Privacy Policy
The only corporate card and spend management platform designed to help you spend less.

We take our responsibilities in handling, using, and protecting your personal data seriously, and respect your own personal privacy interests and concerns. ThisPrivacy Policy (“Policy”) describes how Caesar Sustainability, Inc. (“Caesar”,“we”, “our”, “us”) collects, processes, uses, and discloses certain information obtained through your use of our website (the “Website”) as well as through your use of features made available to you through the Website and our Environmental,Social and Governance (“ESG”) Platform (collectively, the “Services”).

InformationWe Collect and Maintain About You.
We collect information from you directly when you provide it to us through ourServices. We also automatically collect certain information about you and your computer/devices when you use, access, or interact with our Services. 

Personal information provided by Account Holders.
If you create an account with us as a user of our Services (as an account holder or customer), we will collect personal information related to creating your account and offering you our Services. This type of information may include your full name, title, company affiliation, e-mail address, company address, contact number, account login ID, password (that you create), messages, and information provided by you to enable us to provide Services or support or evaluate your environmental, social, and governance goals or performance. 

Other Personal Information Collected through the Website.
You may navigate our Website without submitting any personal information. However, if you use certain features on the Website, such as a chat feature, we will collect any personal information associated that you provide through those features. Additionally, if you reply to one of our “Call to Action” submissions or download a demo of our product, we will collect your personal information in relation to those features, including your name and email address. 

ServerLogs.
Server logs automatically record information and details about your online interactions with us. For example, server logs may record information about your visit to our Website or use of our Services on a particular time and day and collect information such as your device ID or IP address. 

Cookies.
Cookies are small files that are stored on your device through visiting Websites or using our Services that allow our Website or Services to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of ourWebsite or Services during your current session and over time (including the pages you view and the files you download), your device’s operating system, your device ID, IP address, and your general geographic location. 

PixelTags.
A pixel tag (also known as a web beacon, clear GIF, pixel, or tag) is an image or a small string of code that may be placed in an advertisement or email. It allows companies to set or read cookies or transfer information to their servers when you load a webpage or interact with online content. For example, we or our service providers may use pixel tags to determine whether you have interacted with a specific part of our Services, viewed a particular advertisement, or opened a specific email. 

SDKs and Mobile Advertising IDs.
OurServices may include third-party software development kits (“SDKs”) that allow us and our service providers to collect information about your activity. In addition, some mobile devices come with a resettable advertising ID (such asApple’s IDFA and Google’s Advertising ID) that, like cookies and pixel tags, allow us and our service providers to identify your mobile device over time for advertising purposes. 

Third-PartyPlugins.OurWebsite and Services may include plugins from other companies, including social media companies. These plugins may collect information, such as information about the pages you visit, and share it with the company that created the plugin even if you do not click on the plugin. These third-party plugins are governed by the privacy policies and terms of the companies that created them. 

Third-PartyOnline Tracking.
We also may partner with certain third parties to collect, analyze, and use some of the personal and other information described in this section. For example, we may allow third parties to set pixels through the Website. This information may be used for a variety of purposes, including analytics and interest-based advertising, as discussed below (see the section entitled “With Whom and Why WeShare Your Information”). 

Aggregated or Deidentified information.
We may also share aggregated or deidentified information about users of ourServices, such as by publishing a report on trends in the usage of theServices. Such aggregated or deidentified information will not identify you personally. 

HowWe Use and Process Your Information.
We use the information that we collect for a variety of purposes, most important, to optimize your experience with our Services. Our legal bases for processing your personal information are: 1) our legitimate interest in running and maintaining our business; 2) performance and fulfillment of our contracts; 3)your consent; and 4) compliance with our legal obligations. In many instances, more than one of these legal bases apply to the processing of your personal information. The purposes for which we use your information include to:

  1. Provide you with our Services;
  2. Respond to your questions or requests concerning the Services;
  3. Fulfill the terms of any agreement you have with us;
  4. Fulfill your requests for ourServices or otherwise complete a transaction that you initiate;
  5. Send you information about ourServices and other topics that are likely to be of interest to you, including newsletters, updates, or other communications, including promotional emails;
  6. Improve our artificial intelligence
    and machine learning;
  7. Deliver confirmations, account information, notifications, and similar operational communications;
  8. Improve your user experience and the quality of our products and Services;
  9. Comply with legal and/or regulatory requirements;
  10. Aggregate and deidentify information;
  11. Benchmark results for our customers;
  12. Serve advertisements;
  13. Analyze how visitors use the Services and various Services features, including to count and recognize visitors to the Services;
  14. Create new products and Services; and
  15. Manage our business. 

