Privacy Policy

Congruex LLC Privacy Policy

Updated on November 5, 2025

Congruex takes your privacy seriously, and your privacy is important to us. In this privacy policy, we may refer to ourselves as “we,” “us,” or “our,” by which we mean Congruex LLC and its affiliates and subsidiaries. We use the word “you” throughout this privacy policy to refer to anyone within the scope of this policy. If you have any questions, comments or concerns regarding this privacy policy, please contact privacy@congruex.com.

Scope

This privacy policy describes how we collect, use, protect, process and disclose Personal Information that are collected on our website and websites controlled or offered by Congruex and its subsidiaries. We refer to these websites collectively throughout this policy as the “Site.” Congruex may operate under different brand names or through different subsidiaries, and this privacy policy applies to those brands or subsidiaries where this policy is linked within that brand or subsidiaries’ Site, unless otherwise specified.

If your organization has a separate contract or agreement regarding Congruex’s use and processing of Personal Information, to the extent that agreement conflicts with this privacy policy, the agreement will apply. However, where this privacy policy provides additional rights to individuals beyond the rights included in any such agreement, we will also afford individuals with the rights and choices they may have under this privacy policy.

Information We Collect

“Personal Information” means any information which could be used to identify you as an individual, either directly such as your name, mailing address, telephone number, email address, or indirectly, such as your IP address or other unique identifier, or any information that relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. While we use the term “Personal Information” in this Notice, we intend for this to include “Personal Data” where that term is used under applicable privacy laws.

Sources of Collection. We collect Personal Information from the following sources:

1. Directly from you. For example, when you communicate with us, submit a form on the Site, or submit a job application or resume.
2. Automatically through cookies, pixels, and other technologies, which collect Personal Information from you indirectly by observing your actions on our Site
3. From other sources, including our affiliates, other third parties, and publicly available information..

Categories of Personal Information Collected. We collect the following categories of Personal Information from visitors who visit our Site, and in the last twelve months, have collected the following categories of Personal Information from consumers who visit our Site:

• Examples of identifiers are your name, nickname or preferred name, postal address, unique personal identifier (such as a unique device identifier), online identifier, Internet Protocol address, email address, account name, or other identifiers that you submit or that are collected through the Site.
• Personal Information Categories Listed in State Statutes. Examples of Personal Information categories listed in state statutes (including in Cal. Civ. Code 1798.80(e)) are your name, email address, address, telephone number, education, employment, and employment history.
• Protected Classification Characteristics under State or Federal Law. Examples of protected classification characteristics as classified under certain state and federal laws includes information about your age (40 years and older), veteran or military status, race, national origin, citizenship, religion or creed, marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), medical condition, and information about physical or mental disabilities.
• Commercial Information. Examples of commercial information are records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

• General Geolocation Information, such as your zip code or approximate location. We do not collect precise geolocation information that allows us to pinpoint or learn the precise location of Site visitors.
• Internet or Other Similar Network Activity. Examples of internet or other similar network activity include browsing history, search history, information on your interactions with our Site, our apps, or our advertisements.
• Professional or Employment-Related Information. Examples of professional or employment-related information include current or past history or performance evaluations, resume, and other information about your employment or professional credentials.
• Inferences Drawn from Personal Information. Examples of inferences drawn from Personal Information include profiles reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
• Any other category or type of Personal Information that you submit to us through the Site, or that you consent to.

We may not collect each of the above categories of Personal Information from every person who visits our Site. For example, we generally collect different categories of Personal Information from individuals who apply for employment through our Site, as opposed to individuals who browse and visit our Site to learn about our products and services.

Combining Personal Information. We may combine Personal Information we collect from or about you with Personal Information we collect from other sources, for example, automatically or from publicly available sources.

How We Use the Personal Information We Collect and Our Legal Basis for Processing Your Personal Information

The reasons that we use your Personal Information and our legal basis for processing your Personal Information depends on the reason for which we are processing it. Our legal bases for processing your Personal Information generally include with your consent, to perform our contractual obligations to you and to provide you with services, products, and features you request from us, to comply with our legal obligations, and processing that is necessary in our legitimate interests.

