This Privacy Policy (“Policy”) notifies you about Echoflex Solutions, Inc., and its affiliates (“Echoflex,” “we,” “our,” or “us”) privacy practices, including how we collect, use, and disclose information about you when you access or use our website at www.echoflexsolutions.com (“Services”), or when you otherwise interact with us online, such as through our customer support channels or on social media pages.

Certain states, including California and Virginia, require additional information regarding our privacy practices and your privacy rights. If you are a resident of those states (“Consumer”), we provide you additional notices about our privacy practices and consumer rights relating to your personal information or personal data, as defined under those laws. If you are a California or Virginia resident, please see the California and Other States Notice of Collection and Privacy Rights section. 

We may change this Policy from time to time. If we make material changes, we will notify you by revising the date at the top of this Policy and, in some cases, we may provide you with additional notice (such as adding a statement to the Services or sending you a notification). We encourage you to review the Policy often to stay informed about our information practices and the choices available to you.

CONTENTS

Collection of Information
Use of Information
Disclosures of Information
Advertising and Analytics
Transfer of Information to the United States and Other Countries
Your Choices
California and Other States Notice of Collection and Privacy Rights
Additional Disclosures for Individuals in Europe
Contact Us

COLLECTION OF INFORMATION

Information You Provide to Us
We collect information you provide directly to us. For example, we collect information directly from you when you sign up for emails on our Services, create an account, fill out a form, submit or post content through our online community forum, make a purchase, communicate with us via third-party platforms, participate in a contest or promotion, request customer support, or otherwise communicate with us online. The types of information about you that we collect include your:

• First and last name
• Telephone number
• Email address
• Mailing address
• Company details
• Associated university and teacher (if you are a student using our ETCnomad Education Package).
• Username and password if you create an account
• Any other information you provide us

Additionally, if you make a purchase, we work with a third-party payment processor to collect and process your payment information.
Information We Collect Automatically
We automatically collect certain information about your interactions with us or our Services, including:

• Activity Information: We collect information about your activity on our Services, such as when you register a product on our Services.
• Transactional Information: When you make a purchase or return, we collect information about the transaction, such as product details, purchase price, and the date and location of the transaction.
• Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services.
• Information Collected by Cookies and Similar Tracking Technologies: We (and those who perform work for us) use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Services. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see our Cookie Policy (https://www.echoflexsolutions.com/privacy-statement#cookie) and the Your Choices section below.

Information We Collect from Other Sources
We may obtain information from other sources. For example, we may collect information about you when you interact with us through forums, our fixture library, registering for a conference, scheduling a demo, or through our online training Services.
Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address.

USE OF INFORMATION

We use the information we collect to provide, maintain, and improve the Services, and keep you informed about new products and services. We also use the information we collect to:

• Develop or improve products and services, including to debug and repair errors in our Services;
• Personalize your experience with us;
• Send you technical notices, security alerts, support messages and other transactional or relationship messages;
• Communicate with you about products, services, and events offered by Echoflex and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
• Monitor and analyze trends, usage, and activities in connection with our products and services;
• Personalize the advertisements you see on third-party platforms and websites (for more information, see the Advertising and Analytics section below);

• Facilitate contests, sweepstakes, and promotions;
• Sponsor educational or mentorship programs;
• Detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and help protect the rights and property of Echoflex and others;
• Comply with our legal and financial obligations;
• Create de-identified, anonymized, or aggregated information; and
• Carry out any other purpose described to you at the time the information was collected.

DISCLOSURES OF INFORMATION

We may disclose personal information in the following circumstances or as otherwise described in this policy:

• With vendors that access personal information to perform work for us, such as companies that assist us with web hosting, fraud prevention, customer service, and marketing and advertising.
• If you choose to use integrations we offer on our Services, such as Google Maps, we may disclose certain information with the integration partners.
• If we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
• If we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Echoflex, our users, the public, or others.

• With our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• In connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Between and among Echoflex and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
• With your consent or at your direction.

We also use and disclose aggregated or de-identified information that cannot reasonably be used to identify you. Echoflex processes, maintains, and uses this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.

ADVERTISING AND ANALYTICS

We engage others to provide perform related services across the web and in mobile apps. These entities may use cookies, web beacons, SDKs, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address and other identifiers, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used to deliver advertising and content targeted to your interests on our companies’ sites or mobile apps to analyze and track data, determine the popularity of certain content, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance, please visit www.aboutads.info/choices.

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

Echoflex is headquartered in the Canada, and we have operations and vendors in the United States and other countries. Therefore, we and those that perform work for us may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. Where required by law, we provide adequate protection for the transfer of personal data in accordance with applicable law, such as by obtaining your consent, relying on adequacy decisions, or executing Standard Contractual Clauses.

