Privacy Policy

1. Introduction

This Privacy Policy describes how Vailent Inc. (“we,” “us,” or “our”) collects, uses, and protects information when you visit our website at vailent.com (the “Site”). This policy covers our public marketing pages. Those pages are informational in nature, provide an overview of our technology platform, and do not offer user accounts or e-commerce functionality.

We separately operate a secure investor data room at vailent.com/investors. It requires an account and is available only to invited investors. This policy does not cover the data room. If you have been given access to it and want to know what information we hold about you and how we use it, email us at privacy@vailent.com and we will tell you.

We are committed to transparency and to protecting your privacy in accordance with applicable data protection laws worldwide, including the European Union General Data Protection Regulation (GDPR), the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), the UK Data Protection Act 2018, Brazil’s Lei Geral de Proteção de Dados (LGPD), Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), and other relevant global privacy frameworks.

2. Information We Collect

2.1 Information Collected Automatically

When you visit our Site, certain information is collected automatically through third-party services embedded on our Site. These services and the data they collect are described below.

2.1.1 Google Analytics

We use Google Analytics, a web analytics service provided by Google LLC, which may collect the following information:

• ●IP address (which may be anonymized depending on your region)
• ●Browser type and version
• ●Operating system
• ●Device type (desktop, mobile, tablet)
• ●Referring URL and exit pages
• ●Pages viewed and time spent on each page
• ●Approximate geographic location (city/region level, derived from IP address)
• ●Language preferences

Google Analytics may use cookies or similar technologies to distinguish unique visitors. For more information about how Google processes this data, please refer to Google’s Privacy Policy and the Google Analytics Terms of Service.

2.1.2 RB2B

We use RB2B, a business-to-business visitor identification service provided by RB2B Inc. RB2B uses cookies, JavaScript, and similar tracking technologies to identify business visitors to our Site. This service may collect and match the following information:

• ●IP address
• ●Browser type, version, and settings
• ●Device and operating system information
• ●Pages visited and browsing behavior on our Site
• ●Professional contact information such as name, business email address, job title, and company name (matched from third-party data sources)
• ●LinkedIn profile URL and other publicly available professional information

RB2B identifies visitors by matching browsing data against its database of business professionals. This information is used solely for business-to-business lead identification and outreach purposes. For more information, please refer to RB2B’s Privacy Policy.

2.1.3 HubSpot

We use HubSpot, Inc. as our customer relationship management provider, and we run HubSpot’s website tracking code on our Site. Where you have consented to analytics storage, it may collect the following information:

• ●IP address
• ●Browser type and version, operating system, and device type
• ●Referring URL and the pages you view on our Site, including the order and timing of those views
• ●Approximate geographic location, derived from IP address
• ●A first-party cookie identifier that allows return visits from the same browser to be recognized as the same visitor

HubSpot sets cookies in your browser for this purpose. Where you later submit a form on our Site, HubSpot associates the browsing activity recorded under that cookie identifier with the details you submit, so that we can see how you found us and what you looked at before getting in touch. This tracking code is loaded only where you have consented to analytics storage, and it is not loaded in our investor data room. HubSpot’s own privacy notice is available at legal.hubspot.com/privacy-policy.

2.1.4 Microsoft Clarity

We use Microsoft Clarity, a website analytics service provided by Microsoft Corporation. Clarity records how pages are used so that we can see where a layout is confusing or a page is not working. Where you have consented to analytics storage, it may collect:

• ●IP address, browser type and version, operating system, and device and screen information
• ●Pages viewed, and the referring URL
• ●Mouse movement, clicks, taps, and scrolling
• ●Text you type into form fields on our Site, other than fields Clarity is configured to mask
• ●A recording of your session on our Site, and aggregated heatmaps built from many sessions

This is more intrusive than conventional analytics, so we want to be direct about it: Clarity reconstructs a playback of your visit. It is loaded only where you have consented to analytics storage, and it is never loaded in our investor data room. Microsoft may use the data it collects through Clarity for its own purposes as described in its privacy statement, available at privacy.microsoft.com/privacystatement.

2.2 Information You Provide Directly

If you choose to submit our access-request or contact form, we collect the information you enter: your name, business email address, company name, industry, and which of our solutions you are interested in.

We also record how you arrived at our Site alongside that submission, where this is available: the campaign parameters in the link you followed (for example a UTM-tagged link from a social post), the website that referred you, and the pages on which you entered the Site and submitted the form. This is stored in your browser’s session storage and is only recorded where you have consented to analytics storage. It is cleared when you close your browser.

Form submissions are sent to HubSpot, our customer relationship management provider, and are also stored in our own database so that a submission is never lost if that transfer fails. We use them only to respond to your enquiry.

