Thank you for visiting the Company’s website, and, as applicable now or in the future, the Company’s app(s) (including mobile apps), blog(s), social media site(s) or otherwise interacting with the Company via e-mail.  In this Privacy Statement, our website, app(s) (including mobile apps), blog(s), social media site(s) or email interactions are collectively referred to as our “Media”, and this Privacy Policy applies to all of our Media and your interaction with the Company in its Media.  It is our hope and commitment that you feel completely at ease and secure in your interactions with us, and that you will trust the Company to respect your privacy.  So, we at the Company have created this Privacy Statement (sometimes referred to as this “Policy”) to advise you about our guidelines concerning the use of your personal information, and to explain the efforts that the Company is making to protect your personal information accordingly.

The Company may need to change this Policy from time to time to address new privacy or other matters and/or to reflect changes to our Media. The Company will post such changes in this Policy so that you are updated regarding what information gather, how the Company may gather that information, how the Company may use that information and whether the Company will disclose that information to anyone.  It is advisable, therefore, to refer back to this Policy from time to time.

If you have any questions or concerns about our privacy policy, please send an e-mail to info@carobway.com.

At the Company, we understand that protecting the privacy of visitors to our Media is very important and that certain information that the Company requests of you or that you provide may be sensitive. That’s why the Company has taken reasonable steps to treat your personal information in accordance with the Company’s high standards, and consistent with applicable local laws that regulate the storage, process, access and transfer of personal information.

Scope of this Policy

In the event that the Company’s Media displays this Policy and asks you for any information, you are here advised that the Company is committed to collecting, maintaining, and securing personal information about you in accordance with this Privacy Policy, as well as applicable laws, rules and regulations.  This Policy applies to personal information (as defined below) collected from the Company Media (i.e., online resources and communications such as our Website, App(s), or via e-mail, and other online tools) that display a link to this Policy. This Policy does not apply to personal information collected from offline resources and communications, except in cases where such personal information is part of the personal information collected by the Company online. This Policy also does not apply to third-party online resources to which the Company’s Media may link, where the Company does not control the content or the privacy practices of such resources.

The Company only collects personally identifiable information about you if you choose to disclose it. The Company does not share any of your personally identifiable information with third parties for their own marketing use unless you explicitly give the Company permission to do so. Please review this Privacy Statement to learn more about how the Company collects, uses, shares and protects information online.

Information Collected

Generally, the Company uses two methods to collect information from you online.  Information that the Company obtains is comprised of:

• Personal identifiable information: You can visit our Media without providing any personal information. The Company may collect your personally identifiable information (such as name, address, telephone number, e-mail address or other identifying information) only when you choose to submit it to us.
• Aggregate information: In some cases, the Company also removes personal identifiers from data you provide to the Company and maintain it in aggregate form. The Company may combine this data with other information to produce anonymous, aggregated statistical information (g. number of visitors, originating domain name of the Internet Service Provider), helpful to the Company in improving our products and services.

Automatically Collected Non-Personal Information

The Company and some third-party providers that work with the Company automatically receive certain types of information whenever you interact with the Company. on its sites and in some e-mails, we may send each other. Automatic technologies and services the Company uses may include, for example, Web server logs/IP addresses, cookies, Web beacons and third-party application and content tools.

Web Server Logs/IP Addresses. An IP address is a number assigned to your computer or mobile whenever you access the Internet. All computer identification on the Internet is conducted with IP addresses, which allow computers and servers to recognize and communicate with each other. The Company collects IP addresses to conduct system administration and report aggregate information to affiliates, business partners and/or vendors to conduct site analysis and Media performance review.

Cookies. A cookie is a piece of information that is placed automatically on your computer’s hard drive when you access certain web sites. The cookie uniquely identifies your browser to the server. Cookies allow the Company to store information on the server to help make the Web experience better for you and to conduct site analysis and web site performance review. Most Web browsers are set up to accept cookies, although you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you refuse cookies.

Web Beacons. On certain Web pages or e-mails, The Company may utilize a common Internet technology called a “Web beacon” (also known as an “action tag” or “clear GIF technology”). Web beacons help analyze the effectiveness of web sites by measuring, for example, the number of visitors to a site or how many visitors clicked on key elements of a site.

Web beacons, cookies and other tracking technologies do not automatically obtain personally identifiable information about you. Only if you voluntarily submit personally identifiable information, such as by registering or sending e-mails, can these automatic tracking technologies be used to provide further information about your use of the web sites and/or interactive e-mails to improve their usefulness to you.

