Privacy Policy

CARALLEL, INC. (“Carallel”) PRIVACY POLICY (“Privacy Policy”)

(Effective Date: April 2023)

Carallel cares about your data privacy.  Our goal is to allow you to use our services with an understanding of rights and our obligations. Please take the time to review this Privacy Policy and our End User License Agreement for users (“EULA”) and the website Terms of Use.



This Privacy Policy is part of and incorporated into the EULA and Terms of Use that apply to and control your use and access of our Services.  Any capitalized terms that are not defined in this Privacy Policy are defined in the EULA and Terms of Use.  This Privacy Policy, the EULA and the Terms of Use are intended to only apply to United States residents.


We may update this Privacy Policy, and we encourage you to check the effective date of this Privacy Policy whenever you use our Services to see if there have been any changes since your last visit.  We may update this Policy to reflect changes to our information practices. Use of information we collect now is subject to the Policy in effect at the time such information is used. You are bound by any changes to our Policy when you use the Services after such changes have been first posted. We encourage you to periodically review this policy for the latest information on our privacy practices. Your continued use of our Services is your agreement to any of those changes.


When you use our Services, we collect certain information about you automatically through our use of technologies.  Information, based on your usage and navigation of our Services, may be collected by Us or our third party service providers using website analytics tools or other technologies, like cookies and web beacons, in order to collect information about your visit to and use of our Services, including the Website pages you visit, links you click and other actions you may take while using our Services.  We may also collect standard information that your browser automatically sends to the websites you visit, such as your IP address, browser type/language, and other information.  All of this navigation and usage information (together, “Usage Information”) and the technologies that provide it help us to improve your usage experience, for instance, by enabling the number of times you see certain information, to better determine what you may like to see, or to alert you to software compatibility issues.  Usage Information is not considered your Information for the purposes of this Privacy Policy.

Please find below a short description of some of the technologies we may use to collect Usage Information; the list below is not intended to be comprehensive, as we continually update our systems to provide you with the best possible online experience.

  • “Cookies” are small text files that are inserted and stored by your web browser on your computer’s hard drive. They help us determine what parts of the Website you visited, and also help us analyze and improve the design and technology of our Services.  Your browser may permit you to disable cookies; please refer to your browser settings for further information.  However, if you disable cookies, you may not be able to use all of the features and functions of our Services, and any settings or preferences you previously set that are controlled by the cookies may no longer be available.
  • “Web beacons” are images embedded in a web page or email for the purpose of measuring and analyzing website usage and activity. We, or third party service providers acting on our behalf, may use web beacons to help us analyze Website usage and improve your online experience. We may use third party service providers to help us analyze certain online activities and improve the Websites and any product or service offerings available on the Websites. We may permit these service providers to use cookies and other technologies to perform these services for us. We do not share any of your Information with these third party service providers, and these service providers do not collect any of your Information on our behalf.

Use and Disclosure of Usage Information

We may use and disclose the Usage Information to improve our products and Services.

We may also share, disclose or transfer Usage Information in connection with a merger, sale of all or some of our assets, debt financing, or other corporate event, including for transaction due diligence (collectively, a “Corporate Change”).  In the event of a Corporate Change, we may transfer the Usage Information, in whole or in part, to the relevant third part(ies) and, if the Corporate Change actually occurs, the Usage Information will then be subject to the privacy policies of the third part(ies).

We may also use and disclose the Usage Information as required by law, when we believe it is appropriate to comply with law enforcement requests, and/or to enforce this Privacy Policy, or otherwise to protect Carallel’s and Carallel’s users’ rights, property or safety.

Do Not Track Disclosures 

No action is taken in response to web browser “do not track” signals or other mechanisms that provide users the ability to exercise choice regarding the collection of personally identifiable information about an individual’s online activities over time and across third-party web sites or online services. Although we use Google Analytics and other third party tracking tools for our Services, we are not aware if third parties collect personally identifiable information about an individual’s online activities when the individual uses our Services.


Information We Share

We collect your information from your Sponsor and directly from you, those whom you have authorized to use your account, or those for whom you may be seeking information or Services from us.  Your Information may include your name, email address, phone number and zip code, any information about you provided by you and/or your Sponsor in order to permit your access to our Services, and other personally identifiable information, including protected health information of those for whom you may be seeking information or our Services.

Any information you upload to is not shared by us with any third party, including the Sponsor.

If you are sharing information about someone for whom you are seeking information or our Services, you must be legally authorized to share such Information.

We do not sell your name, email address or other information to third parties for their direct marketing purposes.

We may use, share and disclose your Information:

  • To provide you with the information and Services you have requested from us, we may provide your Information to third parties to permit us to fulfill your request. For example, if you request us to identify certain specialized housing options, we may disclose your Information, as applicable, to the third parties from whom we gather the information. Upon your request, which we relay, these third parties may contact you directly by email, telephone, regular mail, in person visits or other means. We do not control how these third parties use or disclose your Information.
  • To provide your Information to your Sponsor at your request in order to provide our Services.
  • To your Sponsor in aggregate and/or anonymous form for its analytic, service delivery or other purposes, as may be described in an agreement between you and your Sponsor or otherwise in the Sponsor’s own privacy policy.
  • With third parties who perform services on our behalf, or give them access to collect your Information; these services may include information processing, customer data management, customer research and the like.
  • To answer your questions, or provide you with information you requested, or to provide you with information about your account, registration or use of our Services; you may not opt out of these communications.
  • With our related companies, such as affiliates, subsidiaries, joint ventures, or other companies under common control with us, in which case we will require them to honor this Privacy Policy.
  • With respect to any other purposes disclosed at the time you provide your Information.

