Privacy Policy
Last Updated: May 10, 2023
This Privacy Policy covers NSPIRE Automation, Inc.’s, and its subsidiaries and affiliates’ (collectively
“Centilytics,” “we,” “us,” “our”) policies on the collection, use, and disclosure of personal information and
data (as defined by applicable law, when visitors and customers (collectively “Users”) access, use, or
otherwise interact with www.centilytics.com (the “Site”) and/or Centilytics’ related mobile applications
(collectively the “Platform”) and the software and services made available through the Platform (collectively
the “Services”).
By optionally providing your Personal Information within the Platform, you consent to the collection, use
and disclosure practices identified in this Privacy Policy. Users may withdraw your consent at any time
through the by email at info@centilytics.com.
Section 8 is intended to provide the Notice of Collection required under the California Consumer Privacy
Act.
1. Personal Information Collected by Centilytics
• Email & Contact Information. Users may optionally provide their email address and/or other
contact information (e.g., name, Centilytics name, job title) to Centilytics to contact us through the
Platform with questions about our Platform and Services. Users may also optionally subscribe to
our newsletters and may unsubscribe at any time through the opt-out link contained within those
communications.
• Account Information. In subscribing to, or otherwise purchasing, the Services, Centilytics requires
its customers to provide account-based information, including Customer address and its authorized
users’ name, address, phone number, and email. This information is necessary to facilitate account
services. Centilytics will utilize email and/or phone numbers provided to communicate with
Customer regarding services. Account information may also be used to (i) provide information
regarding our Services; (ii) communicate material changes to our Master Service Agreement and
Privacy Policy; and/or (iii) help us maintain and improve Services offered.
• Payment Information. To make payments for the Services, Centilytics may collect debit or credit
card account information, email and other information to verify the customer’s identity, such as
name, address, telephone number, and/or date of birth. Centilytics does not itself store debit or credit
card information on its servers, but utilizes third party payment processors to manage and process
payments in order to guarantee the security of personal payment information.
• IP Address. A user’s IP Address is identified and logged automatically in our server log files
whenever you visit the Platform, along with the time of the visit and the page(s) that were visited.
Centilytics uses IP Addresses for calculating usage levels of the Platform, helping diagnose server
problems, and administering the Platform and Services.
• Web Beacons. Pages of our Site and/or emails from Centilytics may contain small electronic files
known as web beacons that permit Centilytics, for example, to count users who have visited those
pages or opened an email and for other related Site statistics.
• Cookies. Centilytics’ Site uses cookies to provide users with a better browsing experience -- cookies
are only collected with your express consent. In addition, by accepting Centilytics’ Privacy Policy
upon purchase of the Services, you are consenting to Centilytics’ use of cookies in connection with
the Services itself. Centilytics utilizes cookie technology to gather information on Internet use in
order to serve you more effectively. Cookies are files with a small amount of data, which may
include an anonymous unique identifier. Cookies are sent to your browser from a website and
transferred to your device. You can set your browser to remove or reject cookies; however some
Platform features or Services may not work properly without cookies.
How You Can Control Advertising Cookies. Cookies are also utilized to deliver advertising on
our Site. Among other uses, they allow us to show more relevant advertising to people who visit the
Site by showing you ads that are based on your browsing patterns and the way you have interacted
with our Site. You can find information about how to opt out of the cookies provided by our
advertising partners here:
o Google Ads. Google Ads utilizes search engine marketing to serve ads to target
audiences. Users can manage ad settings on Google Advertising Opt-Out and revisit their
privacy preferences on Google’s Privacy Checkup tool.
o Facebook/Meta Advertising. Meta may use cookies, web beacons, and other storage
technologies to collect or receive information and use that information to provide
measurement services and target ads. Centilytics may use “Visitor action pixels” from
Facebook on the Platform. This allows user behavior to be tracked after they have been
redirected to the provider’s website by clicking on a Facebook ad. This enables us to
measure the effectiveness of Facebook ads for statistical and market research purposes.
The data collected in this way is anonymous to us, i.e. we do not see the Personal
Information of individual users. Please see the Facebook Privacy Policy for additional
information. Users can opt-out of the collection and use of information for ad targeting. To
opt-out, go to Privacy Settings through your Facebook account and opt out under the Ad
Preferences settings.
o LinkedIn Ads. LinkedIn Ads uses cookies to track the success of LinkedIn advertising.