We use your Personal Information for the following purposes where it is necessary for us to perform our contractual obligations to you and provide you with services, products, and features you request from us, including to:

• Provide our products, services, and Site to you
• Respond to your inquiries and fulfill your requests, such as to send you documents and information you request
• Provide customer service support to you
• Send you important information regarding our relationship with you or the Site, or regarding changes to the Site, our terms, and other policies and administrative information, such as planned maintenance or downtime
• Offer or consider you for employment

We use your Personal Information in the following ways to comply with our legal obligations, including to:

• Comply with legal or regulatory requests to which Congruex is subject, including subpoenas, regulatory inquiries, and other lawful judicial process
• Defend Congruex against actual, potential, or threatened litigation, claims, or to assert other legal rights that Congruex has

We use your Personal Information for the following purposes where it is necessary in our legitimate interests in order to:

• Operate our business
• Improve, enhance, and develop our Site
• Perform our contractual obligations with other entities, organizations, and third parties
• Market our products and services to you
• Identify trends regarding our Site and the use of our Site
• Personalize your experience when you interact with us
• Undertake market research, analytics, or segmentation so that we can better understand our customers’ and potential customers’ needs
• Understand the effectiveness of any marketing campaigns that we run
• Undertake cybersecurity measures
• Ensure continuity of service to you if we sell, assign, or transfer part of our business or enter into a relationship with a successor entity

In addition to the above, we may also use your Personal Information as you otherwise direct us to, or otherwise consent to.

De-Identified, Anonymized, and Aggregated Personal Information

We may permanently anonymize or de-identify your Personal Information so that it is no longer Personal Information under relevant laws. After permanent anonymization or de-identification, you can never be identified and the data is not traceable to you, and we will not take steps to re-identify the data so that it is identifiable. We may use or disclose such anonymized or de-identified data for statistical analysis, product development or improvement, demographic analysis or other similar activities. We may export and process permanently anonymized data in any country in which we or one of our service providers or business partners has operations. We may combine or aggregate anonymized or de-identified data with other third-party data that we collect.

Personal Information Disclosure
Disclosures for a Business Purpose

Congruex discloses Personal Information for a business purpose for a variety of reasons. More specifically, we may disclose any or all of the categories of Personal Information we collect from and about you for a business purpose as follows, to the following categories of third parties:

• Disclosure to Third Party Providers and Subprocessors. We may disclose your Personal Information when we engage third party service providers or data subprocessors to assist in providing analytics, data storage, and other services. We also use third parties to provide, maintain, and improve the Site, to assist with our company operations, and to assist with our marketing efforts. Our Third-Party Providers and Subprocessors are required to treat any Personal Information they process on our behalf in accordance with any applicable laws concerning the processing of Personal Information that we are subject to.
• Disclosure for Legal Requirements. We may disclose your Personal Information to respond to legal requirements, to protect or enforce our rights and policies, to protect or enforce the rights of a third party, to prevent harm to a person or as required or permitted by law, including, without limitation, to comply with a subpoena or court order. The categories of third parties this includes are government and law enforcement officials, other law firms and professional service organizations, courts, regulators, and third parties associated with these third parties, such as court reporters.

• Disclosure to Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety, rights or property of any person or party, or violations of our Terms of Use or this Privacy Policy.

• Disclosures to our Investors, Affiliates, or Partner Organizations. We may disclose your Personal Information to our investors, affiliates, or partners organizations who are associated with or involved with Congruex from a business or operational perspective.

In addition to the foregoing, we may also disclose Personal Information as follows:

• Disclosure to Company’s Affiliates and Successors. If we engage in a merger, acquisition, reorganization, sale of some or all of its assets, or similar transaction, or takes steps in contemplation of such transactions (e.g., due diligence), Personal Information may be shared or transferred with a new or prospective owner, subject to standard confidentiality agreements.

