, and campaign data from advertising partners. Learn more in "What information do we collect?"

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

Do we record how you use the Portal? Yes. We use product analytics and session recording to see how the Portal is used and to fix problems. Text you type into forms is masked. Learn more in "Session recording and product analytics."

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. SESSION RECORDING AND PRODUCT ANALYTICS

4. COOKIES AND SIMILAR TECHNOLOGIES

5. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

6. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

7. HOW LONG DO WE KEEP YOUR INFORMATION?

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

9. DO WE COLLECT INFORMATION FROM MINORS?

10. WHAT ARE YOUR PRIVACY RIGHTS?

11. CONTROLS FOR DO-NOT-TRACK FEATURES

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

13. DO WE MAKE UPDATES TO THIS NOTICE?

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Information you give us

  • Website forms and calls: your name, email address, phone number, company, job title and anything else you choose to share when you contact us, book a call or subscribe.
  • Portal registration: your name, work email address, company name, how you heard about us, the role you want to fill, your preferred candidate location, team size, hiring timeline, an optional partner code, and the address of the page you registered from (which can include campaign parameters).
  • Portal activity: the candidates you shortlist, the interviews you book (date, time and the candidate or CAS team member you book with), and your messages to us.
  • Onshore access: when you sign our onshore non-disclosure agreement we record your name, company and job title, the agreement version, the date and time, and your IP address and browser details as evidence of signature.

Information collected automatically

When you visit our website or use the Portal we, and the providers listed in "When and with whom do we share your personal information?", collect:

  • Device and log data: IP address, browser and device type, operating system, language, referring page, and the dates and times of your visits.
  • Approximate location: country, region and city, derived from your IP address. We do not collect precise (GPS) location.
  • Usage data: pages viewed, links and buttons clicked, scrolling and time on page, searches and filters used (search terms themselves are not recorded in our analytics events), page load performance, and errors.
  • Session recordings of Portal visits, described in "Session recording and product analytics."
  • Cookies and similar technologies, described in "Cookies and similar technologies."

Once you sign in to the Portal, this information is linked to your account (your name, email address and company), so it is not anonymous.

Information from third parties

  • Data enrichment: when you register, we send your registration details to Clay, which may add publicly available business information such as company size, industry or your role.
  • Visitor identification: our website (RB2B) and the Portal registration page (Claydar) use services that may identify the company, and in some cases the professional profile, associated with a visit before you give us your details.
  • Partners and advertising platforms: partners who refer you (for example through a partner code), and Google and LinkedIn, which report how our ads perform.

Candidate information. The Portal shows Firm Users information about candidates represented by CAS, such as first names, photos, introduction videos, resumes, assessment results, experience and rates. Firm Users may use it only to evaluate candidates for engagement through CAS and, for onshore candidates, under the non-disclosure agreement.

Sensitive information. We do not ask Firm Users for sensitive personal information. We process the one-time sign-in codes we email you only to sign you in.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
  • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
  • To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
  • To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
  • To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
  • To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
  • To run the Portal. To create and secure your account, sign you in by email link, show you candidates, save your shortlist and schedule interviews.
  • To manage onshore access. To record your NDA signature, review your request (including checking whether any candidate currently works for your firm so we can withhold that profile), and notify you of the decision.
  • To understand and improve our services. To measure how the website and Portal are used, find where people get stuck, and fix bugs, using product analytics, heatmaps and session recordings.
  • To keep our services secure. To detect bots and abuse, monitor errors, and investigate incidents.
  • To follow up on your interest. To notify our team when you register, to enrich your business contact details, and to contact you about candidates and services.
  • For advertising. To measure our ad campaigns and to show our ads to people who visited our website or Portal, on Google and LinkedIn.

3. SESSION RECORDING AND PRODUCT ANALYTICS

In Short: We record how you interact with the Portal to improve it and fix problems. Text you type is masked and recordings are deleted after 30 days.

We use PostHog, a product analytics provider, on the Portal. It records the pages you visit, the buttons and links you click, how you scroll and move the mouse, and what is shown on screen. From that we can replay a visit as a video-like recording, build heatmaps, and count how often features are used. Our servers also send PostHog records of key actions, such as registering, booking an interview, requesting onshore access and changes our team makes to your account, so we can link them to your visit.

What we record: every visit to the Portal, including the sign-in and registration pages before you sign in. After you sign in, recordings and usage data are linked to your account.

What we don't record:

  • Text you type into forms is masked and never sent.
  • Candidate photos are blocked.
  • The page that completes sign-in from your email link.
  • Your browser's developer console.
  • The contents of the Portal's network requests.

Who can see recordings: authorized CAS personnel, and PostHog as our service provider. Recordings show the candidate information on your screen, including candidates' first names and profile details.

Retention: session recordings are deleted after 30 days.

Where: PostHog stores this data in the United States. The Portal sends it through an address on our own domain (portal.cloudaccountantstaffing.com/ingest) before it is forwarded to PostHog.

Error monitoring: if the Portal hits an error, our error-monitoring provider, Sentry, receives a technical report and a short recording of the moments before the error, with all text masked and all images blocked.

4. COOKIES AND SIMILAR TECHNOLOGIES

We and our providers use cookies, browser local and session storage, and similar technologies ("cookies") on our website and the Portal. Some are needed for the service to work. Others measure usage or support advertising.

