Privacy Policy

CoolSys Privacy Policy

Effective/Last Modified: May 18, 2026

CoolSys, Inc., its affiliates, and subsidiaries (collectively, “CoolSys,” “we,” “us,” and “our”) values its customers, their information, their privacy, and their trust. This Privacy Policy (“Policy”) applies to information collected online from users of our services (the “Services”) or who visit the CoolSys website, www.CoolSys.com, and any other websites and online services that we operate and that include a link to this Policy (collectively, the “Websites”) and explains how we collect, use, and protect that information. This Policy applies to CoolSys’s collection, use, processing, storage, and transfer of information from the Websites. For purposes of this Policy, unless otherwise noted, all references to the Websites include email correspondence of CoolSys’s online forms and other electronic messages between you and the Websites or the Services.

By using any of the Websites or Services, you agree to the terms of the Privacy Policy in effect at the time of use. If you do not agree to the terms of this Privacy Policy, please do not use any of the Websites or Services.

Throughout this Policy, we refer to the term “Personal Information.” “Personal Information” means data that identifies, describes, is associated with, or for which an individual’s identity may reasonably be determined, such as a name, birthdate, postal address, email address, telephone number, driver’s license number, Social Security Number or other government-issued identification number, credit card number, or other unique identifiers. It does not include information publicly available, such as information appearing in federal, state, or local records.

Personal Information does not include anonymous or aggregated data that can no longer be used to identify a specific person, even if combined with other data. Also, we may collect information related to businesses, companies, institutions, or other entities, and their employees, rather than individuals acting in a personal capacity (“Business Information”). We do not consider Business Information, such as title, employer’s name, work email, work phone number, work address, and other similar business information, to be Personal Information.

In some jurisdictions, certain Personal Information is considered “Sensitive Personal Information.” “Sensitive Personal Information” includes your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data used to identify a person, health-related data, and sexual orientation.

Information We Collect or Process:

When you use or access the Websites or Services, we may collect Personal Information directly from you, such as the following:

Identifiers, such as name, email address, mailing address, and phone number.

Information you submit when you contact us through the Websites or Services.

Information regarding employment opportunities, work engagements, or right-to-work confirmations.

Financial information, such as invoicing, bank account, and billing information.

Resumes, CVs, work history, qualifications, role preferences, and compensation expectations.

Transaction information, such as when and where the transactions occur, the names of the transacting parties, a description of the transactions, the payment amounts, and the devices and payment methods used to complete the transactions.

We collect information about you and the devices you use to access the Websites and Services, such as your computer, mobile phone, or tablet. This includes:

Information about your device, including your hardware model, operating system and version, device name, unique device identifier, mobile network information, and information about the device’s interaction with our Services

We also may collect certain other information automatically when you visit the Websites or use the Services, such as the following:

Browser and Device Information: Certain information may be automatically collected by most browsers or devices, such as information about user devices (such as IP addresses and MAC addresses), operating systems, and browsers.

Information Stored in Cookies. The Websites and Services may also use available web-based technologies to collect Personal Information, such as cookies, pixels, or web beacons. Cookies are pieces of information stored directly on users’ computers or devices. Cookies allow us to collect information such as browser type, time spent on online services, pages visited, referring URL, and other traffic and usage data. We may also use cookies for purposes such as determining what features interest our users, revising our site features or operations, and as further described below. For more information, see the Managing and Blocking Cookies and Your Choices section below.

Pixel Tags and Log Files: The Websites and Services may also use other tracking systems, such as log files and pixel tags. For example, pixel tags, sometimes called web beacons, are similar in function to a cookie and can tell us certain information like what content has been viewed.

Information Collected in Connection with Analytics Technology: We may use various technologies to learn more about how visitors use the Websites and as part of our marketing activities, to help us analyze how visitors use the Websites. The information generated by the cookies about your use of the Websites includes your IP address and device IDs. If you so choose, you may be able to opt out by turning off cookies in the preferences settings in your browser. We may also use other technologies to monitor your activities on our Websites.

In some parts of our Websites and through email messages, you will find a “click-through URL” linked to content on our Websites. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click such links in our email messages.

We may also collect information about you from other users of our Services, including:

Information about you from third parties in connection with any recruitment activities, work interests, interview scheduling, identity or account verification process, or as may otherwise be required by applicable law.