Personal Data is processed in accordance with the LinkedIn Privacy Policy. To opt out of
LinkedIn Ads, see manage your LinkedIn Advertising preferences.
Even if you opt out of cookies/ads personalization, you may still see ads based on factors such as
your general location derived from your IP address, your browser type, and your search terms. You
can also manage cookies for any online advertising service via the consumer choice tools created
under self-regulation programs, such as the US-based aboutads.info choices page or the European
Union (“EU”)-based Your Online Choices. See also the Network Advertising Consumer Opt-Out
and/or the Digital Advertising Alliance Opt-Out.
2. Personal Information Received by Centilytics or Disclosed or Shared by Centilytics
Personal Information is collected to facilitate the Services offered, for marketing of our services and
products, or for internal analysis relating to product improvements and data security. Centilytics shares
Personal Information with only those contractors, service providers and other third parties who are bound
by contractual obligations to keep Personal Information confidential and to limit such use only for the
purpose for which it is disclosed. Personal Information collected is processed by the following service
providers to facilitate provision of the Services on the Platform or as otherwise disclosed at the time of
collection to:
Provide Services. Personal Information is used to:
• Provide, operate and improve the Platform and Services;
• Process payments and complete transactions;
• Update you and provide marketing communications about new features and services;
• Respond to inquiries and provide customer support and feedback;
• Detecting, preventing, and investigating security incidents that compromise the availability,
authenticity, integrity or confidentiality of stored or transmitted personal information;
• Protecting against malicious, deceptive, fraudulent or illegal activity directed at Centilytics;
• Debugging to identify and repair errors that impair existing intended functionality;
• Analyze data to assess, understand and improve the services and personalize user experiences,
including creation of anonymized aggregated, statistical and benchmark data. Aggregated data is
utilized to help develop and market products or services and present targeted content and advertising;
• Enable functionality of the services to authenticate a user, prevent fraud, and implement security
measures; and
• Undertaking activities to verify or maintain the quality of a service or product that is developed or
provided, and to improve, upgrade, or enhance any service or product that is developed or provided
by Centilytics.
Share with Service Providers. Centilytics has engaged with third party service providers to facilitate the
Centilytics services and operate our business, including without limitation, data base management hosting,
information technology, email/SMS delivery, customer support, analytics, data security and compliance
services necessary to provide the Services. For each service provider, Centilytics will have in place written
contracts that describes the purpose of the service and disclosure of Personal Information, and requires the
service provider to both keep the Personal Information confidential and not use it for any purpose except
performing the services pursuant to such contract.
SMS Notifications – Notice & Consent. Centilytics utilizes a third party service provider to enable SMS
notifications to its customers and its authorized users (as defined in the applicable Terms of Service or
Services Agreement). You consent to receive recurring text messages relating to the Services to the mobile
number associated with your account or otherwise provided to Centilytics. You understand and agree that
text messages sent to your mobile number may be generated using automated technology. Message and data
rates may apply. Reply STOP to opt-out or HELP for info. Consent is not a condition of any purchase.
Analytics: Centilytics uses the following third party analytics services:
● Google Analytics: Centilytics utilizes Google Analytics for data analytics to generate insights and
recommendations. For more information please see Google’s Privacy Policy. However, if you do
not want your Personal Information to be used by Google Analytics, you may opt-out by installing
Google Analytics Opt-out Browser Add-on.
● Location API. Centilytics utilizes IPInfo.io for generalized location analytics for purposes of
improving the services. Please see the IPInfo.Com Privacy Policy.
● Amazon SDK. Centilytics uses Amazon SDK to track usage, obtain aggregate metrics, generate
data visualizations, and identify meaningful patterns. Users should click the AWS Privacy Policy
hyperlink for more information about their data collection and privacy policies.
Compliance and Protection. Personal Information may be disclosed to serve our legitimate business
interests as follows: (1) as required by law, such as to comply with a subpoena, or similar legal process,
(2) if Centilytics is involved in a merger, acquisition, or sale of all or a portion of its assets, (3) to
investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government
enforcement agencies; (4) enforce our agreements with you, and/or (5) investigate and defend ourselves
against any third-party claims or allegations. We will use commercially reasonable efforts to notify you
about law enforcement or court ordered requests for data unless otherwise prohibited by law.
