Privacy Policy

Effective Date: January 1st, 2026 (“Effective Date”).

Correlatio, Inc. (“Correlatio” “we” “us” “our”) is committed to maintaining the confidentiality, integrity, and security of your personal information and has created the following policy “Privacy Policy” or “Policy” to inform you about the type of information we gather about you when you visit our website www.correlatio.io (the “Site”) and how it is used, and the protections we offer to safeguard your personal information. The words “you,” and “your” refer to any visitor or user of the Site.

This Privacy Policy describes the types of information, including Personal Information (defined below), that we gather from you when you use the Site, as well as your choices regarding use and disclosure of your Personal Information and our practices for collecting, using, maintaining, protecting, and disclosing such information. As used in this Privacy Policy, the phrase Personal Information (defined under the Virginia Consumer Data Protection Act Va. Code Section 59.1-575 and following) means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal Information” does not include de-identified data or publicly available information.  "De-identified data" means data that cannot reasonably be linked to an identified or identifiable natural person, or a device linked to such person. Personal Information includes:

  • First and Last Names of users 

  • Business Names 

  • Business Addresses 

  • Telephone numbers

  • E-mail addresses

This Privacy Policy does not apply to any information collected from you or provided by you to third-party websites that may be linked to or accessible from or through our Site.

Your Agreement to Comply with the Privacy Policy – Changes to the Privacy Policy

By accessing or using the Site, you agree to be bound by this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use our Site. We reserve the right to update or modify this Privacy Policy from time to time. We will notify you of any changes by revising the “Effective Date” at the top of this Privacy Policy. If we make any material changes to this Privacy Policy or the way we use, share, or collect Personal Information, we will post an announcement of the changes on our Site, prior to the new policy taking effect. Your accessing or using our Site, our products or services constitutes consideration and your binding acceptance to any such changes in the Privacy Policy. We encourage you to review this Privacy Policy regularly to ensure that you are familiar with our current practices.

Information Collected by the Site

When you use our Site, Correlatio collects: (i) information that you knowingly and voluntarily provide (such as through forms or profile screens, if any may be presented on the Site) including registration and account set-up ; (ii) information that we are able to collect from your web browser, mobile device, Cookies (defined below) and other similar technologies; (iii) information in the form of records and copies of correspondence (including e-mail addresses, if you contact us); (iv) information that includes your search queries on the Site. We may collect information about your internet connection, the equipment you use to access our Site and usage details. We may aggregate or De-identify information that we collect from you, including Personal Information, for the purpose of internal research, marketing campaigns, and advertising of our products and services.

Information that you Knowingly and Willingly Provide (Personal Information and Payment Information)

We collect information that you knowingly and voluntarily provide when you use our Site, such as through web forms, profile screens, registration or account setup information, profile details, Payment Information (defined below) and information you choose to include in any open text memo fields. We primarily use this information to fulfill your transaction requests by transferring this information to our 3rd party payment processor (our “Payment Processor”). Payment Processor uses its software and Application Processing Interfaces (“APIs”) to process your applications and payments. You can choose not to provide us with certain Personal Information, but then you may not be able to take advantage of the Site or make payments and other available features we offer.

Personal Information is used primarily to process payments and is entered by you and sent directly to our Payment Processor for payment processing.

If payments are made by you through the Site, Payment Information needs to be collected in order to process your payment. “Payment Information” that is provided by you is sent directly to the Payment Processor to process your Payment Information below:

  • Credit and Debit Card account numbers

  • CVV Codes

  • Expiration Date of the Credit or Debit Card

  • Any other information required or used by the Payment Processor for payment processing

Once our Payment Processor saves the data, we have access to limited data elements. We do not have access to the full credit card number or the CVV number on the reverse of the card. We save only limited Payment Information so that we can:

  • Identify and show the user the current card on file in the “Change Payment Method” interface; and

  • Send reminders when the user’s card is scheduled to expire, prompting users to change or update their credit card information.

How Correlatio Uses Your Personal Information

Personal Information is collected and stored on the non-public database that powers the Site. We collect Personal Information on its own or may combine it with other information we have about you in order to:

  • Present our Site and its contents to you

  • Create user accounts and profiles through registration;

  • Perform internal operations, such as tracking and improving the effectiveness of our Site and marketing efforts;

  • Provide products, services, and Site fulfillment, such as creating accounts, managing purchases, payments, and fulfilling orders;

  • Provide you with notices about your account, subscription, including expiration and renewal notices;

  • Personalize user experiences, such as remembering your settings and preferences for things like notification preferences, language, and font size;

  • Provide user support;

  • Advertise and market our products and Sites (but not third-party sites);

  • Notify you about changes to the Site or any products or services we offer or provide through it;

  • Provide information to our representatives and advisors, such as our attorneys, accountants, and others, to help us comply with legal, accounting, and security requirements;

  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

  • Protect the rights, safety, and information of Site users and third parties, as well as our own. This includes fraud prevention, business, or product recalls, prosecuting and defending a court arbitration or similar proceedings; and

  • Comply with legal requirements, such as responses to a subpoena, service of process, or similar legal or investigative requirements or demands.