We may also collect information about you from third parties, including:

Information you make publicly available on or through services such as Indeed or LinkedIn, such as your job interests, CVs, resumes, job history, education history, or other information you have shared with the third-party provider.

On our Websites, we may use one or more of the following cookies:

Strictly Necessary Cookies: These are used to provide necessary information to the Websites and to prevent fraudulent activity, to improve security, and for the administration of the Websites.

Functional and Preference Cookies: These are used to remember choices you make regarding the Websites and help remember you when you visit the Websites to manage your access and privileges.

Performance Cookies: These are used to collect information about how you use our Websites and improve the Websites’ performance by showing us pages you visit, any difficulties experienced, and whether or not the content provided is effective.

Targeting Cookies: These cookies may be placed on our Websites by us or our third-party partners and are used to show you advertisements for goods and services that are targeted to your interests based on your actions on our Websites and information submitted by users of our Websites. These personalized advertisements may appear on our Websites or the websites of our third-party partners. We also use these to provide you with content that is tailored to your interests.

Social Media Cookies: Social media cookies are cookies set by social media services that we have added to the website to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests.

Depending upon your relationship with us, the following is a list of Personal Information that we may have collected from consumers within the last 12 months:

Category	Examples
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
B. Personal information categories	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, credit history, credit score, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.
C. Protected classification characteristics	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial Information	Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
F. Geolocation data	Physical location or movements.
G. Professional or employment-related information	Current or past job history or performance evaluations, resumes, CVs, certificate or license numbers.
H. Non-public education information	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
I. Criminal Record Information	Driving offenses, convictions, motor vehicle driving records.
J. Inferences drawn from other Personal Information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Website Analytics

We may use various technologies to learn more about how visitors use the Websites, such as Google Analytics and Hotjar. Google Analytics uses cookies to help us analyze how visitors use the Websites. The information generated by the cookies about your use of the Websites includes your IP address. If you so choose, you may be able to opt out by turning off cookies in the preferences settings in your browser. For more information on Google Analytics, including how Google Analytics collects, uses, and discloses information, refer to the following page: www.google.com/policies/privacy/partners/. Hotjar is used to record user visits to provide information regarding how visitors use the Websites. We may also use other technologies to monitor your activities on the Websites.

Third Party Service Providers, Marketing, and Advertising

Some content or applications, including advertisements, on the Websites are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. We use Facebook/Meta. LinkedIn, QuantCast, and Google Ads cookies for purposes of targeted advertising of our services we think may be of interest to you and to allow you to interact directly with our social media and to enable you to share content with your networks. The information that third-party cookies collect may be associated with your Personal Information, or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services (i.e., tracking such activities). They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. More information on how to opt-out of third-party advertiser tracking mechanisms can be found at www.networkadvertising.org/choices or www.youronlinechoices.com.

Managing and Blocking Cookies

Through browser settings, you can manage or block the use of cookies. In addition, you can use opt-out tools for ad networks and firms that participate in the Network Advertising Initiative as http://optout.networkadvertising.org/ or the Digital Advertising Alliance as http://optout.aboutads.info/.

To effectively manage cookies via browser settings or through these ad industry opt-out tools, you must opt-out and set cookie preferences on all browsers and all devices that you use. If you clear the browser cache or cookies, be sure to reset your preferences.

Please note that blocking or disabling cookies may prevent or impair functionality and use of the Websites.

Please see your browsers’ help files for additional information about viewing and changing your browser settings to manage or block cookies.

Your Choices

You may choose not to provide the Personal Information we request through the Websites and Services. However, not providing information we request may restrict your ability to use certain features of the Websites and Services. For example, you may be able to restrict the collection of Personal Information or functionality through your device’s operating system or by disabling cookies, but doing so may prevent you from using the functionality of the Websites or Services. Some Internet browsers have a “do-not-track” feature that let you tell the Websites or Services that you do not want to have your online activities tracked. At this time, the Websites and Services do not respond to browser “do-not-track” signals. We have configured our Websites to detect and honor Global Privacy Control (“GPC”) signals.

How and Why We Use Your Information

We may use, disclose, transmit, transfer, store, and otherwise process the information described in the Information We Collect and Process section for various purposes, including the following:

Providing, developing, maintaining, personalizing, protecting, and improving the Websites, Services, and services we offer and provide to you and others.

