Privacy Policy

Tradeswell, Inc., dba Incremental (“Incremental”, “Tradeswell”, “we”, “our” or “us”) understands that privacy is important to our users. Protecting your private information is our priority.

This Privacy Policy discloses our practices regarding information collection and usage for incremental.com (the “Website”) and any communications or services we provide, including our platform, Incremental (collectively, our “Services”), unless another applicable privacy policy is posted on that Service.

With respect to the information that our customers and their vendors collect from you outside of our Services (“Service Data”), we process such information only as a service provider on behalf of our customers in order to provide them our data management and advertising services. Our customers are the business that controls the use of the Service Data and determines the purposes for which we process such information. This policy does describe how we process Service Data on behalf of our customers.

However, our customers are responsible for their own practices in collecting, using and disclosing information they collect from you, including when they use such information on our platform to provide you with online advertising. To learn more about our customer’s use of your information and your rights that you may have over such information, please consult the privacy policy of the applicable company.

Overview: We collect Personally Identifiable Information (as defined below) from users of our Website and Services when it is voluntarily provided to us and use it for the purposes for which it was provided (see Information We Collect Directly From You). We automatically collect information from users of our Website and Services for analytical purposes (see Information We Collect From You Automatically).

We may obtain Service Data from our customers and their vendors which we process on behalf of our customers in accordance with our contract with them.

We will not use or share your information with anyone except as described in this Privacy Policy.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using the Website or Services, you agree to this Privacy Policy. If you do not agree with our policies and practices, you should not use the Website or the Services. If you have questions, you can always contact us using the information in the section below-titled Contact.

Information We Collect Directly From You: We may collect information, including Personally Identifiable Information, from you when you provide such information to us directly, such as when you send us an email or otherwise interact with us on the Website. Your provision of your Personally Identifiable Information to us is completely voluntary. “Personally Identifiable Information” is information that specifically identifies you. We do not collect Personally Identifiable Information unless you submit that information to us. Categories of Personally Identifiable Information we collect directly from you include identity data (e.g., name or other similar identifiers), and contact data (e.g. address, email address, telephone number). We may also collect other information that you directly provide us including marketing and communications data (e.g. your preferences in receiving marketing from us).Information We Collect Automatically: Incremental, our service providers, or our third-party partners may also automatically collect information from you when you visit our Website and use our Services through cookies and other tracking technologies.

Such information does not directly identify you as an individual and may include:

Cookies and Similar Technology We may store some information on your device or device hard drive as a cookie or similar type of file (such as clear gifs, web beacons, tags, and similar technologies that work on mobile devices) to collect data related to usage of the Website or our other Services. “Cookies” are pieces of information that may be placed on your computer by a website for the purpose of collecting data to facilitate and enhance your communication and interaction with that website. Such data may include, without limitation, the address of the websites you visited before and after you visited the Website, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Website you visit and what links you clicked on, the region where your device is located, and geo-IP data.We may use cookies to customize your visit to the Website and for other purposes to make your visit more convenient or to enable us to enhance our Services.Analytics We may work with third-party service providers who use the technologies described in this section to conduct website analytics to help us track and understand how visitors use our Website and other Services.Information We Receive on Behalf of Our Customers As described above, we may receive Service Data on behalf of our customers in order to provide them our data management and advertising services. Service Data that our customers provide us may include demographic information, purchase history, unique identifiers such as cookie IDs or device IDs, and hashed email and mailing addresses.

How We Use Your Information We use your information as described herein including for the following purposes:to contact you about and provide with our Services, to personalize your experience with us including by presenting products or offers tailored to you, to help maintain the safety, security, and integrity of our Website, Services, databases and other technology assets, and business, for internal research for technological development and demonstration and to improve, upgrade or enhance our Website and Services, for detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity, to respond to your direct inquiries, to add you to our mailing lists and send you emails from time to time, for any additional purposes that you specifically consent to As noted above, with respect to Service Data, we use that information to provide Services to our customers.