2.3 Information We Do Not Collect

Beyond the form information described in 2.2, our public marketing pages do not collect, process, or store:

• ●Financial or payment information
• ●Login credentials or account information
• ●Social Security numbers or government-issued identifiers
• ●Sensitive personal data such as health, biometric, or genetic information
• ●User-generated content or file uploads

Cookies that may be present on the Site are those placed by Google Analytics and by HubSpot for analytics purposes, by Microsoft Clarity for measuring how pages are used, by RB2B for visitor identification purposes, and by our consent management platform to record the cookie choices you have made.

3. How We Use Collected Information

The information collected through our third-party services is used for the following purposes:

• ●Understanding visitor traffic patterns and trends
• ●Analyzing which pages and content are most relevant to our audience
• ●Improving Site performance, structure, and user experience
• ●Monitoring the technical health and uptime of the Site
• ●Reviewing recordings and heatmaps of Site usage to find layout, navigation, and usability problems
• ●Identifying business visitors for business-to-business lead generation and outreach

We do not use collected information for consumer advertising, automated decision-making that produces legal effects, or any purpose beyond the analytics and B2B lead identification functions described above.

4. Legal Basis for Processing (GDPR & UK GDPR)

For visitors located in the European Economic Area (EEA), the United Kingdom, or Switzerland, we process personal data under the following legal bases:

• ●Legitimate Interest (Article 6(1)(f) GDPR): We have a legitimate interest in understanding how visitors interact with our Site to improve its content and performance, and in identifying business visitors for B2B lead generation purposes. This interest is balanced against your rights and freedoms.
• ●Consent (Article 6(1)(a) GDPR): Where required by applicable law, we will obtain your consent before placing analytics cookies on your device. You may withdraw your consent at any time using the methods described in Section 7 of this policy.

5. Data Sharing and Third-Party Services

5.1 Google Analytics

Analytics data collected on our Site is processed by Google LLC and its affiliates. Google may process this data on servers located in the United States or other countries. Google’s processing of this data is governed by the Google Ads Data Processing Terms and Google’s Privacy Policy. We have configured Google Analytics to the extent commercially reasonable to minimize the collection of personal data, including enabling IP anonymization where supported by Google’s current analytics infrastructure.

5.2 RB2B

Visitor identification data collected on our Site is processed by RB2B Inc. RB2B may process this data on servers located in the United States. RB2B matches browsing activity against third-party databases of business professionals to provide us with identified visitor information. RB2B’s processing of this data is governed by RB2B’s Privacy Policy and Terms & Conditions.

5.3 HubSpot

We use HubSpot, Inc. as our customer relationship management provider. When you submit a form on our Site, the details you entered, together with the arrival information described in section 2.2, are transferred to HubSpot and stored in our HubSpot account so that a member of our team can respond to you. HubSpot acts as our processor and is contractually restricted to processing that information on our instructions.

We also run HubSpot’s website tracking code, which sets cookies in your browser and records your browsing on this Site where you have consented to analytics storage. Section 2.1.3 describes what that code collects and how it is linked to a form submission. HubSpot’s own privacy notice is available at legal.hubspot.com/privacy-policy.

5.4 Microsoft Clarity

Session recording and heatmap data collected on our Site is processed by Microsoft Corporation. Microsoft may process this data on servers located in the United States or other countries. Unlike our other providers, Microsoft does not act solely as our processor for this service: it may also use the data it collects through Clarity for its own purposes, including improving its products and services. Microsoft’s processing of this data is governed by the Microsoft Privacy Statement.

5.5 No Sale of Personal Information

We do not sell, rent, lease, or trade your personal information to third parties for their own marketing or commercial purposes. For purposes of the CCPA/CPRA, we do not “sell” personal information as that term is defined under California law. Information shared with our service providers (Google Analytics, RB2B, HubSpot, and Microsoft Clarity) is shared solely for the purposes described in this policy and is governed by our agreements with those providers.

5.6 Legal and Compliance Disclosures

We may disclose information if required to do so by law, regulation, legal process, or enforceable governmental request, or to protect the rights, property, or safety of Vailent Inc., our users, or the public.

6. International Data Transfers

Vailent Inc. is headquartered in Houston, Texas, United States. If you are accessing our Site from outside the United States, please be aware that information collected through Google Analytics, RB2B, HubSpot, and Microsoft Clarity may be transferred to and processed in the United States or other jurisdictions where these providers maintain data processing facilities.

Where you submit a form on our Site, the details you provide are transferred to HubSpot, Inc. (United States), which acts as our processor and hosts our customer relationship management system on our behalf. For transfers of personal data from the EEA, UK, or Switzerland, we rely on HubSpot’s Data Processing Agreement and its Standard Contractual Clauses.

For transfers of personal data from the EEA, UK, or Switzerland to the United States, we rely on Google’s compliance with applicable data transfer mechanisms, which may include the EU-U.S. Data Privacy Framework, Standard Contractual Clauses (SCCs), or other lawful transfer mechanisms as adopted by relevant authorities.

