Selerix Systems, Inc., and its affiliates and subsidiaries, including TBX Employee Benefits, LLC, and SyncStream Solutions LLC (collectively referred to as, “Selerix”, “we”, “us”, or “our”) are strongly committed to protecting your privacy online when you visit one of our web sites, including www.selerix.com, www.tbxbenefits.com, and www.sync-stream.com (referred to as the “Sites” or, individually, a “Site”) and personal information about you that you provide to Selerix. Selerix knows that you care how information about you is used and shared and we appreciate your trust that we will do so carefully and sensibly.

This Privacy Policy (“Policy”) describes how Selerix collects, uses, discloses, and protects the personal information of users (“you” or “your”) of our Sites, products, and services. This Policy is designed to comply with applicable data privacy laws in the states of California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia and other state laws currently in effect or that become effective.

This Policy applies to the processing of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”) collected through our Sites or in the course of our business activities. It applies to Personal Information processed by us as a controller.

“Sensitive Personal Information” means personal information that reveals an individual’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; genetic data; biometric information processed for the purpose of uniquely identifying a consumer; personal information collected and analyzed concerning a consumer’s health; or personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.

TYPES OF PERSONAL INFORMATION WE COLLECT

We may collect one or more of the following categories of Personal Information:

• Identifiers (e.g., name, address, email address, phone number, online identifier, IP address, user ID);
• Commercial information (e.g., Selerix products or services purchased, obtained, or considering);
• Internet or other similar network activity;
• Geolocation data (e.g., zip code);
• Characteristics of protected classifications (e.g., sex, and age);
• Professional or employment-related information (e.g., company name, your title, shipping address, billing address, income level); and 
• Inferences drawn from other Personal Information (e.g., preferences, interests). 

SOURCES OF PERSONAL INFORMATION

We collect your Personal Information Directly from you when you provide it to us by telephone, email, text and via the Sites, including via the Site registration system, and automatically through your use of our Sites.

PURPOSES FOR COLLECTING PERSONAL INFORMATION

We collect and use your Personal Information for the following business purposes:

• To provide and maintain our Sites, products and services;
• To process your requests and transactions, and respond to email requests;
• To communicate with you about our products, services, and promotions, including any new features;
• Improving our marketing and promotional efforts;
• To personalize your experience on our Sites and with our products and services, including customizing our Sites, content, products and services;
• To improve our Sites, content, products and services;
• To comply with legal obligations;
• To protect the security and integrity of our Sites and businesses; and
• For any other purpose disclosed to you at the time of collection.

USE AND DISCLOSURE OF PERSONAL INFORMATION

We use the personal information we collect for the purposes described in Section 3 and as otherwise disclosed at the time of collection. For example, we may use your email address to send you promotional offers or your purchase history to recommend products you might like. We also use your Personal Information to create aggregate reports; however, these reports do not contain Personal Information. These aggregate reports further help us improve and better tailor our Sites, products and services to meet your needs and the needs of our other customers.

By way of example, we use your Personal Information in the following ways:

• We use your user IDs and passwords to provide you with access to your profile areas and to protected content.
• We use your account information to learn more about who you are and how to contact you, and we use your shipping and billing information, if appropriate. Your account information also contains any preferences you have provided, such as language, email format and interests.
• We use the information you provide us with respect to customer feedback and support to inform us about how we can improve our products, services and Sites designs.
• We use the contents of your email correspondence with us to raise and respond to issues and inquiries of all types and to distribute information about Selerix products and services.
• We use information related to your transactions to identify which products and services you have requested and what other products and services may be of interest or use to you.

We may disclose your personal information to the following categories of third parties:

• Service providers, processors and agents who perform services on our behalf (e.g., hosting providers, payment processors);
• Affiliates and subsidiaries; and
• Government entities or law enforcement agencies, when required by law.

Unfortunately, due to the existing regulatory environment, we cannot ensure that all of your private communications and other Personal Information will never be disclosed in ways not otherwise described in this Policy. By way of example (without limiting the foregoing), we may be forced to disclose information to the government or third parties under certain circumstances, or third parties may unlawfully intercept or access transmissions or private communications. Further, we can (and you authorize us to) disclose any information about you to law enforcement or other government officials as we, in our sole discretion, believe necessary or appropriate. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your Personal Information or private communications will remain private.

As we continue to develop our business, Selerix or substantially all of its assets may be acquired. In such a transaction, customer information, including your Personal Information, will be one of the transferred business assets.

We share aggregated demographic and profile data collected via our Sites and registration system, with our advertisers. Such shared information is in aggregate form only and does not identify any individuals.

Except at otherwise stated in this Privacy Policy, we do not sell, rent, lease or share Personal Information, as such activities are defined under applicable state laws.