3. Personal Information of Minors
Centilytics does not knowingly collect Personal Information from anyone under the age of 16. If we learn
we have collected or received Personal Information from anyone under the age of 16 without verification of
parental consent, we will delete that information. If a parent or guardian becomes aware that his or her child
under the age of 16 has provided Centilytics with Personal Information without their consent, he or she
should contact Centilytics at info@centilytics.com. Centilytics will delete such Personal Information from
our files within a commercially reasonable time, but no later than required under the applicable law.
4. Retention and Deletion of Personal Information; De-Identified Data
Unless erasure is otherwise requested under applicable law or as otherwise stated in this Privacy Policy,
Centilytics will retain account data as long as it is necessary to provide services to our customers. Personal
Information obtained from Platform visitors will be maintained as long as it is necessary to provide requested
communications and information-based services or until a visitor exercises the right to opt-out of requested
communications or information-based services. Anonymized and pseudo-anonymized data will be retained
as long as Centilytics determines such data is commercially necessary for its legitimate business interests.
To the extent Centilytics de-identifies any Personal Information, Centilytics shall maintain and use such de-
identified data without attempting to re-identify the data.
5. Centilytics’ Security Practices.
We have implemented reasonable administrative, technical and physical security measures to protect
Personal Information against unauthorized access, destruction or alteration. However, although we endeavor
to provide reasonable security for Personal Information we process and maintain, no security system can
ever be 100% secure.
6. Response To “Do Not Track” Signals
Do Not Track” is a feature enabled on some browsers that sends a signal to request that a website disable its
tracking or cross-website user tracking.
Centilytics shall treat any user-enabled Global Privacy Control, such as a browser plug-in or privacy setting,
device setting, or other mechanism, that communicate or signal the consumer’s choice to opt-out of the sale
of their Personal Information as a valid request submitted pursuant to the CCPA for that browser or device,
or, if known, for the consumer.
7. Changes to this Privacy Policy
If we make material changes to our Privacy Policy, we will notify you by (i) changing the Effective Date at
the top of the Privacy Policy, or (ii) sending an electronic notification to all active account holders, or (iii)
adding a banner/notification to the Site itself.
8. Supplemental U.S. State-Specific Notices – Notice of Collection
This supplemental notice sets forth the disclosures and rights applicable to residents of California, Colorado,
Virginia, Connecticut, and Utah. Such consumer privacy notices and rights shall also apply to other state
residents to the extent other state consumer privacy laws are implemented following the last effective update
to this Privacy Policy.
Centilytics collects, uses and/or discloses Personal Information as follows:
Personal Information Collected, Used and/or Disclosed in Preceding 12 Months
Category of Personal
Information Collected
Categories
of Source of
Collection
Purpose of Use
Categories to
Whom
Centilytics
Discloses
Personal
Information
Purpose of
Disclosure
Identifiers & Personal
Information
• Name/Alias
User
Performing Services;
Security
Service
Provider
Performing
Services;
Security
• Email
User
Performing Services;
Security
Service
Provider
Performing
Services;
Security
• Address
User
Performing Services;
Security
Service
Provider
Performing
Services;
Security
• Cell or Telephone #
User
Performing Services;
Security
Service
Provider
Performing
Services;
Security
• Unique/Online ID
(cookies)
Device
Performing Services;
Security;
Auditing;
Debugging
Service
Provider
Performing
Services;
Security;
Auditing;
Debugging
• Generalized
Geolocation Data
Device
Performing Services
Service
Provider
Performing
Services
Centilytics does not retain a consumer's Personal Information for longer than is reasonably necessary
for each disclosed purpose.
Other Potential Disclosures: Personal Information may also be disclosed to serve our legitimate business
interests as follows: (a) as required by law, such as to comply with a subpoena, or similar legal process, (b)
as part of a merger, acquisition, bankruptcy or other transaction in which a third party assumes control of all
or part of the business, (c) to investigate, prevent, or take action regarding suspected or actual illegal
activities or to assist government enforcement agencies as required by law; (d) enforce our agreements with
you, and/or (e) investigate and defend ourselves against any third-party claims or allegations.
