EFFECTIVE: October 30, 2024

INTRODUCTION

This Privacy Notice explains how Cadex Solutions Corporation, including any and all subsidiaries (“Cadex,” “we,” “us,” or “our”) collects, uses, shares, and protects the personal information of our website users, clients, suppliers, and potential clients gathered through the Cadex websites, apps, or other digital or online information gathering platforms Cadex may use (collectively, the “Sites”), as well as through our offline interactions with you. We may collect, process, store, and share your personal information throughout the course of our relationship with you as described in this Privacy Notice. The types of personal information we collect and the ways we use, store, and share that information depend on the nature and circumstances of our relationship with you.

This Privacy Notice concerns the processing of personal information where we are the Data Controller. Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information is or will be processed.

When Cadex processes the personal information of debtors in the performance of collections services on behalf of a client, our client is the Data Controller and we are a Data Processor. We only process debtors’ personal information on the express instructions of our clients, subject to a data processing agreement. As Data Controllers, our clients determine the purposes and means of processing debtors’ personal information. This Privacy Notice does not cover our practices as a Data Processor. If you are a debtor, please see the privacy notice of your debt holder for information about the processing of your personal information and how to exercise your privacy rights.

HOW WE COLLECT PERSONAL INFORMATION

Cadex may collect personal information about you from a variety of sources, including:

• From You: Information may be collected when you submit it on our Sites or interact with us. For example, Cadex collects the information you provide when you create an account with us or communicate with us.
• From Your Devices: Our Sites and email messages may use cookies, pixels, and tags to collect network and device data, including the device model, operating system and version, the name of the domain from which you access the Internet, your Internet Protocol (“IP”) address, and the browser you use, along with activity information like the date and time you access our Site, which pages or portions of our Site or emails you interact with and the links you click on.
  • Cookies: Small files that are transferred to your device’s hard drive to store online activity, preferences, and other types of information to help us provide you with certain features.
  • Web Beacons or Pixels: Single-pixel electronic images placed in the code of a webpage, application, or email that allow us to monitor things such as user activity and Site traffic. We may also use pixels in our emails and newsletters to count how many of those messages are read.
  • Tags: Pieces of code that provide functionality and gather information about user activity. For example, we use tags on our website to better understand online usage patterns and trends.
• From Our Service Providers: Information we may obtain from vendors depends on the services they provide to Cadex. For example, we may collect information from our credit card processors and background check vendors. The information we obtain from these vendors depends on the services they provide to Cadex and may also be governed by those companies’ privacy policies.
• From Publicly Available Information: Cadex may collect information you have publicly posted on your website or social media pages. We may also collect information about you and your business from public databases for tax, accounting, and similar financial purposes.

Please see our Cookie Policy at www.cadex-solutions.com/cookie-policy for more information about the ways we use these technologies and the personal information collected through them.

TYPES OF PERSONAL INFORMATION WE COLLECT

Cadex may collect the following categories of personal information from and about you, depending on the circumstances of your relationship with us.

• Identifiers and Contact Information such as your name, email address, job title, business address, and phone numbers (fax, mobile, or landline).
• Financial Information such as bank account information, purchase order numbers, account numbers, routing numbers, wire/ACH numbers (online and offline), payment method, payment terms, payment history, credit card number, credit card expiration, CVV, credit limit, and credit terms. We use third-party credit card processors that collect, process, and store credit card numbers, expiration dates, security codes, and related information through their own websites and subject to their privacy policies.
• Professional and Employment Information if you apply for a job with us, such as your employment history, educational history, qualifications and skills, date of birth, employment eligibility information, and criminal background information, where permitted by local law.
• Internet or Other Electronic Network and Device Activity such as your IP address, internet service provider, browser type and version, operating system, language settings, pages you visit, referring and exit pages and URLs, date and time of your visit, amount of time spent on particular pages, unique device identifiers, search terms, and other diagnostic data.