How We May Disclose Personal Information that We Collect

Correlatio may disclose your Personal Information in the following instances:

  • Third Parties. We employ other companies and individuals to perform functions on our behalf.  For example, Payment Information that is entered by you goes directly to the Payment Processor and is used to process your payment.   We share some or all of our users’ Personal Information with these third parties as we deem necessary for such third parties to perform their functions. 

  • Our Employees. We authorize our employees to access your Personal Information for official uses only.

  • To Comply with Legal Process, Protect the Site, or enforce our rights. We may release your Personal Information when it is necessary to: (a) conform to legal requirements or comply with legal process, such as a court order; (b) enforce or apply our Terms of Use and other agreements; (c) protect the rights, safety or property of Correlatio, our affiliates, Site providers, our users, or the public.

  • As Part of a Merger or Sale of Business. We may disclose your Personal Information in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy, but only the minimum required to complete such business transactions or as required by law.

  • Other Disclosures. We may also disclose your Personal Information as otherwise set forth in this Privacy Policy, as permitted by law, or with your consent.

  • We do not knowingly permit the collection of online behavioral information nor do we permit the collection of any such behavioral information by third parties from our users. We do not permit third-party advertising on the Site and we do not have any third-party content providers providing any data to our Site.

Age Restriction

As a requirement to use our Site, you acknowledge that you are not younger than 18 years of age and that you will not provide the Personal Information of any individual under the age of 18. If you are under the age of 18, do not use or provide any information on this Site or through any of its features or provide any information about yourself to us. We do not collect or use anyone’s age information, but, if we learn that we have collected or received Personal Information from anyone under the age of 18, without verification of parental consent, we will delete all such information.

Non-Personal Information – Site Visitation Data

As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns. For example, we collect standard information about Site users such as IP addresses, browser types, operating systems, referring and exit pages, the dates and times of visits, and other Site usage data (“Site Visitation Data”). Site Visitation Data is used to administer the Site and provide general statistics regarding the use of the Site. Site Visitation Data is collected and does not include Personal Information. Site Visitation Data helps us to improve our Site and to deliver a better and more personalized service, including enabling us to: (i) estimate our audience size and usage patterns; (ii) store information about your preferences, allowing us to customize our Site according to your individual interests; (iii) speed up your searches; and (iv) recognize you when you return to our Site.

When you visit our Site, we may store information about your session and assign you one or more Cookies. “Cookies” are small blocks of data created by a web server while a user is browsing a website and are placed on the user's computer or other device by the user's web browser. Your browser will store these Cookies on your computer in a small text file, and if you return to the Site the Cookie may be read. For example, when you decide to log in, we store encrypted information in your browser so you don't have to log in on every page. Cookies are not linked to your Personal Information. We use our Payment Processor for processing credit card data. These services may save Cookies to the user's browser. We do not access this Cookie data for any reason.

We may also use web beacons, clear gif technology, or other similar devices as mechanisms to collect aggregate Site Visitation Data by tracking how users navigate to and through our Site. We may also use this technology to track the delivery of email messages.

Permanent cookie files remain on your computer’s hard drive until you delete them manually using your browser or operating system software. You can set your browser to refuse cookies, but doing so may disable access to some Sites and tools that we offer. We do not use third-party cookies to track your behavior on other websites.

We do not collect personal information automatically, but we may tie this Site Visitation Data to Personal Information about you that we collect from other sources or you provide to us.

State Specific Provisions

State consumer privacy laws may provide their residents with additional rights regarding our use of their Personal Information. Definitions as to the meaning of Personal Information may differ among the states, so you need to check the definition of “Personal Information” for any individual state.

To learn more about consumer privacy rights in other states and how to exercise them, visit the specific state statutes below using the text hyperlinks.

CALIFORNIA – California Consumer Protection Act CCPA regulations (as of 3-22-2023): 

https://govt.westlaw.com/calregs/Browse/Home/California/CaliforniaCodeofRegulations?guid=I5E53FC80FEDE11ECA3A49C17D1AA5D7C&originationContext=documenttoc&transitionType=Default&contextData=(sc.Default)

CPRA  The CPRA (California Privacy Rights Act) is more accurately described as an amendment of the CCPA. The CPRA specifically states that it “amends” existing provisions of Title 1.81.5 of the California Civil Code (currently known as the CCPA) and “adds” new provisions (related to the establishment of the California Privacy Protection Agency).