YOUR RIGHTS AND CHOICES

Depending on your state of residence, you may have the following rights with respect to your Personal Information:

• Right to Know/Access: You may request access to the specific pieces of Personal Information we have collected about you.
• Right to Delete: You may request that we delete Personal Information we have collected from you, subject to certain exceptions.
• Right to Correct: You may request that we correct inaccurate Personal Information we maintain about you.
• Right to Opt-Out: You may opt-out of the sale or sharing of your Personal Information for cross-context behavioral advertising purposes. At this time, we do not sell or share your Personal Information for cross-context behavioral advertising purposes.
• Right to Limit Use and Disclosure of Sensitive Personal Information: You may direct us to limit our use and disclosure of your sensitive Personal Information, if any, to that which is necessary to perform the services or provide the goods reasonably expected by an average consumer.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.
• Right to Appeal: Where applicable by state law, you have the right to appeal our decision regarding your rights request.

To exercise your rights, please contact us as follows:

• You can send e-mail to: legal@selerix.com
• You can call the following telephone number: (469) 747-1144

See Section 12 for full contact information. We will respond to your request within the timeframe required by applicable law, which is generally forty-five (45) days, unless an extension is permitted.

In addition, Sites give you the opportunity to opt-in to receive communications from us and our partners at the point where we request information about you.

Residents of certain states have the option to have an authorized agent exercise certain of these rights on their behalf. If you are an authorized agent, then you will be required to submit your contact information and a certification, as well as provide certain information about the consumer for whom you are making a request. Residents of certain states may also have the right to appeal our denial of one or more of the above requests. To submit an appeal, please contact us using the information provided in Section 12.

VERIFICATION PROCESS

To protect your privacy and security, we will take reasonable steps to verify your identity before granting access to your Personal Information or complying with your request. Our verification process may vary depending on the nature and sensitivity of the request. We may require you to provide:

• Name and email address associated with your account;
• A description of your request; and/or
• A declaration under penalty of perjury that you are the individual whose Personal Information is the subject of the request.

For requests related to particularly sensitive information, we may require additional proof of identification, such as a copy of a government-issued ID or a recent utility bill.

For certain requests, we may use a third-party identity verification service to confirm your identity. This service may ask you questions based on public records or credit reports to verify your identity.

If we are unable to verify your identity to a reasonable degree of certainty, we may deny your request and explain the reasons for the denial.

DATA SECURITY

We implement reasonable security measures designed to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include:

• Encryption of personal information in transit and at rest using industry-standard encryption protocols (e.g., TLS, AES-256);
• Regular security assessments and penetration testing conducted by third-party security firms;
• Employee training on data protection and security practices, including annual security awareness training;
• Access controls and authentication procedures, including multi-factor authentication for sensitive systems;
• Network segmentation and firewalls to protect against unauthorized access; and
• Regular software updates and patch management to address known vulnerabilities.

However, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. In the event of a data breach that compromises your personal information, we will notify you and the relevant authorities as required by applicable law.

DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by law. Our typical retention periods are:

• Account information: For the duration of your account plus 7 years from the date of account closure;
• Transaction information: 7 years from the date of the transaction;
• Communication records: 3 years from the date of last communication; and
• Marketing preferences: Until you opt-out or request deletion.

We review our retention periods for personal information on a regular basis. We will securely delete or anonymize personal information that is no longer needed for the purposes for which it was collected.

COOKIE AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to collect information about your browsing activities on our Sites. This information may include:

• Pages visited;
• Time spent on pages;
• Links clicked;
• Preferences selected;
• Device information (e.g., browser type, operating system); and
• IP address and approximate location derived from IP address.

“Cookies” are pieces of information that a web site transfers to an individual’s hard disk for record keeping purposes. Our Sites use cookies during your on-line session to deliver content specific to your interests. Cookies allow us to avoid showing you the same ad or other message repeatedly and allow us to tailor a Site or to better match your interest and preferences. We use cookies and tracking technologies, including those from third-party platforms like Google Tag Manager, GA4, Google Ads, and LinkedIn Ads, to:

• Understand and analyze visitor behavior;
• Measure the effectiveness of our marketing campaigns;
• Provide targeted advertisements based on user interests; and
• Improve overall functionality or Sites and user experience with our Sites.

Our cookies enable Selerix to relate your use of the Sites to information that you have specifically and knowingly provided to our Sites. Most internet browsers enable you to erase cookies from your computer hard drive, block all cookies or receive a warning before a cookie is stored. Please refer to your browser instructions or help screen to learn more about these functions.

USE OF ADVERTISING AND ANALYTICS TECHNOLOGIES

Selerix uses third-party advertising and analytics platforms to enhance user experience, track website performance, and improve marketing efforts. These platforms include, but are not limited to:

• Google Tag Manager (for managing marketing tags and scripts);
• Google Analytics 4 (GA4) (for tracking and analyzing website traffic and user behavior);
• Google Ads (for targeted advertising and remarketing campaigns); and
• LinkedIn Ads (for targeted B2B advertising and audience insights).

These platforms collect and analyze data regarding user interactions with our website, such as page visits, time spent on pages, conversion tracking, and ad effectiveness. Some of this data may be used for personalized advertising based on user interests and behaviors.