HOW WE USE PERSONAL INFORMATION

Cadex may use the personal information we collect for the following purposes:

• To enter into and fulfill business agreements with you.
• To prepare and send invoices, make and receive payments, and manage accounts, including payment processing.
• To provide customer service.
• To manage our relationships with our clients and vendors.
• To respond to general inquiries, solicit feedback regarding our services and support, and communicate with you about current and future Services.
• To provide relevant content on our Sites, including advertisements regarding Cadex Services.
• To process job applications.
• To operate, maintain, secure, and improve our Sites, product offerings, and services.
• To maintain the rights, safety, and security of Cadex, our Sites, Cadex products, databases, and other technology assets.
• To detect, prevent, investigate, respond to, or otherwise address fraud and unauthorized access to or use of the Sites or our services, including breaches of terms, policies, contracts, or other wrongful behavior.
• To protect your or someone else’s health, security, or welfare.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
• To comply with any procedures, laws, and regulations that apply to us.
• As otherwise described to you at the time your personal information is collected, or with your consent, if not listed here.
• As otherwise required or permitted by law.

HOW WE SHARE PERSONAL INFORMATION

Cadex may share your personal information for the following purposes:

• With our third-party service providers who perform a variety of services and functions for Cadex, such as financial and legal services. Your information will only be shared on the condition that the service providers use your information only to provide the agreed services on our behalf.
• With law enforcement and government or regulatory agencies as required by law, such as for tax or audit purposes or pursuant to a lawful order.
• In the event we go through a business transition such as a merger, acquisition by another company, bankruptcy, reorganization, or sale of all or a portion of Cadex’s assets.
• To unrelated third parties for their independent use upon your request or with your authorization.
• Where necessary to protect Cadex’s rights or safety, or the rights or safety of Cadex employees or others.

JOB APPLICANTS

If you apply for a job with Cadex, we will use the personal information that you provide in your application, including any attachments sent, for the purpose of considering your candidacy for employment. This data includes your name, home address, email, phone number, date of birth, Social Security Number, background check and drug test results, the information in your CV or resume, your job preferences, your job application profile, and if you choose to disclose it, your race or ethnicity. If you have a social media profile, including a LinkedIn profile, Cadex may review the data you choose to share on social media as well.

LINKS TO EXTERNAL WEBSITES

Our Site may contain links to external/third-party websites, including social media sites with content regarding Cadex, such as LinkedIn, YouTube, X (formerly known as Twitter), and Instagram (collectively, “External Sites”). Such links do not constitute an endorsement by Cadex of those External Websites. Cadex provides these links as a convenience and is not responsible for the content of such External Websites.

Your use of External Websites is subject to the terms of use and privacy policies of those External Websites. We encourage you to read the privacy policy of any website you visit before providing any information to the operator of that website.

DO NOT TRACK

Currently, Cadex does not respond to Do Not Track (“DNT”) signals. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. All About Do Not Track, a Future of Privacy Forum website located at https://allaboutdnt.com, has more information about DNT signals.

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

If you are from the European Economic Area (“EEA”), our legal basis for collecting and using your personal information as described in this Privacy Notice depends on the personal information we collect and the specific context in which we collect it.

Cadex may process your personal information because:

• We need to perform a contract with you (GDPR Art. 6(1)(c)).
• You have given us consent to do so (GDPR Art. 6(1)(a)).
• The processing is in our legitimate interests, and it is not overridden by your rights (GDPR Art. 6(1)(f)).
• To comply with the law (GDPR Art. 6(1)(b)).
• In rare cases, where necessary to protect the life or imminent safety of you or another individual and where no other legal basis applies (GDPR Art. 6(1)(d)).

PURPOSE LIMITATION

Cadex will only process personal information in a way that is compatible with and relevant to the purposes for which it was collected or authorized by you, as we notify you if the purposes change, or as described in this Notice, as updated from time to time.

INTERNATIONAL USERS OUTSIDE OF THE U.S. AND CANADA

Cadex is a global company with global affiliates, and therefore we use global vendors, subcontractors, systems, and applications. As a result, the personal information that we collect and process about you may be transferred, stored, or accessed in a destination outside of your country, which may have less strict or no data protection laws when compared to the laws in your country. Any transfers of personal information to Cadex affiliates or third parties outside your local country will be conducted in compliance with the international data transfer restrictions that apply under applicable data protection laws.

We take measures to ensure that adequate safeguards are in place (e.g., standard contractual clauses, data transfer agreements) to protect your personal information in accordance with applicable privacy laws and this Privacy Notice.