Operating, evaluating, debugging, identifying and repairing errors, effectuating similar functional enhancements, and improving our Websites, Services, or other services.

Understanding how you and other users use our Websites, Services, and other services, performing analytics, analyzing and reporting on usage and performance of the Websites, Services, and marketing materials, and determining what features and services may interest you and our business customers.

Managing advertising and marketing activities, including engaging in targeted and cross-context behavioral advertising and offering surveys, contests, giveaways, and other promotions.

Communicating with you and others, including responding to your requests and providing promotional information.

Storing information about your preferences, recognizing you when you use the Websites, Services, and customizing your experience.

Synchronizing users across devices, affiliates, business partners, business customers, and select third parties.

Creating aggregate or deidentified data.

Legal and safety purposes, such as maintaining the safety, security, and integrity of our Websites and Services, other technology assets, services, and our organization, preserving or enforcing our legal rights and property; protecting our users, our employees, and others, and complying with industry standards.

Protecting against malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.

Enforcing our policies, terms of use, contracts, or other legal rights.

Evaluating or participating in an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceedings.

Complying with law and legal obligations.

We only use your Personal Information for the original purposes it was given, as described in this Policy, and to further our legitimate interests, such as to provide information about our organization and services, and to communicate with visitors of our Websites, and such other purposes as you may authorize or that we otherwise disclose.

Our employees and agents may view your Personal Information to perform their jobs and address your needs. We authorize their access to your Personal Information on a need-to-know basis to provide you with information or services, or for one of the other reasons listed in this section, and always in connection with an obligation to protect the privacy of that information.

Disclosure of your Personal Information

We do not sell, rent, or lease any information we collect from you to others for monetary compensation. However, we may disclose personal information to third parties for targeted advertising or cross-context behavioral advertising purposes, which may be considered “sharing” or a “sale” under applicable state privacy laws. You may opt-out of these activities by updating your preferences on our Website or by letting us know using the contact information in the “Contact Information” section below. We do not make your Personal Information available to any unaffiliated parties, unless we tell you we will do so, or as described below:

We may disclose your Personal Information to our third-party business partners, service providers, and contractors who are engaged to help us provide the Services, including those services that you request on the Websites.

To comply with applicable law, other legal requirements, and industry standards.

To enforce our policies, terms of use, contracts, or other legal rights.

To investigate or prevent unlawful activities or misuse of the Websites or Services.

To protect against malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.

To operate, evaluate, debug, identify and repair errors, effectuate similar functional enhancements, and improve our Websites, Services, or other services.

To protect the legal rights, property, safety, and security of us, our users, our employees, and others.

When required to do so by law, regulation, or in response to a subpoena or court order, or in response to duly authorized information requests from law enforcement or other government authorities.

When the Company believes in its sole discretion that disclosure is reasonably necessary to protect the property, rights, or safety of the Company or its contractors, partners, affiliates, or employees.

To an actual or potential buyer, successor, or other organization in the event of an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceedings.

In the preceding 12 months, the following categories of Personal Information may have been disclosed to the categories of third parties defined above:

Category	Examples	Disclosed for a Business Purpose in Last 12 Months?	Types of Third Parties Shared With
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes	Affiliates, third-party service providers, business partners
B. Personal information categories	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, credit history, credit score, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.	Yes	Affiliates, third-party service providers, business partners
C. Protected classification characteristics	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	No
D. Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes	Third-party service providers
G. Geolocation data	Physical location or movements.	No
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment-related information	Current or past job history or performance evaluations, resumes, CVs, certificate or license numbers.	Yes	Affiliates, third-party service providers, business partners
J. Non-public education information	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Criminal Record Information	Driving offenses, convictions, motor vehicle driving records.	Yes	Affiliates, third-party service providers, business partners
M. Inferences drawn from other Personal Information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes	Affiliates, third-party service providers, business partners

Children’s Information

Our Websites and Services are not directed at children. We do not knowingly collect Personal Information from anyone under the age of 18. If you are a parent or guardian and believe your child has provided us with Personal Information without your consent, please contact us by using the information in the Contact Information section, below, and we will take steps to remove such Personal Information from our systems.

Data Transfers

We will only transfer Personal Information outside the United States for the reasons described in Information We Collect or Process section above.

Your Rights in Relation to Your Personal Information

You may have the certain legal rights in relation to our use of your Personal Information.