CHILDREN’S PRIVACY

Selerix understands the importance of protecting children’s privacy in the interactive, on-line world. Selerix does not intentionally or knowingly target or solicit to children thirteen (13) or younger for purposes of collecting Personal Information. If we become aware that we have collected personal information from a child under 13 without parental consent, we will take steps to delete that information promptly. If you believe we may have collected information from a child under 13, please contact us using the information provided in Section 12. The Sites may link to third party web sites which may target or solicit to children thirteen (13) or younger and may collect Personal Information. Those web sites are not governed by this Privacy Policy, but will (or should) have their own privacy policies that more fully explain how they respect and protect the privacy of children while providing them information, goods or services.

CONTACT US

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

Selerix Systems, Inc.
Attn: Privacy Officer
2851 Craig Dr., Suite 300
McKinney, TX 75072

Email: legal@selerix.com
Phone: (469) 747-1144

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. The date of the most recent revision will be indicated at the top of this Policy. We will notify you of any material changes by posting the updated Policy on our Site and, where required by law, seeking your consent. We encourage you to review this Policy periodically to stay informed about our information practices. This Privacy Policy is not intended to, and does not, create any contractual or other legal rights in or on behalf of any party.

TERMS AND CONDITIONS OF USE AND NOTICES

If you choose to visit one of our Sites, your visit and any dispute over privacy is subject to this Privacy Policy and our Terms and Conditions, including limitations on damages, arbitration of disputes, and application of the law of the State of Texas. If you have any concern about privacy at Selerix, please send us a thorough description to legal@selerix.com, and we will try to resolve it. Our business changes constantly. This Privacy Policy and the Terms and Conditions will change also, and use of information that we gather now is subject to the Privacy Policy in effect at the time of use. We may e-mail periodic reminders of our notices and conditions, unless you have instructed us not to, and you should check our Sites frequently to see recent changes.

STATE SPECIFIC PROVISIONS

CALIFORNIA RESIDENTS:

In addition to the rights described in Section 5, California residents have the following rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA):

• Right to Know: You may request disclosure of the categories and specific pieces of Personal Information collected, the categories of sources from which Personal Information is collected, the business purpose for collecting or selling Personal Information, and the categories of third parties with whom the business shares personal information. However, Selerix does not sell your Personal Information, as that term is defined under the CPA.
• Right to Opt-Out of Sale: You may opt-out of the sale of personal information to third parties. However, Selerix does not sell your Personal Information, as that term is defined under the CPA.
• Right to Limit Use of Sensitive Personal Information: You may limit the use and disclosure of sensitive Personal Information for certain purposes.
• Right to Correct: You may request correction of inaccurate Personal Information.
• Right to Designate an Authorized Agent: You may designate an authorized agent to make a request on your behalf. Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with written confirmation that you have given the authorized agent permission to submit the request. Authorized agents are required by California law to implement and maintain reasonable security procedures and practices to protect their clients’ information.

Information We Collect. In the 12 months prior to the “last updated” date of this notice, we have collected the following categories of personal information:

• Identifiers, such as name, address, email address, phone number, online identifier, IP address, user ID;
• Personal information as defined in California Customer Records law such as name, address, telephone number, employment;
• Characteristics of protected classifications under California or federal law such as age and sex;
• Commercial information such as Selerix products or services purchase or transaction history;
• Internet or other electronic network activity information such as browsing history, search history, and information regarding your interaction with an internet website application or advertisement;
• Geolocation data, such as zip code;
• Professional or employment-related information; and
• Inferences drawn from any of the above information to create a profile about you reflecting your preferences.
• Personal Information does not include publicly available information.

No Personal Information Sold to or Shared with Third Parties. In the preceding 12 months, we have not sold or shared personal information with third parties for cross-contextual behavioral advertising. “Cross-context behavioral advertising” means advertising that is targeted to you based on personal information obtained from your activity across businesses, distinctly branded internet websites, applications, or services.

We do not knowingly sell or share the personal information of consumers under 13 years of age.

Categories of Information Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose with the following categories of third parties:

Use or Disclosure of Sensitive Personal Information. We do not use or disclose your sensitive Personal Information.

RESIDENTS OF OTHER STATES:

For residents of Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia, or any other state that has a general data privacy law currently in effect, we use our commercially reasonable efforts to comply with all applicable state data privacy laws. If you are a resident of one of these states and have specific questions about your data privacy rights, please contact us using the information provided in Section 12.

NO INTERNATIONAL DATA TRANSFERS

We primarily operate in the United States and do not transfer personal information to countries other than the country in which the data was originally collected for the purposes described in this Privacy Policy. When we transfer personal information across borders, we take appropriate safeguards to protect your information and comply with applicable legal requirements.

ADDITIONAL INFORMATION

• Do Not Track Signals. Some web browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. Our Sites do not currently respond to “Do Not Track” signals.
• Third-Party Links. Our Sites may contain links to third-party websites or services. This Privacy Policy does not apply to such third-party content or services, which are subject to their own privacy policies. We encourage you to read the privacy policies of any third-party websites you visit.
• Accessibility. We are committed to ensuring that our Privacy Policy is accessible to individuals with disabilities. If you need assistance accessing our Privacy Policy, please contact us using the information provided in Section 12.

By using one of our Sites, you acknowledge that you have read and understood this Privacy Policy and agree to our collection, use, and disclosure practices as described herein. If you do not agree with our policies and practices, you may choose not to use our Sites.