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Legal|Last Updated: 2025-12-15|Version 2.0

Privacy Policy

PRIVACY POLICY

Last updated December 15, 2025

This Privacy Notice for Operion LLC (doing business as Operion) ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

  • Visit our website at operion.io, or any website of ours that links to this Privacy Notice
  • Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@operion.io.


SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. This includes browser fingerprints, IP addresses, device characteristics, and browsing behavior. Learn more →

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more →

In what situations and with which parties do we share personal information? We share information with analytics service providers (PostHog, Google Analytics) and may share in specific business situations. Learn more →

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. Learn more →

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more →

How do you exercise your rights? The easiest way to exercise your rights is by contacting us at support@operion.io. We will consider and act upon any request in accordance with applicable data protection laws.


TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
  4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
  7. HOW LONG DO WE KEEP YOUR INFORMATION?
  8. HOW DO WE KEEP YOUR INFORMATION SAFE?
  9. DO WE COLLECT INFORMATION FROM MINORS?
  10. WHAT ARE YOUR PRIVACY RIGHTS?
  11. CONTROLS FOR DO-NOT-TRACK FEATURES
  12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  13. DO WE MAKE UPDATES TO THIS NOTICE?
  14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • Names
  • Phone numbers
  • Email addresses
  • Job titles
  • Usernames
  • Passwords
  • Contact preferences
  • Debit/credit card numbers

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address, browser fingerprint, and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, for fraud prevention, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies, localStorage, and similar technologies.

The information we collect includes:

Browser Fingerprinting and Device Identification

We use browser fingerprinting technology (specifically, FingerprintJS) to create a unique identifier for your browser and device. This technology analyzes a combination of your browser and device characteristics to generate a stable identifier that persists across sessions.

What is collected for fingerprinting:

  • Browser type, version, and configuration settings
  • Operating system and version
  • Screen resolution, color depth, and pixel ratio
  • Installed fonts and font rendering characteristics
  • Available plugins and extensions
  • Hardware characteristics (CPU class, GPU information, device memory)
  • Audio and canvas fingerprinting data
  • Timezone, language settings, and keyboard layout
  • Touch support and sensor information

How we use fingerprinting:

  • Fraud prevention and bot detection
  • Security and abuse prevention
  • Session continuity across page visits
  • Analytics and understanding user journeys
  • Improving our Services

Storage: The fingerprint itself is computed in your browser but not stored on your device. We receive the computed fingerprint identifier and store it in our internal analytics database along with your session information, IP address, and browsing activity.

Your choices: You can use privacy-focused browsers (Firefox with Enhanced Tracking Protection, Brave, Tor Browser) or browser extensions that randomize fingerprinting signals. However, this may limit some functionality of our Services.

Session Tracking via localStorage

We use your browser's localStorage (not cookies) to store:

  • Session ID (operion_sid) - A unique identifier for your current browsing session
  • Last Activity Timestamp (operion_last_active) - When you last interacted with our Services

Session Management:

  • Sessions expire after 30 minutes of inactivity
  • A new session ID is generated if you return after the timeout period
  • This data stays on your device and is not automatically transmitted to us

Your control: You can clear localStorage through your browser settings (usually found under "Clear Browsing Data" > "Cookies and other site data").

Log and Usage Data

Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include:

  • IP address (used to determine approximate geographic location)
  • Device information (device type, model, manufacturer)
  • Browser type and settings
  • Date/time stamps of your visits
  • Pages and files viewed
  • Clicks, scrolls, and other interactions
  • Search queries within our Services
  • Referrer URL (the page that linked you to us)
  • Device event information (system activity, error reports, hardware settings)

This data is stored in our internal PostgreSQL database and is also shared with third-party analytics providers (see Section 4).

Device Data

We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include:

  • IP address (or proxy server)
  • Device and application identification numbers
  • Browser type
  • Hardware model and specifications
  • Internet service provider and/or mobile carrier
  • Operating system and system configuration
  • Installed fonts and system capabilities

Location Data

We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services.

  • IP-based location: We determine your approximate geographic location (city/region level) based on your IP address
  • Timezone-based location: Your device's timezone setting

You can opt out of allowing us to collect precise location information by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.


2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts
  • To deliver and facilitate delivery of services to the user
  • To understand how you use our Services through analytics and usage patterns
  • To improve our Services based on aggregated usage data
  • To detect and prevent fraud and abusive behavior using browser fingerprinting
  • To maintain security of our Services and prevent unauthorized access
  • To send you marketing and promotional communications (with your consent)
  • To comply with our legal obligations under applicable laws
  • To save or protect an individual's vital interest such as to prevent harm

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent →

For browser fingerprinting used for analytics purposes, we rely on your explicit consent. For strictly necessary security and fraud prevention purposes, we may rely on legitimate interests (see below).

Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

  • Detect and prevent fraud and malicious activity
  • Ensure security of our Services
  • Diagnose problems and improve our Services

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • For identifying injured, ill, or deceased persons and communicating with next of kin
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

Third-Party Analytics Providers

We share your personal information with third-party analytics services to help us understand how you use our Services and to improve them:

PostHog (posthog.com)

  • Location: United States
  • What we share: Event data (pageviews, clicks, scrolls), your visitor ID (from fingerprinting), session ID, timestamps, URL paths, and custom event properties
  • Cross-border transfer: Yes (US-based company processing EU/UK data)
  • Their use: Product analytics, user journey analysis, feature usage tracking
  • Privacy Policy: https://posthog.com/privacy
  • Data processing agreement: Yes, we have a DPA in place
  • Your control: Contact us at support@operion.io to request opt-out

Google Analytics 4 (google.com)

  • Location: United States
  • What we share: Event data, client ID (mapped to your visitor ID), session ID, page paths, and interaction data
  • Cross-border transfer: Yes (US-based company processing EU/UK data)
  • Their use: Website analytics, performance measurement, aggregated reporting
  • Privacy Policy: https://policies.google.com/privacy
  • Your control: Google Analytics Opt-out Browser Add-on

FingerprintJS (fingerprint.com)

  • Service: Browser fingerprinting technology
  • What we share: Your browser and device characteristics (sent to their API for fingerprint computation)
  • Location: United States
  • Their use: Compute stable browser fingerprint identifier
  • Privacy Policy: https://fingerprint.com/privacy-policy/
  • Note: We use their client-side library; fingerprint computation happens in your browser

Other Sharing Scenarios

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

With Your Consent. We may disclose your personal information for any other purpose with your consent.


5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We use a combination of cookies, localStorage, and browser fingerprinting to collect and store information about your use of our Services.

First-Party Tracking

localStorage (Browser Storage)

We store the following data in your browser's localStorage:

| Name | Purpose | Expiration | |------|---------|------------| | operion_sid | Session identifier | 30 minutes after inactivity | | operion_last_active | Activity timestamp for session management | 30 minutes after inactivity |

What is localStorage? localStorage is a browser storage mechanism that persists data even after you close your browser, until you manually clear it. Unlike cookies, localStorage data is not automatically sent to our servers with every request.

Your control: You can clear localStorage through your browser settings under "Clear Browsing Data" > "Cookies and other site data." This will reset your session.

Browser Fingerprinting

We use FingerprintJS to create a stable identifier for your browser. This is NOT stored as a cookie or in localStorage but is regenerated on each page visit based on your browser's unique characteristics.

Legal classification: Browser fingerprinting is considered personal data processing under GDPR and CCPA. For analytics purposes, we obtain your explicit consent. For essential security and fraud prevention, we rely on legitimate interests.

Third-Party Tracking Technologies

PostHog Cookies and Storage

PostHog uses both cookies and localStorage for tracking:

| Name | Type | Purpose | Duration | |------|------|---------|----------| | ph_* cookies | Cookie | Session and user identification | Persistent (varies) | | PostHog localStorage | localStorage | User properties, session data | Persistent |

Configuration: We configure PostHog with persistence: 'localStorage+cookie' to ensure robust tracking across sessions.

Google Analytics Cookies

Google Analytics uses cookies for tracking:

| Name | Purpose | Duration | |------|---------|----------| | _ga | User identification | 2 years | | _ga_* | Session and campaign tracking | 2 years | | _gid | User identification | 24 hours |

Your Control and Opt-Out Options

LocalStorage: Clear through browser settings (Developer Tools > Application > Local Storage, or browser's "Clear Browsing Data" feature).

Cookies: You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Services may become inaccessible or not function properly.

Browser Fingerprinting:

  • Use privacy-focused browsers (Firefox with Enhanced Tracking Protection, Brave, Tor Browser)
  • Install browser extensions that randomize fingerprinting signals (e.g., Canvas Defender, Chameleon)
  • Note: Randomization may cause difficulties with session continuity and may affect functionality

Third-Party Opt-Out:

  • Google Analytics: Use the Google Analytics Opt-out Browser Add-on
  • PostHog: Contact us at support@operion.io to request permanent opt-out
  • Global Privacy Control (GPC): We honor GPC browser signals for California residents (CPRA requirement)

Do Not Track (DNT): See Section 11 for our DNT policy.

Cookie Consent Management: For EU/UK visitors, we provide a consent banner that allows you to accept or reject non-essential tracking technologies before they are activated.


6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Our AI Products

Our AI Products are designed for the following functions:

  • AI automation and workflow optimization
  • AI-powered chatbots and conversational interfaces
  • AI development tools and platforms

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.

AI Training: We do not use your personal data to train AI models without your explicit consent.


7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

Specific retention periods:

| Data Type | Retention Period | |-----------|------------------| | Browser fingerprints (visitor IDs) | 12 months from last activity | | Session data | 30 minutes after inactivity (then deleted) | | Analytics events in database | 12 months from event date | | Account information | 12 months from account deactivation | | Marketing communications data | Until you unsubscribe + 30 days |

No purpose in this notice will require us keeping your personal information for longer than twelve (12) months past the start of the idle period of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Backup retention: Data in backup archives is retained for 90 days and then permanently deleted.


