1. Introduction

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Bastazo, Inc., a Delaware corporation (“Company”, “we”, “us” or “our”), respects your privacy and is committed to protecting it through our compliance with this privacy policy (“Policy”).

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This Policy describes the types of information we may collect from you or that you may provide when you visit the website https://www.bastazo.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. 

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This Policy pertains to information we collect through your use and interaction with the Website, and not to any information collected by us offline or by any third party. 

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By using the Website, or by providing personally identifiable information to us, you expressly consent to the collection and use of the information as described in this Policy. The purpose of this Policy is to provide you with clear and understandable information about our privacy practices. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Policy.

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2. Information We Collect

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We collect several types of information from and about users of our Website, including but not limited to the following:

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• Usage data: browser type, operating system, pages visited, time spent on pages, and clickstream data.
• Device and technical information: IP address, device identifiers, and geolocation data.
• Cookies and tracking technologies: we use or may use “cookies”, web beacons, and similar technologies to enhance user experience and analyze website traffic. Users can manage cookie preferences via their browser settings.
• Contact forms and submissions: information voluntarily submitted, such as name, email address, company name, and message content.

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We may use both session cookies and persistent cookies to better understand how you interact with our Website, to monitor aggregate usage by our users and web traffic routing on our Website, and to improve our Website. Authorized third parties may also place their own cookies on our Website and may collect personal information. For more information about how we use cookies and the cookies you are consenting to use by visiting our website, review our Cookie Policy attached as Exhibit A to this Policy.

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3. Methods of Data Collection

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Data is collected through multiple channels to ensure accuracy and completeness:

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• Direct collection: information provided directly by users through their use of the Website.
• Automated Website collection: data collected automatically through your interaction with our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Collection and/or retention of any other data that our users independently provide to us in their use of the Website.

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4. Use of Information

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The information we collect is processed for purposes including, but not limited to, the following:

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• To present our Website and its contents to you.
• To operate, maintain, and improve our Website.
• To respond to inquiries submitted through our contact forms.
• To analyze website traffic and usage patterns for performance optimization.
• To comply with legal obligations and enforce Website terms of use.
• To provide marketing communications, subject to user consent where required by law.
• For any other purpose with your consent.

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5. Disclosure of Information

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We may disclose personal and technical information to the following categories of recipients:

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• Affiliates and subsidiaries: entities within our corporate group, subject to equivalent data protection obligations.
• Service providers and sub-processors: third parties who provide technical support, hosting, analytics, or other services integral to our operations, pursuant to appropriate data processing agreements.
• Regulatory authorities and legal requests: governmental agencies, regulatory bodies, or law enforcement pursuant to lawful requests, subpoenas, or legal mandates.
• Corporate transactions: in connection with any merger, acquisition, asset sale, or other business reorganization, subject to appropriate confidentiality obligations.
• To fulfill the purpose for which you provide it.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

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6. Legal Basis for Processing (Where Applicable)

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In jurisdictions subject to comprehensive data protection laws, including but not limited to the General Data Protection Regulation (EU and UK GDPR) and the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), we rely on the following lawful bases:

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• Contractual necessity: processing necessary for the performance of a contract to which the data subject is a party.
• Legitimate interests: processing necessary for the purposes of our legitimate interests, provided such interests are not overridden by the data subject’s rights.
• Legal obligations: processing required for compliance with a legal or regulatory obligation.
• Consent: processing based on the data subject’s explicit consent, particularly for marketing and non-essential data collection.

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7. Data Security 

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We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website 

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8. Data Subject Rights

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Subject to jurisdiction-specific laws, you may exercise the following rights regarding the collection and use of your data:

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• Right of access: obtain confirmation as to whether personal data is being processed and access to such data.
• Right to rectification: request correction of inaccurate or incomplete data.
• Right to erasure: request deletion of personal data where legally permissible.
• Right to restrict processing: request limitation on data processing under certain conditions.
• Right to data portability: receive personal data in a structured, commonly used, and machine-readable format.
• Right to object: object to processing based on legitimate interests or for direct marketing.
• Right to withdraw consent: withdraw consent at any time, without affecting the lawfulness of processing prior to withdrawal.