YOUR CHOICES

Account Information
You may update and correct certain account information at any time by logging into your account on the Services. If you wish to deactivate your account, please email privacy@etcconnect.com, but note that we may retain certain information as required by law or for our legitimate business purposes.
Cookies
Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.
Communications Preferences
You may opt out of receiving promotional emails from Echoflex by following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
Links to other Websites and Services
We are not responsible for the practices employed by websites or services linked to or from the Services, including the information or content contained in such websites or services, and this Policy does not apply to them. We provide links to products available on third-party websites for your convenience. Your browsing and interaction on any third-party website or service, including those that have a link on or to our Services, are subject to that third party’s own rules and privacy policies. Please read the terms of such websites and applications carefully and exercise care when providing your personal information.

CALIFORNIA AND OTHER STATES NOTICE OF COLLECTION AND PRIVACY RIGHTS

California and Other State Notice of Information Collected and/or Disclosed

The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.), as amended by the California Privacy Rights Act (“CPRA”), affords consumers residing in California certain rights with respect to their personal information. In addition, privacy laws in Virginia provide consumers residing in that those states certain rights with respect to their personal information. If you are a California or Virginia resident, this section applies to you as indicated.

If you are a California applicant or employee, employee applicant, or contractor, please refer to the Echoflex Privacy Notice for California Applicants/Employees for a description of Echoflex’s privacy practices in that context, and if you are a California business contact, please see our Notice at Collection for California Business Contacts.

We collect and have collected in the preceding 12 months the following categories of personal information:

We collect personal information for the business and commercial purposes described in the Use of Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you. We retain personal information for as long as necessary to carry out the purposes for which we originally collected it and for other purposes described in this privacy policy.

Sale of Personal Information

California law requires that we provide transparency about personal information we ”sell.” “Sale” under California law, broadly means scenarios in which we have disclosed personal information with partners in exchange for valuable consideration. In addition, California and other state privacy laws define “sale” to include disclosure of Personal Information with third parties for monetary consideration. In the preceding twelve (12) months, Echoflex has not sold personal information.

We do not knowingly sell or share personal information about consumers under the age of 16.
Information Relevant to California and Other States

The CPRA requires that we notify you if we “Share” your personal information with third parties. For purposes of the CPRA, “Sharing” means that we make available or otherwise disclose your information to third parties for cross-context behavioral advertising, such as targeting of advertising to you based on your personal information obtained from your activity across businesses, websites, apps, and services other than our Services.

Similarly, Virginia’s privacy law requires that we notify you if we use your information for Targeted Advertising. Targeted Advertising means displaying advertisements to you where the advertisement is selected based on personal information obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests.

Accordingly, we “Share” and use your information for Targeted Advertising. Specifically, we disclose your identifiers and internet or other network activity with Service Providers and third parties with whom you direct us to disclose your personal information.

To opt out of targeted advertising, sharing, and sales of your personal information, please follow the prompts here. If you are a California resident, you may also opt out of certain “sharing,” “targeted advertising,” and “sales” by visiting our Services with a legally recognized universal choice signal enabled (such as the Global Privacy Control). Please note that, depending on which legally recognized opt-out preference signal you use and whether you are logged into your account with us, our processing of the signal may be limited to the specific browser or device that you are using. You may need to renew your opt-out choice if you use a different browser or device to access our Services.

Privacy Rights

Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose, (2) request correction of your personal information, (3) request deletion of your personal information, (4) opt out of any “sales” or “sharing” of your personal information that may be occurring, and (5) not be discriminated against for exercising these rights. You may make these requests by calling +1 (778) 733-0111or sending an email to privacy@etcconnect.com. We will verify your request by asking you to provide information related to your recent interactions with us.

If we receive your request from an authorized agent and they do not provide a valid power of attorney, we may ask the authorized agent to provide proof that you gave the agent signed permission to submit the request to exercise rights on your behalf. In the absence of a valid power of attorney, we may also require you to verify your own identity directly with us or confirm to us that you otherwise provided the authorized agent permission to submit the request. If you are an authorized agent seeking to make a request, please call +1 (778) 733-0111.

ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

We store personal data associated with your MyETC or Echoflex forum account for as long as your account remains active. If you close your account, we will delete your account data in accordance with our data retention policy; otherwise, we will delete your account data after six years of inactivity. If you place an order through the ETC Swag Store, we will have to store the personal data relating to such order for at least as long as necessary to fulfill the order and as long as necessary for compliance with statutory tax and accounting requirements in accordance with our Record Retention Policy, even if you do not have a MyETC or Echoflex Forum account or if your MyETC or Echoflex Forum account has meanwhile been deleted. We store other personal data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Contact Information
If you have any questions or comments about this notice, the ways in which Echoflex collects and uses your information described above (and in the Echoflex Privacy Policy), your choices and rights regarding such use, or how to exercise your rights under California law, please do not hesitate to contact us at:
Phone: +1 (778) 733-0111
Email: privacy@etcconnect.com
Postal Address:
ATTN: Legal Department
Echoflex Solutions, Inc.
39465 Discovery Way, Unit 120
Squamish, British Columbia
Canada V8B 1C9