Privacy Policy — Ceviche

California Notice at Collection / State Privacy Rights Notice: see the State privacy rights notice section below for important information about your rights under applicable state privacy laws.

Ceviche, Inc. (“Ceviche,” “we,” “us,” or “our”) provides an AI-powered fund expense allocation platform for private fund CFOs, controllers, and finance teams. This Privacy Policy describes how Ceviche processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including, as applicable, our website at www.ceviche.ai and our social media pages), as well as our marketing activities, live events, and other activities described in this Privacy Policy (collectively, the “Service”).

Personal information we collect

Information you provide to us

Personal information you may provide to us through the Service or otherwise includes:

Contact data, such as your first and last name, salutation, email address, mailing address, professional title and company name, and phone number.
Demographic data, such as your city, state, country of residence, and postal code.
Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources

We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
Data providers, such as information services and data licensors.
Partners, such as marketing partners and event co-sponsors.
Customers.
Service providers that provide services on our behalf or help us operate the Service or our business.
Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction. For example, we may receive your personal information from an entity we acquire or are acquired by, a successor, or assignee or any party involved in a business transaction such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.

Automatic data collection

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications, and other online services, such as:

Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, and general location information such as city, state, or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
Communication interaction data, such as your interactions with our email or other communications (e.g., whether you open and/or forward emails). We may do this through use of pixel tags (also known as clear GIFs), which may be embedded invisibly in our emails.

For more information concerning our automatic collection of data, please see the Tracking technologies section below.

Tracking technologies

Some of our automatic data collection is facilitated by cookies and other technologies. For more information, including your choices with respect to these technologies, see our Cookie Notice.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations

provide the Service;
enable security features of the Service;
communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages; and
provide support for the Service, and respond to your requests, questions, and feedback.

Service personalization

understand your needs and interests;
personalize your experience with the Service and our Service-related communications; and
remember your selections and preferences as you navigate webpages.

Service improvement and analytics

We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites at tools.google.com/dlpage/gaoptout.

Marketing

Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt out of our marketing communications as described in the Opt-out of communications section below.

Events. We may use your personal information to communicate with you about events in which you participate, or to contact or market to you after collecting your personal information at an event.

Compliance and protection

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations, or requests from government authorities;
protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

To create aggregated, de-identified and/or anonymized data

We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you, and we will not attempt to reidentify any such data. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including analyzing and improving the Service and promoting our business.

Further uses

In some cases, we may use your personal information for further uses, in which case we will ask for your consent to use your personal information for those further purposes if they are not compatible with the initial purpose for which the information was collected.

Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, establishing or defending legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

How we share your personal information

We may share your personal information with the following parties (or as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection):

Affiliates. Our corporate parent, subsidiaries, and affiliates.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research, and website analytics).
Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.
Partners. Third parties with whom we partner, including parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Ceviche, financing of Ceviche, public stock offerings, or the sale, transfer, or merger of all or part of our business, assets, or shares). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Ceviche as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Your choices

In this section, we describe the rights and choices available to all users. Users who are located in certain U.S. states can find additional information about their rights below.

Opt-out of communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Cookies and other technologies. For information about cookies and other technologies employed by the Service and how to control them, see our Cookie Notice.
Blocking images/clear GIFs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications, or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.

Security

We employ technical, organizational, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

If you have questions about our practices or if you would like to exercise any privacy-related right that may be available to you, please contact us via one of the methods listed below.

Email: operations@ceviche.ai
Mail: Ceviche, Inc., 169 Madison Ave STE 2511, New York, NY 10016

State privacy rights notice

Except as otherwise provided, this section applies to residents of U.S. states to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively, the “State Privacy Laws”). This section describes how we collect, use, and share Personal Information of residents of these states and the rights these users may have with respect to their Personal Information. Please note that not all rights listed below may be afforded to all users, and if you are not a resident of one of these states, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it.

For purposes of this section, the term “Personal Information” has the meaning given to “personal data,” “personal information,” or other similar terms, and “Sensitive Personal Information” has the meaning given to “sensitive personal information,” “sensitive data,” or other similar terms in the State Privacy Laws, except that in neither case does such term include information exempted from the scope of the State Privacy Laws.

Your privacy rights

The State Privacy Laws may provide residents with some or all of the rights listed below. However, these rights are not absolute and some State Privacy Laws do not provide these rights to their residents, so we may decline your request in certain cases as permitted by law.

Information. You can request the following information about how we have collected and used your Personal Information: the categories of Personal Information that we have collected; the categories of sources from which we collected Personal Information; the business or commercial purpose for collecting Personal Information; the categories of third parties with which we share Personal Information; and the categories of Personal Information that we disclosed for a business purpose.
Access. You can request a copy of the Personal Information that we have collected about you.
Appeal. You can appeal our denial of any request validly submitted.
Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
Deletion. You can ask us to delete the Personal Information that we have collected from you.
Targeted advertising. We do not process your Personal Information for targeted advertising purposes.
Profiling and automated decision-making. We do not use your Personal Information to engage in profiling or to perform automated decision-making that results in significant financial impacts, significant impacts on housing, education, employment, health care, or criminal justice, or similarly significant impacts.
Sale of Personal Information. We do not sell your Personal Information within the meaning of the State Privacy Laws.
Consumers under 16. We do not have actual knowledge that we collect, sell, or share the personal information of consumers under 16 years of age.
Sensitive Personal Information. We do not intentionally collect or process Sensitive Personal Information.
Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.

Opt-out preference signals (Global Privacy Control)

We do not sell or share your Personal Information within the meaning of the State Privacy Laws. To the extent any State Privacy Law nonetheless requires us to honor opt-out preference signals, we honor the Global Privacy Control (“GPC”) signal as a valid opt-out request as required by applicable law.

Exercising your state privacy rights

You may submit requests to exercise any of the state privacy rights listed above via email to operations@ceviche.ai.

Verification of identity; authorized agents

We may need to verify your identity in order to process your access, appeal, correction, or deletion requests, and we reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law. Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf, and may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized.

Information practices

The following describes our practices currently and during the past 12 months. We collect the categories of personal information described in the “Personal information we collect” section above (contact data, demographic data, communications data, marketing data, and device and online activity data, which correspond to the CCPA statutory categories of identifiers, professional or employment-related information, commercial information, and internet or other electronic network activity information) from the sources and for the business and commercial purposes described above in this Privacy Policy. We disclose these categories for business purposes to the categories of third parties described in the “How we share your personal information” section above (service providers, professional advisors, authorities, and business transferees). We do not sell or share any category of Personal Information. The criteria for deciding how long to retain personal information are described in the Retention section above. We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.

Additional information for California residents

Shine the Light law. Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family, or household purposes to provide the names of third parties to which they have disclosed certain personal information during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to operations@ceviche.ai. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency.

Additional information for Nevada residents

Nevada residents have the right to opt out of the sale of certain personal information for monetary consideration. While we do not currently engage in such sales, if you are a Nevada resident and would like to make a request to opt out of any potential future sales, please email operations@ceviche.ai.

If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the How to contact us section above.