• Disclosure to Third Party Marketing and Website Partners. As described in the “Cookies” section, we may rely on third parties to assist us with marketing campaigns. As part of this assistance, these third parties may place cookies, web pixels, or other technologies on our Site to identify visitors to our Site and other websites across the Internet. The information collected by or disclosed to these third parties may include identifiers, commercial information, internet and other similar network activity, general geolocation information, and inferences drawn from personal information. We, and third parties, use this information to obtain more information about our visitors and we may use this information to reach out to them through other channels, such as email and/or direct mail. For more information about this practice and rights you may have, please review the “Sales and Other Sharing of Personal Information,” “Cookies,” and “Additional Privacy Rights and Choices” sections of this privacy policy.

• Disclosure With Your Consent. In addition to the sharing described elsewhere in this Privacy Policy, we may share Personal Information with companies, organizations, or individuals outside of those listed here if we obtain your consent to do so, or if you otherwise direct us to.
• Disclosure of Non-Personal Information. We may disclose your anonymized and aggregated or de-identified information to any party including potential business partners, advertisers, investors, and other third parties. When we share information in this manner, it is aggregated, anonymized, or de-identified such that it is no longer considered Personal Information and for this reason, we may share this information without restriction.

Cookies

We use web tools including cookies, pixels, clear GIFs, session replay, and other similar tracking technologies to monitor, customize and enhance a user’s experience on the Site, and to allow us to track user activity on our Site and across the Internet. We refer to these tools collectively in our policy as “cookies.” A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that website to recognize your browser. Cookies may store unique identifiers, user preferences, and other information. You can set your browser to refuse all cookies or to indicate when a cookie is being sent. However, some features or services on our Site may not function properly without cookies. We use cookies to improve the quality of the Site and services, including to store user preferences, to track user trends, and to provide relevant advertising to you. Third-party cookies and analytics services we currently use include:

1. Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies to help us analyze how users use our Site and enhance your experience when you use our services. More information on how Google uses this data.
2. Meta Pixel, an advertising network provided by Facebook that allows us learn more about visitors to our Site and to serve ads to people within our network. More information on how Facebook uses this data.

For more information about rights and choices you may have regarding our use of cookies, please visit the section below called “Your Rights and Choices.”

Sales and Other Sharing of Personal Information for the Purpose of Cross-Context Behavioral Advertising

Congruex does not sell Personal Data for money, but in the last twelve months we have shared Personal Information including identifiers, Personal Information categories listed in state statutes, commercial information, general geolocation information, internet or similar network activity, and inferences drawn from Personal Information, with providers of advertising and analytics services, and network advertisers. This sharing and disclosure may be considered a “sale” or “sharing” under applicable state law.

Security

Congruex maintains appropriate administrative, technical and physical safeguards designed to protect the Personal Information we collect against unauthorized access, disclosure or use.  While we have these safeguards in place, no transmission of data over the Internet is guaranteed to be completely secure and we cannot guarantee the security of any information you provide to us.

Data Storage and Retention

Your Personal Information is stored on Congruex’s servers, and on the servers of the cloud-based database management services it engages, located in the United States. Congruex retains Site form submission for one year unless otherwise required by law or to the extent such communications are necessary for ongoing business with the submitter. Congruex retains other data for the duration of the customer’s business relationship with Congruex, for the purposes indicated in this Privacy Policy, in accordance with Congruex’s data retention policies, or for such other period as may be permitted or required by law, whichever is longest.

Links to Other Sites

This Site contains links to third-party websites that are provided for your convenience.  Congruex does not endorse nor is it responsible for the privacy practices or the content or services of such websites.  We recommend that you review the privacy policies and terms of use that govern those websites when you visit them.

International Transfers

For Site visitors who reside outside of the United States, your Personal Information will be processed in the United States, where our servers and the center of our operations are located. You understand and agree that Congruex will process your Personal Information in the United States if you choose to visit our Site or access our Site from a jurisdiction outside of the United States. The data processing laws of the United States may be different than the laws in the jurisdiction in which you reside. Congruex may be required by law to disclose your Personal Information in certain circumstances, such as in response to inquiries or requests from government authorities or to respond to judicial process in the United States. If we are compelled to provide Personal Information about you pursuant to judicial process, we will endeavor to provide you with notice of the request prior to supplying the information, where permitted by law. When you use our Site, your information is governed by this privacy policy. In accordance with any other applicable terms, including our Terms of Use, you consent to the transfer of Personal Information to the United States by using our Site after receiving notice that our Personal Information is processed in the United States. If you wish to revoke your consent at any time, you may do so by contacting us as set forth below. Please note that if you revoke your consent to transfer your Personal Information to the United States for processing, we likely cannot process your Personal Information at all.