  • Essential – Google Firebase (Portal): keeps you signed in. Browser storage firebaseLocalStorageDb, kept until you sign out.
  • Essential and security – Vercel BotID (Portal registration): bot detection, using browser signals checked when you submit the form.
  • Analytics and session recording – PostHog (Portal): product analytics, heatmaps and session recordings. Cookie and local storage ph_<project key>_posthog.
  • Analytics – Vercel Web Analytics (Portal): page view counts. No cookies.
  • Error monitoring – Sentry (Portal): error reports and recordings on error. Session storage sentryReplaySession, kept for the browser session.
  • Analytics – Google Analytics 4 (website and Portal): traffic and campaign measurement. Cookies _ga and _ga_<id>.
  • Advertising – Google Ads (website and Portal): conversion tracking and remarketing. Cookie _gcl_au, local storage _gcl_ls, and Google domain cookies.
  • Advertising – LinkedIn Insight Tag (website and Portal): conversion tracking, remarketing and audience insights. Local storage li_adsId and LinkedIn domain cookies.
  • Visitor identification – Claydar (Portal registration page): identifies the business behind a visit. Session storage claydar_session, claydar_device_id and radar_sn_*, kept for the browser session.
  • Visitor identification – RB2B (website): identifies the business or professional behind a visit. Cookies _reb2buid, _reb2bsessionID, _reb2bgeo and _reb2butk.
  • Marketing and CRM – HubSpot (website): forms, visit tracking and cookie banner. Cookies hubspotutk, __hstc, __hssc and __hssrc.
  • Personalization – Intellimize (Webflow Optimize) (website): page personalization and testing.

Some of these cookies are set on cloudaccountantstaffing.com, so they apply to both our website and the Portal.

Your choices: you can block or delete cookies in your browser settings. Blocking essential storage will stop the Portal from keeping you signed in.

5. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • For identifying injured, ill, or deceased persons and communicating with next of kin
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by the regulations

6. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We share personal information only as described here.

Service providers. These companies process personal information for us under written contracts that limit their use of it to providing services to us:

  • Vercel Inc.: hosting for the Portal, web analytics and bot detection (all Portal traffic, page views, browser signals).
  • Google LLC (Firebase and Google Cloud): accounts, sign-in, database and background functions (account and registration details, shortlists, bookings, NDA records).
  • PostHog, Inc.: product analytics, session recording and heatmaps (usage events, session recordings, and account identifiers: name, email and company).
  • Functional Software, Inc. (Sentry): error monitoring (error reports, masked recordings on error).
  • Resend: email delivery (email address, sign-in links, notification content).
  • Calendly LLC: interview scheduling (name, email, booking details).
  • Slack Technologies, LLC: internal notifications to our team (onshore access requests: name, company, email).
  • Clay: data enrichment and lead routing (registration details).
  • Claydar: visitor identification on the Portal registration page (device and visit data, IP address).
  • Notion Labs, Inc.: candidate records (candidate information).
  • Webflow, Inc.: website hosting (website traffic).
  • HubSpot, Inc.: CRM, website forms and analytics (contact details, website activity).
  • RB2B: website visitor identification (device and visit data, IP address).
  • Termly: privacy request form (request details).

Advertising and analytics partners. Google (Google Analytics and Google Ads) and LinkedIn (LinkedIn Insight Tag) collect information about your visits to our website and the Portal through their tags, including the pages you view. They may use it for their own purposes, such as showing you our ads on other sites, under their own privacy policies.

People you book interviews with. When you book an interview, your name, email address and the booking details go to the person whose calendar you book, through Calendly. That may be a CAS team member or, for some candidates, the candidate themselves.

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Legal requirements and protection. We may disclose information when the law requires it, or to protect our rights, our users, candidates or others, for example to enforce the onshore non-disclosure agreement.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Session recordings collected through PostHog are deleted after 30 days.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

If you have questions or comments about your privacy rights, you may email us at [email protected].

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

CategoryExamplesCollected
A. IdentifiersContact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, account name, cookie and device identifiers, and account IDYES
B. Personal information as defined in the California Customer Records statuteName, contact information, education, employment, employment history, and financial informationYES
C. Protected classification characteristics under state or federal lawGender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic dataNO
D. Commercial informationTransaction information, purchase history, financial details, and payment information; services requested, shortlists, and interview bookingsYES
E. Biometric informationFingerprints and voiceprintsNO
F. Internet or other similar network activityBrowsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements; pages viewed, clicks, searches and filters, session recordings, and ad interactionsYES
G. Geolocation dataApproximate location only (country, region, and city), derived from your IP addressYES
H. Audio, electronic, sensory, or similar informationImages and audio, video or call recordings created in connection with our business activities; session recordings of Portal screen activityYES
I. Professional or employment-related informationBusiness contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with usYES
J. Education InformationStudent records and directory informationNO
K. Inferences drawn from collected personal informationInferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics; hiring needs and interest in candidate typesYES
L. Sensitive personal InformationNO

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

  • Category A - As long as the user has an account with us
  • Category B - As long as the user has an account with us
  • Category I - As long as the user has an account with us
  • Category K - As long as the user has an account with us

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

In the past twelve (12) months we have "shared" (for cross-context behavioral advertising) identifiers and internet activity with advertising partners (Google and LinkedIn). We do not sell personal information for money. You can opt out of this sharing using the methods in "How to Exercise Your Rights" below.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

  • Right to know whether or not we are processing your personal data‍
  • Right to access your personal data‍
  • Right to correct inaccuracies in your personal data‍
  • Right to request the deletion of your personal data‍
  • Right to obtain a copy of the personal data you previously shared with us‍
  • Right to non-discrimination for exercising your rights‍
  • Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

  • Right to access the categories of personal data being processed (as permitted by applicable law, including Minnesota’s privacy law)
  • Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California's and Delaware's privacy law)
  • Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Minnesota's and Oregon's privacy law)
  • Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including Minnesota’s privacy law)
  • Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)
  • Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at [email protected], or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at [email protected]. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

13. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at [email protected] or contact us by post at:

New CAS LLC

1060 North Capitol Ave, Suite 3-101

Indianapolis, IN 46204

United States

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.

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