A. Sale of Personal Information; Sharing of Personal Information; Right to Opt-Out
Centilytics does not and will not sell your Personal Information. However, under the CCPA, some
sharing of personal information necessary to provide you with personalized ads may be considered
a “sale,” even if no money is exchanged.
Centilytics does not share Personal Information with third parties for cross-context behavioral
advertising purposes.
To the extent Centilytics is regarded as “selling” your personal information (as the term “sell” is
defined under the CCPA), you have the right to opt-out of that “sale” on a going-forward basis at
any time. Certain state residents have a right to opt-out from the “sale” or “sharing” of your personal
information with third parties who are not our service providers (as those terms are defined by
applicable laws) and/or to opt out of cross-context behavioral advertising. To exercise this right,
click the Do Not Sell or Share My Personal Information link on the bottom of the Platform page
where your information is being collected or go to your account settings. You can also submit a
request to opt-out by emailing us at info@centilytics.com with the subject line “Do Not Sell or
Share.” Finally, if your browser supports it, you can turn on the Global Privacy Control to opt-out
of the “sale” or “sharing” of your personal information.
B. Collection of Sensitive Information
Centilytics does not collect Sensitive Information
C. Consumer Rights. Consumers may contact Centilytics to exercise the following consumer
rights:
1. Request Centilytics Disclose At No Charge (“Right to Know”):
• Specific pieces of personal information it has collected about you;
• categories of Personal Information collected, used, and/or disclosed about you;
• categories of sources from which Personal Information is collected;
• business and/or commercial purposes for collecting and disclosing your Personal Information;
• categories of third parties with whom your Personal Information has been disclosed/shared; and
Right to Know Requests can be submitted to Centilytics by email at info@centilytics.com.
2. Request Centilytics to Delete At No Charge (“Right to Delete”):
Deletion Requests can be submitted to Centilytics by email at info@centilytics.com or by mail to
Centilytics at: Centilytics, Inc., Attention: Privacy Request to Delete, 2711 Center Ville Road,
Suite 400 Wilmington, Delaware, 19808 or by email at: info@centilytics.com.
D. Request Centilytics Correct At No Charge (“Right to Correct”):
Requests that Centilytics correct any inaccurate Personal Information collected by Centilytics can
be submitted by email to info@centilytics.com
E. Verified Request Process
Centilytics will verify all consumer requests prior to taking any action in response to such request.
For consumers that maintain an account with Centilytics, it may verify the identity of the consumer
making the request by either matching information with the account information on file or through
existing account authentication credentials.
Under applicable state law, you may exercise these rights yourself or you may designate an
authorized agent to make these requests on your behalf. Authorized agents must demonstrate they
have written authorization from you to make requests on your behalf. Centilytics may additionally
require the consumer to confirm their identity and verify the authorized agent’s permission before
complying with any request.
F. Consumer Request Limitations
Please note that these rights are not absolute and in certain cases are subject to conditions or limitations
as specified in the applicable state laws, including, but not limited to:
• Centilytics is obligated to disclose/delete only upon a verifiable Consumer request from the
consumer or an authorized agent acting on behalf of Consumer.
• Consumers may only make a personal information request twice in a 12-month period.
• Deletion is not required if it is necessary for Centilytics to maintain the Personal Information to
fulfill applicable permissible purposes enumerated pursuant to applicable state consumer
privacy laws.
Centilytics will confirm and respond to all requests within the timeframe required under applicable state
law. In responding to any request to disclose/delete, Centilytics shall maintain a record of the requests
as required under applicable state law.
G. Non-Discrimination Policy
You have the right not to receive discriminatory treatment for exercising any rights conferred by the
CCPA and VCDPA. Centilytics shall not discriminate against a consumer for exercising any statutory
consumer privacy rights, including, but not limited to, (a) denying goods or services, (b) charging
different prices or rates (including discounts/penalties) that is not directly related to the value provided
to Centilytics for the Personal Information, (c) suggesting Consumer will receive a different rate/price
or different level of quality of goods/services, or (d) providing a different level of quality of goods/
services.
Employees, applicants and independent contractors have the right not to be retaliated against for the
exercise of their CCPA rights.