With Whom and Why We Share Your Information.
We share your information with third parties for a variety of purposes, as described below. 

  • Referring Third Parties. If you were referred to Caesar by another user who has requested access to data about your company, the information you input about your company through the platform may be shared with the referring third party. 
  • Third-Party Service Providers. We use third-party service providers that perform Services on our behalf, including web-hosting companies, and mailing vendors. These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above. We may also share your information with third parties when necessary to fulfill your requests for Services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business. 
  • Analytics. We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use pixels or server logs, and they may set and access device IDs and IP addresses from your device. 
  • Interest-Based Advertising. TheServices also enable third-party tracking mechanisms to collect information about you and your computing devices for use in online interest-based advertising. For example, third parties, such as Facebook, may use the fact that you visited our App to target online ads to you about our Services. In addition, our third-party advertising networks might use information about your use of our Services to help target advertisements based on your mobile activity in general.   The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies. 
  • Legal Purposes.  We also may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary: to comply with applicable law     or a court order, subpoena, or other legal process; to investigate, prevent, or     take action regarding illegal activities, suspected fraud, violations of     our terms and conditions, or situations involving threats to our property     or the property or physical safety of any person or third party; to establish, protect, or     exercise our legal rights or defend against legal claims; or to facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal     of all or part of our business or assets. 

Your Choices.
If you wish to access, correct, or delete the personal information we have on file, or opt out of marketing emails you receive from us, you may contact us atprivacy@caesarsustainability.com

International Users.
The information that we collect through or in connection with the Services is transferred to and processed in the United States for the purposes described above. We may also subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Services or by providing any information to us, you expressly consent to such transfer and processing. If you are a resident of the EU, UK, or another jurisdiction with an applicable privacy law, you may have certain rights available to you. These rights may include:

  1. The right to be informed about our data collection practices;
  2. The right to access and rectify your data;
  3. The right to erase or delete your data;
  4. The right to data portability;
  5. The right to restrict and object to the processing of your data (including for direct marketing purposes);
  6. The right to opt out of the sale of your information;
  7. The right to opt-out of marketing emails and text messages;
  8. The right to limit our use of any automated decision-making processes;
  9. The right to lodge a complaint to your local data protection authority; and
  10. The right to withdraw consent (to the extent applicable).To exercise any of the rights listed above, please contact us via email at at privacy@caesarsustainability.comand we will respond to your request as soon as reasonably possible but no longer than 30 days. 

External Links.
OurWebsite may contain links to third-party websites. If you use these links, you will leave our Website. We have not reviewed these third-party sites and do not control and are not responsible for any of these sites, their content, or their privacy policy. Thus, we do not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party sites listed on our website, you do so at your own risk. 

Data Security.
We employ physical, technical, and administrative procedures to safeguard the personal information we collect both online and offline. However, no website or platform is 100% secure, and we cannot ensure or warrant the security of any information you transmit to the Services or to us, and you transmit such information at your own risk. 

Data Retention.
We retain personal information about you necessary to fulfill the purpose for which that information was collected or as required or permitted by law. We do not retain personal information longer than is necessary for us to achieve the purposes for which we collected it. When we destroy your personal information, we do so in a way that prevents that information from being restored or reconstructed. 

Changes to this Policy.
Information privacy is an ongoing responsibility, and so we will from time to time update this PrivacyPolicy as we undertake new or revise existing personal data practices and privacy policies. We will notify users of any changes to our Privacy Policy by posting the revised Privacy Policy with an updated date of revision on our Website.Your continued use of our Services following the effective date of such update constitutes your acceptance of the revised Privacy Policy.

Contact Information.
For more information about our privacy practices, or if you have questions or comments, please contact us by email at privacy@caesarsustainability.com.

location

Our offices

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New York, USA:
299 Park Avenue New York,
New York 10171
London, UK:
30 Stamford Street,
London SE1 9LQ