Opting in or Opting Out – Your Choices

You have several choices regarding your use of our Media. You could decide not to submit any personally identifiable information at all by not entering it into any forms or data fields on our sites and not using any available personalized services. Certain sites may ask for your permission for certain uses of your information and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, the Company will work to remove your information promptly, although the Company may require additional information before the Company can process your request.

As described above, if you wish to prevent cookies from tracking you anonymously as you navigate the Company’s Media, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent.

Security

The Company uses technology and security precautions, rules and other procedures to protect your personal information from unauthorized access, improper use, disclosure, loss or destruction. To ensure the confidentiality of your information, The Company uses also industry standard firewalls and password protection. It is, however, your personal responsibility to ensure that the computer or mobile device you are using is adequately secured and protected against malicious software, such as Trojans, computer viruses and worm programs. You are aware of the fact that without adequate security measures (e.g. secure web browser configuration, up-to-date antivirus software, personal firewall software, no usage of software from dubious sources) there is a risk that the data and passwords you use to protect access to your data, could be disclosed to unauthorized third parties.

Use of Data

The Company will use any personally identifiable information you choose to give the Company to comply with your requests. The Company will retain control of and responsibility for the use of this information. Some of this data may be stored or processed at computers located in other jurisdictions, such as the United States, whose data protection laws may differ from the jurisdiction in which you live.

The information will be helpful for the Company to better understand your needs and how the Company can improve our products and services. It helps the Company also to personalize certain communications with you about services and promotions that you might find interesting.

As explained above, the Company may also aggregate personal data without any identifying tags and/or non-personal data collected from you as described above to enable our own or third party scientific studies to better understand and help our end-users.  This use of data will be non-personal, which is to say that it will not identify the data with any of your personal information.

Data Sharing and Transfer

The Company may share personally identifiable data about you with various outside companies or agents doing technological maintenance or working on our behalf to help fulfill business transactions, such as providing customer services, sending marketing communications about our products, services and offers. All these companies and agents are required to comply with the terms of our privacy policies. The Company may also disclose personally identifiable information for these purposes:

1. to respond to appropriate requests of legitimate government agencies or where required by applicable laws, court orders, or government regulations; or
2. where needed for corporate audits or to investigate or respond to a complaint or security threat.

No Third-Party Direct Marketing Use. The Company will not sell or otherwise transfer the personally identifiable information you provide to the Company through its Media to any third parties for their own direct marketing use unless the Company provides clear notice to you and obtains your explicit consent for your data to be shared in this manner.

E-mail a Friend or Colleague. On some of the Company’s Media, you may choose to send a link or a message to a friend or colleague referring them to the Company Media. E-mail addresses you may provide for a friend will be used to send your friend information on your behalf and will not be collected or used by the Company or other third parties for additional purposes.

Google Analytics, SimilarWeb or Alexa. The Company’s Media may use Google Analytics, a web analytics service provided by Google, Inc. or other similar tools, such as SimilarWeb or Alexa (collectively, “Analytics”).  Analytics use “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Analytics providers on servers in the United States of America or elsewhere. Analytics providers will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Analytics providers may also transfer this information to third parties where required to do so by law, or where such third parties process the information on behalf of the Analytics providers. Analytics providers will not associate your IP address with any other data held by them You may refuse the use of cookies by selecting the appropriate settings on your browser, however, as mentioned above please note that if you do this you may not be able to use the full functionality of the Company Media. By using the Company Media, you consent to the processing of data about you by Analytics providers in the manner and for the purposes set out above.

Links to Other Sites

Our sites contain links to a number of web sites and Social Media such as Facebook, Twitter and more that may offer useful information to our visitors. This Privacy Statement does not apply to those sites, and the Company recommends communicating to them directly for information on their privacy policies.

Privacy Statement for Children

Our Media are directed at an adult audience. The Company does not collect any personally identifiable information from anyone the Company knows to be under the age of 13 without the prior, verifiable consent of his or her legal representative. Such legal representative has the right, upon request, to view the information provided by the child and/or to require that it be deleted.

Additional Information on Web Sites

If a web site has particular provisions relating to privacy that differ from those stated here, those provisions will be disclosed to you on the page on which personally identifiable information is collected.

Note to Users of Business or Professional Web Sites

If you have a business or professional relationship with the Company, the Company may use information you submit on the Company’s sites, including sites intended specifically for business and professional users, to fulfill your requests and develop our business relationship with you and the entities you represent. The Company may also share such information with third parties acting on our behalf.

How to Contact The Company

For questions or if you wish The Company to amend or delete your profile, please contact the Company in writing (by email) to info@carobway.com.

Unless explicitly stated otherwise, this Privacy Policy applies to all the Company’s Media.

Dated: April 30, 2023