7. Your Rights and Choices

7.1 All Visitors

Regardless of your location, you have the following options to manage your privacy on our Site:

• ●Cookie Consent Banner: Our consent banner lets you accept or decline each category of non-essential cookie. Microsoft Clarity, HubSpot’s tracking code, RB2B, and our campaign-attribution storage are not loaded or written at all unless the relevant category is granted. Google Analytics works differently, and we would rather be accurate than flattering about it: the Google tag loads on every page, and your choice controls whether it may store cookies and identifiers, not whether it runs. In the EEA, the UK, and Switzerland it stores nothing until you opt in, though a cookieless measurement signal containing your IP address is still sent to Google. Elsewhere, including the United States, all categories are granted by default under an opt-out model, and cookies are set unless you decline.
• ●Withdrawing Consent: You can withdraw consent at any time by clearing this Site’s cookies in your browser, which causes the banner to ask again on your next visit, or by emailing privacy@vailent.com, and we will action it. Two honest caveats. Withdrawing stops these services loading on subsequent page views, but a service already running in your current tab continues until you reload or leave the page. And withdrawal does not affect the lawfulness of processing carried out before you withdrew.
• ●Browser Settings: You can configure your browser to block or delete cookies, including those placed by Google Analytics, HubSpot, and Microsoft Clarity. Please refer to your browser’s help documentation for instructions.
• ●Google Analytics Opt-Out: You may install the Google Analytics Opt-Out Browser Add-On to prevent Google Analytics from collecting data during your visits.
• ●Do Not Track: Our Site does not currently respond to “Do Not Track” browser signals, because no common standard for them exists.

7.2 European Economic Area, UK & Swiss Residents (GDPR)

Under the GDPR and UK GDPR, you have the right to access, rectify, erase, restrict processing of, and port your personal data, as well as the right to object to processing and to withdraw consent. Given the limited and largely anonymized nature of data we collect, we may not be able to identify you from the analytics data alone. To exercise any of these rights, please contact us using the information provided in Section 11.

7.3 California Residents (CCPA/CPRA)

If you are a California resident, you have the right to know what personal information we collect, the right to request deletion, and the right to opt out of the sale or sharing of personal information. As stated above, we do not sell or share personal information as defined under the CCPA/CPRA. You also have the right to non-discrimination for exercising your privacy rights. To submit a request, please contact us using the information provided in Section 11.

7.4 Brazil Residents (LGPD)

Under Brazil’s LGPD, you have rights including confirmation of processing, access to data, correction, anonymization, portability, deletion, and information about data sharing with third parties. To exercise these rights, please contact us using the information provided in Section 11.

7.5 Canadian Residents (PIPEDA)

Under PIPEDA, you have the right to access your personal information held by us and to challenge its accuracy. To make a request, please contact us using the information provided in Section 11.

7.6 Global Privacy Control (GPC)

Global Privacy Control is a browser signal that communicates an opt-out of the sale or sharing of personal information. We are implementing support for it. Until that support is live, a GPC signal does not by itself change what loads on this Site, and we would rather tell you that than claim otherwise. If you are a California resident and you wish to opt out, please decline the relevant categories on our cookie banner or email us at privacy@vailent.com, and we will honor the request.

8. Data Retention

Analytics data collected through Google Analytics is retained in accordance with Google’s default data retention settings. Visitor identification data collected through RB2B is retained in accordance with RB2B’s data retention policies. Session recordings and heatmap data collected through Microsoft Clarity, and website tracking data collected through HubSpot, are retained in accordance with those providers’ respective data retention policies. We periodically review and, where possible, configure retention periods to the minimum duration necessary to achieve the purposes described in this policy. Aggregated and anonymized data that cannot be used to identify any individual may be retained indefinitely for trend analysis and reporting purposes.

Information you submit through a form is retained in our HubSpot account, and in our own database, for as long as we have a legitimate business interest in the enquiry or an ongoing business relationship with you. You can ask us to delete it at any time using the contact details in section 11, and we will do so unless we are required to keep it by law.

9. Data Security

We take reasonable technical and organizational measures to protect the data processed through our Site. Data transmitted between your browser and our Site is encrypted using HTTPS/TLS. However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security. Google applies its own security measures to protect analytics data processed through its infrastructure.

10. Children's Privacy

Our Site is not directed at children under the age of 16 (or the applicable minimum age in your jurisdiction). We do not knowingly collect personal information from children. If you believe that a child has provided personal information to us, please contact us immediately, and we will take steps to delete such information.

11. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

For data protection inquiries from the European Economic Area or the United Kingdom, you may also contact your local supervisory authority.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the “Effective Date” at the top of this policy. We encourage you to review this page periodically for the latest information on our privacy practices. Your continued use of the Site after any changes constitutes your acknowledgment of the updated policy.