H. Your Virginia Privacy Rights under VCDPA
If Centilytics is unable to process requests relating to your Personal Information and denies your
request, Virginia residents have the right to appeal by emailing Centilytics at info@centilytics.com.
Centilytics will respond to your appeal request within 60 days of receiving the request to appeal.
I. Your California Privacy Rights under California Civil Code Section 1798.83 & Business and
Professions Code Section 22581
California law permits Consumers to request and obtain from Centilytics once a year, free of charge,
certain information about their Personally Identifiable Information (“PII”) (as defined by California law)
disclosed to third parties for direct marketing purposes in the preceding calendar year (if any). If
applicable, this information would include a list of the categories of PII that was shared and the names
and addresses of all third parties with which we shared information in the immediately preceding
calendar year.
In addition, a business subject to California Business and Professions Code Section 22581 must allow
California residents under age 18 who are registered users of online sites, services or applications to
request and obtain removal of content or information they have publicly posted. Your request should
include a detailed description of the specific content or information to be removed. Please be aware that
your request does not guarantee complete or comprehensive removal of content or information posted
online and that the law may not permit or require removal in certain circumstances.
J. Accessibility of this Policy.
• You can download and print a copy of this Notice here.
K. Contact Us
If you have any questions regarding your Personal Information or about our privacy practices, please
contact us at: Centilytics, Inc., Attention: Privacy Department, 2711 Center Ville Road, Suite 400
Wilmington, Delaware, 19808 or by email at: info@centilytics.com.
8. Applicable EU GDPR Notices
Data Processor. Centilytics is the processor of all Personal Data (as defined by applicable law) in
connection with a Customer’s use of the Centilytics Services. Centilytics’ Data Protection Offer can be
reached at Centilytics, Attention: Privacy Department, 2711 Center Ville Road, Suite 400 Wilmington,
Delaware, 19808. You may contact us at any time through by emailing us at info@centilytics.com
For applicable EU Users, we will only collect and process Personal Data about you where we have lawful
bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary
for the performance of a contract with you, and “legitimate interests.” Where we rely on your consent to
process Personal Data, you have the right to withdraw or decline your consent at any time and where we rely
on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon
which we collect and use your Personal Data, please submit a request through email Centilytics at
info@centilytics.com
When we transfer Personal Data of data subjects from the European Economic Area ("EEA"), Switzerland
or the United Kingdom ("UK"), we will enter into a Data Processing Agreement with customers
incorporating current Standard Contractual Clauses and the UK Addendum. We also implement additional
safeguards where appropriate, such as commercial industry standard secure encryption methods to protect
customer data at rest and in transit and other appropriate contractual and organizational measures to ensure
the confidentiality, integrity and security of a customer’s Personal Data.
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of
Supervisory Authorities is available here: http://ec.europa.eu/justice/data-
protection/bodies/authorities/index_en.htm. If you need further assistance regarding your rights, please
contact us using the contact information provided below and we will consider your request in accordance
with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations
to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or
legal requirements, or because processing is necessary to deliver the services you have requested. Where
this is the case, we will inform you of specific details in response to your request.
How to Review, Transfer, Restrict the Use of or Request Erasure of Personal Data
IF YOU WOULD LIKE TO:
● Access, review, restrict processing of, or otherwise request erasure of your Personal Data
● Obtain the identity of the source of any Personal Data collected;
● Request correction of any errors contained within your Personal Data;
● Request Centilytics transfer your Personal Data to another service provider;
● Object to the manner in which your Personal Data is processed;
● Lodge a complaint with an EU supervisory authority; or
● Withdraw consent to the collection of your Personal Data
Requests under this Section can be made through email at info@centilytics.com. We will respond in the
timeframes required under applicable law. For all requests made pursuant to this section, Centilytics will (a)
respond as required under applicable law, (b) provide a copy of any requested Personal Data in a structured,
commonly used and machine-readable format, and/or (c) transmit such Personal Information to another
service provider without restriction in accordance with applicable law
9. Contact Us
If you have any questions regarding your Personal Information or about our privacy practices, please contact
us at: Centilytics, Inc., Attention: Privacy Department, 2711 Center Ville Road, Suite 400 Wilmington,
Delaware, 19808 or by email at: info@centilytics.com.
This Privacy Policy was last updated on May 10, 2023