In addition, we may also use your Information for our own internal business purposes including statistical, design or operational purposes, such as to estimate our audience size, measure aggregate traffic patterns and understand demographic trends among our users.

We may use your email address or cell phone number to send you any periodic text, email or newsletter communications on topics generally relevant to our users.  In that event, we will provide you with an opportunity to opt-out and/or unsubscribe to such communications.

Please note, if you wish to opt out of communications with your Sponsor or third parties whom Carallel has contacted on your behalf, you must contact your Sponsor or those third parties directly; we do not have any control over the communication practices of your Sponsor or those third parties.

Except as described in this Privacy Policy, we will not share your Information with third parties without your consent.


Certain of your Information may be updated directly on the Websites or our other applications or systems.  If not, you may update your Information by emailing us at [email protected]. We will use reasonable efforts to update your Information as soon as possible, but you understand that it may not be possible to completely delete information from our systems, including any backup systems.


We retain and dispose of your Information in accordance with our general record retention policies and do not have any obligation or liability to you or any party with respect to any information, including your Information, that is so deleted. With respect to all personal data, where the purpose of the processing is satisfied or where consent to processing has been withdrawn, such data will be deleted and/or de-identified unless we need to retain it for legal or compliance purposes.


Our Services are delivered and maintained in the United States, and your Information will be processed and shared in the United States, where the laws and protections regarding data and information may be different from those of other countries.  Our Services are intended for use solely by or on behalf of individuals located in the United States.    If you (or anybody authorized by you to use your account, or the person(s) for whom you are using our Services) are located in a country other than the United States, please be aware that your Information will be transferred to the United States and, by providing such information, you consent to such transfer.


We collect and use Usage Information as described in this Privacy Policy.  We may also create aggregated, anonymized information that may include or be based upon Usage Information and your Information, along with the similar information of other users (“Aggregated Information”).  You are not identifiable in Aggregated Information.  Aggregated Information is not considered your Information for the purposes of this Privacy Policy.

We may use, disclose, share and/or sell Aggregated Information for any purpose, including providing it to third parties for their own business or marketing purposes.


Our Websites may contain links to other websites and information solely for your convenience.  Those other websites may have privacy policies different from ours and they may treat your Information differently, including sharing it based on their own privacy policies.  Any use of such other websites and/or any information you provide to or through such other websites will be subject to the terms of use and privacy policies of those other websites and not this Privacy Policy.


The security of your Information is important to Us.  While we have established administrative, physical and technical safeguards in compliance with applicable law and general industry standards, to safeguard and secure your Information from unauthorized access or disclosure, we do not and cannot guarantee that any information, including your Information, is 100% secure.  You understand that no storage, processing or transfer of your Information or any other information can be guaranteed to be completely secure.


We do not knowingly collect any information, including your Information, from children under the age of 13.


If you are a resident of California, Colorado, Connecticut, Utah or Virginia, you may have one or more of the following rights in accordance with the California Consumer Privacy Act of 2018 and as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), the Colorado Privacy Act of 2021 (“CPA”), the Virginia Consumer Data Protection Act of 2021 (“VCDPA”), the Utah Consumer Privacy Act of 2022 (“UCPA”), and the Connecticut Data Privacy Act of 2022 (“CDPA”) and any and all regulations arising therefrom.  We will honor requests received to the extent required by applicable law and within the time provided by law.

  • Request to Access. You have the right to request that we disclose to you the categories and specific pieces of personal data we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:
    • Whether we are processing personal information about you;
    • The categories of personal data we have collected about you;
    • The categories of sources from which the personal data is collected;
    • Our business or commercial purpose for collecting, selling or sharing personal data;
    • The categories of third parties with whom we disclose personal data;
    • The specific pieces of data we have collected about you;
    • The categories of personal data about you, if any, that we have sold or shared and the categories of personal data for each category of third party to whom we sold or shared the personal data; and
    • The categories of personal data about you that we disclosed for a business purpose and the categories of persons to whom we disclosed the information for a business purpose.
  • Request to Correct. You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data.
  • Request to Delete. You have the right to delete the personal data provided to us by you. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.
  • Data Portability. You have the right to obtain a copy of the personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your personal data to another controller without hindrance, where the processing is carried out by automated means.
  • Request to Opt-Out.  You have the right to opt-out of the sale and sharing of your personal data with third parties. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising, as defined in the CCPA, CPA, VCDPA, UCPA, and CDPA.
  • Sensitive Information. You have the right to consent to the use of your sensitive personal information in CO, CT, VA and UT. Separately, you have the right in CA to instruct us to limit the use and disclosure of your sensitive personal information to only that which is necessary to perform our Services or provide the information reasonably expected by an average consumer or for specific business purposes defined by law. However, we do not use sensitive personal information for purposes beyond those authorized by the CCPA, or beyond your consent.
  • Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.
  • Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the relevant Attorney General.

If you like to make any of the above requests, you can contact us at [email protected] or by mail at the address provided below. If you choose to submit a request, you must provide us with enough information to identify you in order to comply with your request. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or if such person is a known child, that child’s parent or legal guardian.

You may designate an authorized agent to exercise your rights under the CCPA on your behalf. Such individual must have power of attorney, or be an authorized agent registered with the relevant Secretary of State.

Special Notice to Nevada Residents

We do not sell, rent, or lease your personally identifiable information to third parties. However, if you are a resident of Nevada and would like to submit a request not to sell your personally identifiable information, you may do so by emailing us at [email protected].


If you have any questions about this Privacy Policy, please contact us at [email protected].


We may modify this Privacy Policy from time-to-time and will post such modifications prominently on the Website(s). Please review this Privacy Policy each time you visit our Website(s) or access our Services.  If you do not agree with a modification, your sole remedy is to not provide any additional your Information after the effective date of such modification and/or to stop using our Services.