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We provide an opt-out choice for most types of communication, such as updates from us regarding new services and product releases (if any). You may opt out from the use of your personal information for those non-required communications. Your opt-out choice may be exercised by clicking on the link provided in the emails you receive or by sending an unsubscribe request to privacy@bastazo.com.

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Users cannot opt out of certain communications that are necessary for the operation of our Website and to send notices and other disclosures as required by law. We may also communicate by phone to resolve customer complaints or investigate suspicious transactions. 

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9. State Privacy Rights

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California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

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• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah).
• Data portability.
• Opt-out of personal data processing for:
  
  • targeted advertising (excluding Iowa);
  • sales; or 
  • profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
• Either limit (opt-out of) or require consent to process sensitive personal data. 

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The exact scope of these rights may vary by state. To exercise any of these rights or to appeal a decision regarding a consumer rights request, please contact privacy@bastazo.com. Requests to exercise these rights will be addressed in accordance with applicable legal requirements.

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10. Children’s Data

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Our business is not focused on, nor do we knowingly collect information from children under the age of 13. If a parent or guardian becomes aware that their child under 13 has provided us with personally identifiable information, they should contact us at privacy@bastazo.com. If we become aware that a child under 13 has provided us with personally identifiable information, we will remove that information.

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11. Changes to this Policy

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We reserve the right to amend or update this Policy at our discretion to reflect changes in legal obligations, technological advancements, or business practices. The latest version will be published on our Website, and the effective date of the most recent revision will be clearly indicated. We encourage periodic review of this Policy to stay informed.

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12. Contact Us

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For questions, concerns, or requests regarding this Policy or our data protection practices, please contact us at privacy@bastazo.com. 

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EXHIBIT A

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COOKIE POLICY

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By visiting our Website with your browser settings adjusted to accept cookies you consent to our use of cookies as described in this Policy.

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What Are Cookies?

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Cookies are small data files that are stored on your computer or other device when you visit a website. They allow the site to recognize your device on subsequent visits and remember your preferences.

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Our Use of Cookies

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We use cookies to allow our systems to recognize your device and collect website usage data. Cookies allow us to understand how our Website is used and to improve its functionality and use. Some cookies may collect personal data in order to perform their intended functions. 

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We may use both session cookies and persistent cookies to better understand how you interact with the Website. In addition, please be aware that other parties may also place their own cookies on the Website, and may collect or solicit personal information from you. A session cookie enables certain features of the website and is deleted from your computer when you disconnect from or leave the Website. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Website.

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We may match information we gather from cookies with other information you provide to us. We will only use such information as described in our Policy that is posted on our Website.

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Cookie Type

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Strictly necessary cookies

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Anonymous cookies that allow visitors to navigate around our Website, use its features and access secure areas. The information gathered by these cookies may be used for security purposes, but is not used for marketing purposes. If the use of this type of cookies is not allowed, certain parts of our Website may not be used.

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Analytics cookies

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Anonymous cookies that help us improve our website by collecting information about how visitors use our Website. For example, we track what pages are visited the most often and what error messages are shown. GoogleAnalytics cookies are an example of this type of cookie.

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The information gathered by these cookies is not used for targeted marketing and is not distributed to third parties.

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Functionality cookies

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Functionality cookies that allow us to remember visitor choices and preferences. Based on this information, we can show you more relevant information. For example, we may gather country and language preferences.

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If you do not allow the use of this type of cookie, it will prevent the use of certain parts of our Website and will prevent us from remembering your preferences.

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Advertising cookies

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With our permission, this type of cookie is placed on our Website by third parties such as advertising networks. These cookies are used to:

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• Show relevant and personalized advertisements;
• Measure the effectiveness of an advertising campaign; or
• Remember your visit and share data collected with third parties, such as advertisers. Often these cookies are linked to website functionality provided by the third party.

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Social Media cookies

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Social media cookies collect information about social media usage. We may partner with third parties to provide you with connections to certain social networks, such as Facebook, Twitter, and LinkedIn, and to provide you with additional features. These cookies may also provide to the third parties the information about your visit so that they can present you with advertisements for services we offer which may be of interest to you and help us track the effectiveness of our marketing efforts.

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How to Block or Restrict Cookies

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If you do not want us to place cookies on your device you can modify your browser settings. The “Help” feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or visiting the website of the add-on’s manufacturer. Please note that you may not be able to use certain parts of our Website if you block cookies.

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