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes, if any.   The Site does not share or disclose any Personal Information to any parties for their marketing purposes.  

Colorado: (Consumer Protection - Section Colorado Privacy Act Rules 4 CCR-904-3)

https://coag.gov/app/uploads/2022/10/CPA_Final-Draft-Rules-9.29.22.pdf

Connecticut: (The Connecticut Data Privacy Act or “CTDPA”)

https://portal.ct.gov/AG/Sections/Privacy/The-Connecticut-Data-Privacy-Act

Utah: (Utah Consumer Privacy Act)

https://casetext.com/statute/utah-code/title-13-commerce-and-trade/chapter-61-utah-consumer-privacy-act

Virginia: (Consumer Data Protection Act)

https://law.lis.virginia.gov/vacode/title59.1/chapter53/

Colorado, Connecticut, Virginia, and Utah, in very general terms, each provide their state residents with rights to:

  • Confirm whether a website will process their Personal Information.

  • Access and delete certain Personal Information.

  • Data portability.

  • Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia, in very general terms also provide their state residents with rights to:

  • Correct inaccuracies in their Personal Information, taking into account the information's nature, processing, and purpose.

  • Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To receive additional information about these state laws and regulations, or to exercise any of these rights please notify us at info@correlatio.io or by U.S. mail at: 2900 Polo Parkway, Suite: 200 , Midlothian, VA 23113.

Nevada NRS §603A.300

Nevada provides its residents with a limited right to opt-out of certain Personal Information sales to third parties. Nevada residents who wish to exercise this sale opt-out rights may submit a request to this designated address: info@correlatio.io or by U.S. mail at: 2900 Polo Parkway, Suite: 200 , Midlothian, VA 23113. However, please know we do not currently sell data that would trigger Nevada’s opt-out requirements.

Third Party Sites

We are not responsible for the privacy policies or practices of any third-party including sites or services directly linked to or embedded within our Site. We encourage you to review the privacy policies of any third-party site that you visit.

Storage

The Personal Information that you provide to us is generally stored on servers located in the United States. If you are located in another jurisdiction, you explicitly ACKNOWLEDGE AND CONSENT that once your Personal Information is submitted through our Site, it will be transferred to our servers in the United States and that the United States currently does not have uniform data protection laws in place. Further, the United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the General Data Protection Regulation (“GDPR”) of the European Union. For residents of the European Union, we rely on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, we collect and transfer to the U.S. Personal Information of European Union residents only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms.

Retention

We will retain your information for as long as your account is active or as needed to provide you with our Sites. If you wish to cancel your account or request that we no longer use your information to provide you Site usage and services, contact us at info@correlatio.io. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Data Controller

Correlatio, Inc., A Corporation is your data controller. A data controller makes decisions regarding and is responsible for the collection, use, disclosure, retention, and protection of your Personal Information in accordance with this privacy notice, as well as any applicable national laws. As your data controller, we may transfer data to our affiliates who agree to the obligations of this privacy notice. We may process and retain your personal information on our servers in the U.S. and elsewhere in the world where our data centers are located. If you have questions regarding your Personal Information, please contact us using the contact information set forth in the “Privacy Inquiries” section below.

Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any Payment Information goes directly to our Payment Processor and will be encrypted using SSL technology. When you enter your Payment Information it is sent directly to the Payment Processor, so such information is not monitored nor collected except for limited information we mention above in this Privacy Policy.

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 Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards, if any exist. The information you share in public areas may be viewed by any user of the Site. 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 Site. 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 Site.

Information Correction, Removal, and Opting-Out

Correction & Removal

If any of the information that we have about you is incorrect, or you wish to have information (including Personal Information) removed from our records, please contact us at info@correlatio.io. We will respond to such inquiries within fifteen (15) business days.

Opting Out

Additionally, if you prefer not to receive marketing messages from us, please let us know by clicking on the unsubscribe link within any marketing message that you receive, or by sending a message to us at info@correlatio.io. Some communications (for example, important account notifications and billing information) are considered transactional and are necessary for all of our users. You must cancel your Correlatio account to unsubscribe from these transactional communications. To cancel your account, please email us at info@correlatio.io.

Exercising Consumer Rights Under Virginia Law

Users may exercise their rights pursuant to Section 59.1-577 of the Virginia Consumer Data Protection Act, including how a user may appeal a decision with regard to the user’s request or may submit a request to exercise their consumer rights under the Virginia Consumer Data Protection Act, by contacting Correlatio:

  • By emailing us at info@correlatio.io

  • By mail post to: 2900 Polo Parkway, Suite: 200 , Midlothian, VA 23113.

Privacy Inquiries

If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us as follows:

  • By emailing us at info@correlatio.io

  • By mail post to: 2900 Polo Parkway, Suite: 200 , Midlothian, VA 23113.


Effective Date: January 31st, 2026

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