Subject to the specific jurisdictional rights below or as otherwise provided in this Privacy Policy, we reserve the right to use and disclose information that is not Personally Identifiable Information, such as aggregated or de-identified information (“Non-Personally Identifiable Information”) in any manner permitted by law. We also reserve the right to supplement your Personally Identifiable Information we obtained directly from you with information we gather from other sources, including both online and offline sources. If we combine Personally Identifiable Information and Non-Personally Identifiable Information, we will treat it as Personally Identifiable Information.How We Share Your Information Besides using your Personally Identifiable Information ourselves, we may send your Personally Identifiable Information and other information to other companies, affiliates and third parties in the following instances:We may share your information with our customers who we provide Services, including data management and advertising services through our platform. In addition, we share Service Data as directed by our customers and for the purposes of providing our Services to them.We may share your information with our customers who we provide Services, including data management and advertising services through our platform. In addition, we share Service Data as directed by our customers and for the purposes of providing our Services to them. Service Providers. We may share your Personally Identifiable Information with third parties who may use your information to provide us services such as website hosting, data analysis, infrastructure provision, information technology services, customer service, e-mail delivery services, auditing, and anti-fraud monitoring. These third parties may have access to Personally Identifiable Information that is necessary to perform their functions.

Legal Compliance and to Defend Our Rights. We may disclose Personally Identifiable Information and other information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Business Transfers. We may share your Personally Identifiable Information and other information with third parties in connection with a corporate restructuring, acquisition or divestiture.Aggregated or Non-Personally Identifiable Information. We may share aggregated information or Non-Personally Identifiable Information with unaffiliated third parties, such as business partners, manufacturers, distributors and retailers, in a form in which means the shared information will not contain nor be linked to any Personally Identifiable Information, to improve and enhance your experience using the Website and Services and for our market research activities.Security The security of your information is very important to us. We attempt to provide for the secure transmission of your information from your computer to our servers by utilizing encryption software. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and Incremental, or information stored on the Website, our Services or our servers, will be free from unauthorized access by third parties such as hackers and your use of the Website or Services demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect.

Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personally Identifiable Information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the Contact section below.Data Retention We will retain your information for as long as your account or inquiry is active or as needed to provide you with the Website or Services and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your information, we may continue to retain and use anonymous or aggregated data previously collected. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.Protection for Children Our Website and Services are intended for ages 18 and over. We do not knowingly collect Personally Identifiable Information from minors.

When we become aware that Personally Identifiable Information (or other information that is protected under applicable law) from a child under 13 (or such other age as may be restricted under local law) has been collected, we will use all reasonable efforts to delete such information from our database. If you believe we might have any Personally Identifiable Information from or about a child under 13, please contact us at privacy@incremental.com.Opt-Out To opt-out of any future promotional messages from us, you should send an unsubscribe request to us at privacy@incremental.com. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of the Website or Services may no longer be available to you. If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org.

By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or some of its functionality may be affected.Please note that, unless required by law, we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers.California Privacy Rights California Consumer Privacy Act In order to provide our data management and advertising services to our customers through our platform, we may process Service Data on behalf of our customers. If you are a California resident, you may have certain rights over such information under the California Consumer Privacy Act (CCPA) whether or not that information constitutes Personally Identifiable Information. Under CCPA, we act as a service provider over such information and process your information through our platform as necessary to provide our services to our customers, at our customers’ direction in accordance with our contract with them. If you wish to exercise any of your rights under CCPA in regards to such information, please contact the relevant business that collected the information from you, as they control and determines how your information is processed.California “Shine the Light” We do not disclose your personal information, as defined under California Civil Code Section 1798.83 (“Shine the Light”), to third parties for their direct marketing purposes. Nevada Privacy Rights If you are a Nevada resident, you have the right to request that we do not sell your covered information (as those terms are defined in N.R.S. 603A) that we have collected, or may collect, from you. We do not sell your covered information, however, if you would like to make such a request you may do so by contacting us at privacy@incremental.com.

Changes to policy: We reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time, provided that any such modifications will only be applied prospectively. Your continued use of the Website or Services following the posting of any changes to this policy means you accept such changes.

Contact: For questions or concerns relating to privacy, we can be contacted at: privacy@incremental.com.

Site Maintenance: Our Website is maintained in the United States of America. If you are located outside the U.S., by using the Website, you authorize the export of your information to the USA and its storage and use as specified in this policy.