DATA SECURITY

Cadex takes the security and privacy of the personal information it collects very seriously. Accordingly, we will take reasonable steps to ensure that personal information is accurate, complete, current, secure, and reliable for its intended uses. We employ procedural and technological security measures that are designed to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, please remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to protect your personal data, we cannot guarantee its absolute security.

DATA RETENTION

Cadex will retain your personal information for as long as reasonably necessary for legitimate business purposes or as required by law. Personal information will be kept until it is no longer necessary to provide our products and services, to fulfill our contractual agreements with you, to comply with applicable law or legal orders, to protect Cadex’s rights and interests (e.g., where the retention is necessary for the establishment, exercise, or defense of claims), as otherwise needed for the purposes for which it was collected or processed, or to fulfill its legal and regulatory obligations.

PRIVACY STATEMENT FOR CHILDREN

Our Site and services are not intended to be directed to children that are younger than thirteen (13). Cadex does not knowingly collect or intend to collect any personal information from children under the age of thirteen through the Site. If you are under thirteen (13), please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our privacy policy by instructing their children never to provide personal information to us without their permission. If you have reason to believe that we may have information from or about a child under the age of thirteen (13), please contact us at privacy@cadex-solutions.com, and we will endeavor to delete that information from our databases.

YOUR PRIVACY RIGHTS

Some privacy laws provide certain rights for individuals. Cadex respects your rights concerning your personal information. Your rights with respect to your personal information may include the following, in accordance with applicable laws and subject to necessary validation of your identity:

• Withdraw Consent: If we use or share your personal information based on your consent, you may withdraw your consent at any time by contacting us using the contact information listed below. To withdraw your consent to receive marketing communications from Cadex, you may alternatively follow the unsubscribe process described in the message. Please note that withdrawing consent does not affect the lawfulness of processing based on your consent prior to its withdrawal.
• Access: You may request access to or obtain a copy of your personal information. You may also request information about the types of personal information we have, the purposes for which we process it, and who has received access to or a copy of your personal information.
• Correction: You may request that we correct your personal information if you think it is inaccurate or incomplete.
• Deletion: You can also request that we erase or delete your personal information in certain circumstances.
• Data Portability: You may request that we provide you with the personal information we obtained from you in a machine-readable format, and you can ask us to provide it to another entity.
• Objection: You may have the right to object to our processing of your personal information for certain purposes.

To exercise these rights, please send an email to privacy@cadex-solutions.com with the details of your request. We will take steps to verify your identity before fulfilling your request to protect your personal information against unauthorized disclosure, modification, or deletion.

You may use an authorized agent to submit a request relating to your rights. Only you or someone legally authorized to act on your behalf may make requests regarding your personal information and privacy rights. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your personal information, we reserve the right to deny a request from an agent who does not submit proof that you have authorized them to act on your behalf.

We will handle any request to exercise your rights in accordance with applicable law, but please note that these rights may not be absolute. Cadex may refuse or deny a request in accordance with applicable privacy laws.

NON-DISCRIMINATION

Cadex does not discriminate against individuals who exercise their rights under applicable law. In particular, we will not engage in the following in a discriminatory manner:

• Deny you products or services.
• Charge you different prices or rates for products or services, including through granting discounts and other benefits, or imposing penalties.
• Provide you with a different level or quality of products or services.
• Suggest that you may receive a different price, rate, or level of quality of products or services.

LODGING A COMPLAINT

If you believe we are using, disclosing, or otherwise processing your personal information in a way that is not in accordance with applicable law, you can lodge a complaint with the relevant data protection authority in your state, country, or region.

PRIVACY NOTICE CHANGES AND UPDATES

This Privacy Notice may be amended at any time. If material changes are made in how personal information is collected, used, disclosed, or otherwise processed, this Privacy Notice will be updated, including the “Effective Date” at the top of this Privacy Notice. We recommend that you review the Privacy Notice each time you visit our Site to stay informed of our privacy practices. Any changes will be effective when we post the updated Privacy Notice.

CONTACT INFORMATION

All questions, complaints, or comments about this Privacy Notice or Cadex’s data protection practices can be submitted to Cadex by email at privacy@cadex-solutions.com. You may also contact our data protection officer at dpo@cadex-solutions.com.