CCPA Compliance Policy

Effective date: 09.09.2025

1. Introduction

This California Consumer Privacy Act (CCPA) Compliance Policy applies to residents of California whose personal information is collected by IntraconIX Group ("Company," "we," "us," or "our") in the course of our business operations.

This policy supplements our general Privacy Policy and Terms & Conditions with specific disclosures and rights provided under the California Consumer Privacy Act of 2018 (Cal. Civ. Code § 1798.100 et seq.) and its implementing regulations, as amended by the California Privacy Rights Act (CPRA).

2. Scope and Applicability

2.1 Who This Policy Covers

This policy applies to:

California residents acting as individuals
California residents acting on behalf of businesses (in B2B contexts)
Authorized agents acting on behalf of California consumers
Households of California residents (where applicable)

2.2 When This Policy Applies

When we collect personal information from California residents
When we process California residents' personal information
When California residents exercise their CCPA rights

2.3 Relationship to Other Policies

This CCPA Policy should be read in conjunction with:

Our general Privacy Policy
Our Terms and Conditions
Any service-specific privacy notices

3. Personal Information We Collect

3.1 Categories of Personal Information Collected

In the last 12 months, we have collected the following categories of personal information:

A. Identifiers

Real name, Email address, Postal address, Phone number, Account name, IP address, Unique personal identifier, Online identifier

B. Personal Information under Cal. Civ. Code § 1798.80(e)

Name, Address, Telephone number, Employment, Employment history, Financial information (payment card numbers, account numbers)

C. Protected Classification Characteristics

We do not intentionally collect this information. May be incidentally collected if voluntarily provided.

D. Commercial Information

Records of products or services purchased, Purchase history, Transaction information, Service preferences

E. Biometric Information

We do not collect biometric information.

F. Internet or Network Activity

Browsing history on our website, Search history on our services, Interaction with our website or services, Browser type and settings, Operating system

G. Geolocation Data

Approximate location from IP address. We do not collect precise geolocation data.

H. Sensory Information

Audio from recorded business calls (with notice). We do not collect other sensory information.

I. Professional or Employment Information

Current employer, Job title, Business contact information, Professional qualifications, Work history (if provided for services)

J. Education Information

We do not typically collect education information. May be provided in professional contexts.

K. Inferences

Preferences derived from above categories, Characteristics, Behaviors, Attitudes, Abilities, Aptitudes

3.2 Sensitive Personal Information

We do not intentionally collect sensitive personal information as defined by CPRA. If sensitive information is required for specific services (e.g., AML/KYC compliance), we will provide additional notice.

4. Sources of Personal Information

We collect personal information from the following sources:

Directly from You (e.g., forms, orders, communications)
Automatically (e.g., website interactions, cookies)
From Third Parties (e.g., payment processors, business partners)
From Your Business (e.g., your employer for B2B services)

5. How We Use Personal Information

5.1 Business Purposes

We use personal information for Operations (providing services), Security and Legal (detecting incidents, compliance), Commercial (marketing, analytics), and Internal (auditing, R&D) purposes.

5.2 Commercial Purposes

We may use personal information for direct marketing, limited cross-context behavioral advertising, and personalization of services.

6. Disclosure of Personal Information

We share information with Service Providers, Professional Advisors, Government and Legal entities, Business Partners, and in the event of Business Transfers. In the preceding 12 months, we have disclosed Identifiers, Commercial information, Internet activity, Professional information, and Inferences for business purposes.

We do not sell personal information. We engage in limited sharing for cross-context behavioral advertising, which you may opt-out of.

7. Your Rights Under CCPA

Right to Know / Access: You can request the categories and specific pieces of personal information we have collected.
Right to Delete: You can request the deletion of your personal information, subject to legal exceptions.
Right to Opt-Out of Sale/Sharing: You can opt-out via a "Do Not Sell or Share" link, email, or Global Privacy Control signals.
Right to Correct: You can request the correction of inaccurate personal information.
Right to Limit Use of Sensitive Personal Information: You can limit how we use your sensitive data.
Right to Non-Discrimination: We will not discriminate against you for exercising your rights.

8. How to Exercise Your Rights

Submit requests via email to privacy@intraconix.com or through the web form on our website. We will verify your identity before processing your request. We will acknowledge your request within 10 days and respond within 45 days.

9. Financial Incentives and Loyalty Programs

We may offer financial incentives like referral programs or loyalty discounts. Participation is voluntary, and you can withdraw at any time.

10. Notice of Collection

We provide a notice at or before the point of collection detailing the personal information we collect and the purposes for which it is used.

11. Data Retention

We retain personal information based on the purpose of collection, legal requirements, and business needs. For example, transaction records are kept for 7 years for tax purposes.

12. Cookies and Tracking Technologies

We use essential, analytics, and marketing cookies. You can manage these through your browser settings, our cookie preference center, or Global Privacy Control.

13. Information Security

We implement administrative, technical, and physical safeguards, including encryption and access controls, to protect your information.

14. Special Considerations

We do not knowingly collect information from minors under 16. The full rights of the CCPA apply in B2B contexts.

15. Metrics and Reporting

If applicable, we will report annual metrics regarding consumer rights requests.

16. Contact Information

For privacy inquiries, please email privacy@intraconix.com. For data protection matters, contact dpo@intraconix.com.

17. Updates to This Policy

This policy is reviewed annually. Material changes will be communicated via our website and email to registered users.

18. California Shine the Light

California residents may request information about our disclosure of personal information to third parties for their direct marketing purposes by contacting us at privacy@intraconix.com.

19. Accessibility

This policy is available in alternative formats upon request. Contact privacy@intraconix.com for accessibility needs.

20. Compliance Disclosure

IntraconIX Group maintains a comprehensive CCPA compliance program, which is regularly reviewed and aligned with current regulations and best practices.

Document Version: 1.0
Last Updated: September 25, 2025
Legal Framework: California Consumer Privacy Act (Cal. Civ. Code § 1798.100 et seq.), as amended by CPRA
Questions: privacy@intraconix.com