8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

Our security measures include:

  • Encryption: All data transmitted between your browser and our servers is encrypted using TLS/SSL
  • Database security: Our PostgreSQL database is protected with authentication, encryption at rest, and network isolation
  • Access controls: Role-based access control limits who can access your data
  • Regular security audits: We conduct periodic security reviews of our systems
  • Secure development practices: We follow secure coding standards and conduct code reviews

Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.


9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services.

If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@operion.io.


10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right:

  • (i) to request access and obtain a copy of your personal information
  • (ii) to request rectification or erasure
  • (iii) to restrict the processing of your personal information
  • (iv) if applicable, to data portability
  • (v) not to be subject to automated decision-making

In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in Section 14.

We will consider and act upon any request in accordance with applicable data protection laws.

Withdrawing Your Consent

If we are relying on your consent to process your personal information (such as for browser fingerprinting for analytics purposes), you have the right to withdraw your consent at any time. You can withdraw your consent at any time by:

  1. Adjusting your consent preferences in our consent banner
  2. Contacting us at support@operion.io

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting Out of Marketing and Promotional Communications

You can unsubscribe from our marketing and promotional communications at any time by:

  • Clicking on the unsubscribe link in the emails that we send
  • Replying "STOP" or "UNSUBSCRIBE" to the SMS messages that we send
  • Contacting us using the details provided in Section 14

You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Log in to your account settings and update your user account
  • Contact us at support@operion.io

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and Similar Technologies

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

Request Data Deletion

You have the right to request deletion of your personal data, including:

  • Browser fingerprints stored in our database
  • Session and analytics data
  • Account information

To request deletion, contact us at support@operion.io with "Data Deletion Request" in the subject line.

If you have questions or comments about your privacy rights, you may email us at support@operion.io.


11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.

At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

However, we DO honor Global Privacy Control (GPC) signals for California residents as required by the California Privacy Rights Act (CPRA). If your browser sends a GPC signal, we will treat it as an opt-out request for the sale/sharing of personal information.

If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.


12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

| Category | Examples | Collected | |----------|----------|-----------| | A. Identifiers | IP address, browser fingerprint, session ID, user ID (if provided via URL parameter), email address, name | YES | | B. Personal information as defined in the California Customer Records statute | Name, contact information, employment information, financial information | YES (Name, email, phone if provided) | | C. Protected classification characteristics under state or federal law | Gender, age, date of birth, race and ethnicity, national origin, marital status | NO | | D. Commercial information | Transaction information, purchase history, financial details, payment information | YES (if you make a purchase) | | E. Biometric information | Fingerprints and voiceprints | NO | | F. Internet or other similar network activity | Browsing history, pages viewed, clicks, scrolls, session duration, search queries, interactions with our Services | YES | | G. Geolocation data | Approximate location based on IP address | YES | | H. Audio, electronic, sensory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO | | I. Professional or employment-related information | Business contact details, job title, work history (if you apply for a job) | YES (if provided) | | J. Education Information | Student records and directory information | NO | | K. Inferences drawn from collected personal information | Inferences drawn from any of the collected personal information listed above to create a profile about your preferences and characteristics | YES (usage patterns, preferences) | | L. Sensitive personal Information | | NO |

We do not "sell" personal information in the traditional sense (exchanging data for money). However, sharing data with analytics providers like Google Analytics may be considered a "sale" or "sharing" under certain state laws.

Sources of Personal Information

Learn more about the sources of personal information we collect in Section 1: "What Information Do We Collect?"

How We Use and Share Personal Information

Learn more about how we use your personal information in Section 2: "How Do We Process Your Information?"

Learn more about when and with whom we share your personal information in Section 4: "When and With Whom Do We Share Your Personal Information?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months beyond our analytics providers (PostHog, Google Analytics). We will not sell or share personal information in the future belonging to website visitors, users, and other consumers except as required for analytics purposes with your consent or as disclosed in this policy.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

  • Right to know whether or not we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with us
  • Right to non-discrimination for exercising your rights
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects

Depending upon the state where you live, you may also have the following rights:

  • Right to access the categories of personal data being processed (Minnesota)
  • Right to obtain a list of the categories of third parties to which we have disclosed personal data (California, Delaware)
  • Right to obtain a list of specific third parties to which we have disclosed personal data (Minnesota, Oregon)
  • Right to limit use and disclosure of sensitive personal data (California)
  • Right to opt out of the collection of sensitive data and personal data collected through voice or facial recognition (Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by:

  • Email: support@operion.io
  • Visiting: operion.io/contact

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request.

However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at support@operion.io. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.

If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact details provided in Section 14.


13. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

Version History:

  • Version 2.0 (December 15, 2025) - Added browser fingerprinting disclosures, localStorage tracking, updated CCPA categories
  • Version 1.0 (February 15, 2025) - Initial policy

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at support@operion.io or contact us by post at:

Operion LLC
5473 Blair Rd Ste 100
Dallas, TX 75231
United States


15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information.

These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please:

  • Email us at: support@operion.io
  • Subject line: "Data Subject Access Request" or "Data Deletion Request"
  • Include: Your name, email address, and specific request

We will respond to your request within 30 days as required by applicable law.

Questions about this policy? Contact us at support@operion.io

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