Some jurisdictions (state, federal, national, and international) provide individuals with certain rights regarding their Personal Information. Examples of these laws (without limitation) are: California (California Consumer Protection Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”)), Colorado Privacy Act (“CPA”), Connecticut Data Protection Act (“CTDPA”), Utah Consumer Privacy Act (“UCPA”), and Virginia Consumer Data Protection Act (“VCDPA”), and the General Data Protection Regulation (“GDPR”). To exercise any rights your jurisdiction may provide, please use the contact information provided in the Contact Information section. Your rights will depend on the location in which you reside when your Personal Information is collected or otherwise processed. The following illustrates the rights that may be afforded under these laws or your jurisdiction collectively:

Being informed about how we obtain and process your Personal Information;

Viewing and obtaining a copy of the Personal Information we maintain about you;

Amending or revising Personal Information we maintain about you;

Having Personal Information we maintain about you erased or forgotten;

Objecting to the use of your Personal Information for direct marketing;

Restricting our use of the Personal Information we maintain about you;

Transferring the Personal Information we maintain about you to another entity who will provide substantially similar services;

Objecting to our use of Personal Information we maintain about you;

Objecting to automated decision making based on your Personal Information;

Objecting to automated profiling based on your Personal Information;

Knowing from where we obtained your Personal Information;

To receive the same services (to the extent possible) at the same price regardless of whether you exercise your individual rights under this statement;

Withdrawing your previously provided consent (this right may only be available on a prospective basis); or

Filing a complaint with us or the appropriate governmental entity.

Some states require specific information regarding our practices and that your rights be provided to you in the form of a privacy notice. These notices are provided in the State Specific Notices section below.

Only you or your authorized agent may make requests related to your personal information. We may require that you verify your identity before exercising your individual rights. We may also verify the identity of your authorized agent and ask they provide us with a legally binding document signed by you and identifying them as your authorized agent. In most circumstances, individual rights are not absolute, and where applicable law permits or requires, we may choose to limit or deny a request. If we limit or deny a request, we will provide an explanation in writing.

We will respond to your request within thirty (30) days of receipt. The period of response may be extended to forty-five (45) or sixty (60) days if more time is required. In that event, we will inform you of the reason and extension period in writing.

State Specific Notices:

Right to confirmation of processing	California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, Virginia
Right to access	California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, Virginia
Right to correction	California, Colorado, Connecticut, Delaware, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Virginia
Right to data portability	California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, Virginia
Right to deletion	California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, Virginia
Right to opt-out of processing for targeted advertising	California, Colorado, Connecticut, Delaware, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, Virginia
Right to opt-out from a sale of personal data	California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, Virginia
Right to opt-out from profiling for certain decisions with legal or similarly significant effect	Colorado, Connecticut, Delaware, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Virginia
Right to non-discrimination for exercising your rights	California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, Virginia
Right to appeal the refusal of a request to exercise your rights	Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Virginia
Right to confirm the third parties or categories of third parties to which personal data has been disclosed	Delaware, Oregon
Right to limit the use and disclosure of sensitive personal data	California
Right to opt-out from sharing for cross-context behavioral advertising	California

Depending on your location and subject to applicable law, you may have the right to request confirmation of whether we process Personal Information relating to you, and if so, to request a copy.

Security and Retention

We maintain reasonable security measures at an appropriate level or risk associated with processing your Personal Information to protect it from unauthorized access, use, disclosure, alteration, and destruction. We also require our third-party vendor to implement reasonable security measures to protect any data they may process on our behalf. Unfortunately, no data transmission can be guaranteed to be 100% secure. Thus, we cannot guarantee or warrant the security of any information you transmit to us, and you do so at your own risk.

We keep your Personal Information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (such as for tax, accounting, or other legal requirements).

Third-party Links

The Websites or Services may include links to other websites, applications, information, and services provided by third parties. We are not responsible for the privacy policies or practices of those third parties. We encourage you to review the applicable privacy policies of such third parties if you elect to follow the links provided.

Policy Updates

We may update this Policy to reflect changes in our privacy practices at any time and without prior notice to you. When we do so, we will update the effective and last updated date above.

Contact Information

If you have any questions or comments about this Policy or our privacy practices, or if you would like to exercise any of your rights, please contact us by email at privacy@coolsys.com or by mail at 145 S. State College Boulevard, Suite 200, Brea, California 92821.

CoolSys Privacy Policy

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