Your Rights and Choices

All Site visitors can review and update or correct their Personal Information at any time by logging into their account through the careers page on our site (if you applied for a job with us) or by contacting us using the information below. All individuals may also update their marketing preferences at any time, as described below. In addition to these rights, if you live in a jurisdiction with a consumer privacy law to which Congruex is subject, you may have additional rights and choices. These additional rights and choices are described below in the “Additional Privacy Rights and Choices” section.

Opting Out of Marketing Communications
If you receive email marketing communications from us, you may opt-out at any time by clicking the “unsubscribe” link contained in the email (usually at the bottom of the email). Please allow us up to ten (10) days to process your request.

Additional Rights and Choices

In addition to the foregoing, depending on the jurisdiction in which you reside, you may have the following additional rights and choices regarding your Personal Information. Whether you have additional rights and choices may depend not only on whether your jurisdiction has an applicable law that affords rights, but also whether Congruex is subject to the law and meets the thresholds for compliance. As indicated above in the “Information We Collect,” section, while we use the term “Personal Information” throughout this policy, we intend for this to include “personal data” where that is the term used under applicable law. If you have questions about whether you live in a jurisdiction that affords privacy rights that we are obligated to fulfill, please contact us using one of the methods listed below in the “Contact Us” section.

Right to Request Access or Right to Know
You may have the right to request that we disclose information to you about our collection and use of your Personal Information over the past 12 months. You may have the right to request the following:

• The categories of Personal Information we collected about you.
• The specific pieces of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• The business or commercial purpose for collecting your Personal Information
• The categories of third parties with whom we have disclosed your Personal Information in the preceding twelve (12) months.
• The categories of Personal Information we sold or shared about you, and the categories of third parties to whom the Personal Information was sold or shared by category of Personal Information.

Right to Portability
After you make a request to access or know your Personal Information, you may have the right to request to obtain a copy of this information in a portable, readily usable format that allows you to transmit the information to another party, to the extent it is technically feasible. You may also have the right to request that we transfer your data to another organization, under certain circumstances.

Right to Deletion or Right to Erasure
You may have the right to request that we delete any of the Personal Information that we collect or retain about you, subject to certain exceptions. After we receive and verify your request, we will delete (and direct any of our service providers that hold your Personal Information on our behalf to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining your Personal Information is necessary for us or our service providers, as permitted by law.

Right to Opt-Out of the Sale or Sharing of Personal Information, or the Use of Personal Information for Targeted Advertising
You may have the right to opt-out of the sale or sharing of your Personal Information. Information about our practices that may constitute a “sale” or “sharing” of your Personal Information as defined by law are noted in the above section titled “Sales and Other Sharing of Personal Information.” You may exercise your right to opt-out by following the instructions set forth in this section of this Notice titled “Exercising Your Rights.” Please note you may also need to update your preferences in your browser settings in order to fully opt-out.

In some states, this right is known as the right to opt-out of the use of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of certain decisions.

[This Site responds to global privacy control—or “GPC”—signals, which means that if we detect that your browser is communicating a GPC signal, we will, where required by applicable law, process that as a request to opt that particular browser and device out of sales and sharing of Personal Information.]

Right to Limit Certain Uses and Disclosures of your “Sensitive Personal Information”
You have the right to limit our use and disclosure of your “Sensitive Personal Information,” as that term is defined in applicable statutes, where we have collected it, to use as necessary to perform the services or provide the goods reasonably expected by you, and as otherwise authorized by the statute and regulations. We do not generally collect Sensitive Personal Information from consumers who visit our Site. If we do, we believe we only use your Sensitive Personal Information in ways that you would reasonably expect are necessary to perform the services or to provide you with the services you request. Congruex does not “sell” or “share,” as those terms are defined, Sensitive Personal Information.

Right to Correct Personal Information if the Data is Inaccurate
If you believe or discover that Personal Information we have collected about you is inaccurate, you may contact us to request that we correct and update the information so that it is accurate. Where applicable, you may also visit your account profile change to update or change your information, such as through your profile on our careers page. Consistent with applicable law, we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Right to Withdraw Consent
If you have previously consented to the use of your Personal Information for direct marketing or targeted marketing, you may withdraw your consent at any time.

Right to Restrict or Object to Processing
You may have the right to restrict certain processing of your Personal Information, or to object to certain processing of your Personal Information, including where our legal basis for the processing is your consent, where the processing involves Special Category Personal Data or Sensitive Personal Information, or where it involves automated decision-making technologies. This right is subject to certain restrictions.

Right to Appeal
If you are a resident of certain jurisdictions, you have the right to file an appeal with us if we deny your request to exercise your rights. Requests to appeal can be communicated through the same means by which your request was submitted. If we deny your appeal, you may have the right to appeal to your state regulator. We will provide you the information of the applicable regulator if we deny your appeal.

In addition to the above rights, you also have the right to:

• Appoint an individual to exercise your rights on your behalf, or to exercise rights on behalf of your minor child, if we have collected their information
• Access information about automated decision making (as applicable)
• Opt-out of automated decision making (as applicable)
• To not be discriminated against for exercising your rights

Right to Lodge a Complaint
You may have the right to make a complaint with the supervisory authority for your country of residence. If you are an EU Resident, details can be found here.

Exercising Your Rights

If you believe you reside in a jurisdiction that affords broad consumer privacy rights to its residents and you wish to exercise any of the rights described above, please submit the details of your request through our Privacy Rights Portal here. Alternatively, you may submit a request by email to privacy@congruex.com, with the subject line “Consumer Privacy Request” if you are a United States resident, and “Data Subject Privacy Request” if you are a non-United States resident.

A consumer may designate an authorized agent to submit requests on their behalf by emailing privacy@congruex.com. The agent must be able to establish their identity and authorization to act on your behalf by sending a notarized affidavit or power of attorney making suitable authorization and the details of the specific request. Congruex may need to take additional steps to verify the agent and/or the request before proceeding.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. If you make a request, your request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will take steps to verify your consumer request, including that you are the person making the request, or you have authority to make the request on behalf of the individual the request relates to. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format
We will endeavor to respond to verifiable consumer requests within forty-five (45) days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any rights you have under applicable law. Unless permitted by applicable law, we will not:

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

However, we may offer you certain financial incentives permitted by state law that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program may require your prior consent, which you may revoke at any time.

Shine the Light

Under California’s “Shine the Light” law, California residents who provide Personal Information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2025 will receive information regarding 2024 sharing activities, if any).

To obtain this information, please send an email message to privacy@congruex.com with “Shine the Light Request” on the subject line and in the body of your message.  We will provide the requested information to you at your e-mail address in response.  Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

 Children’s Privacy

This Site is directed towards adults who are age 18 or older. Congruex does not knowingly collect information from children under the age of 13. If we learn that we have collected Personal Information from a child under the age of 13, we will promptly delete that information. If you believe we have collected Personal Information from a child under the age of 13, please email us at privacy@congruex.com.

 Changes to Our Privacy Policy

We reserve the right to change this privacy policy from time to time to reflect changes in our business practices.  Any changes to this privacy policy, including information collected and the use and disclosure of information, will be posted here. For material changes, we may endeavor to provide you with more direct notice. Following any modification, we will revise the “updated on” date at the top of this policy, so be sure to check back periodically for the most current version. Changes to this policy will be effective when posted, unless otherwise noted.

How to Contact Us

You can direct questions regarding this Privacy Policy by emailing us at privacy@congruex.com, or by calling us toll-free at 1-888-581-4776..

Click here for our Privacy Rights Form

Click here to review your cookie settings