Last updated: August 10, 2026
1. Introduction
Darwin CX provides technology and data services that power websites, platforms, and digital experiences for our clients.
This Privacy Policy explains how Darwin CX (“Darwin CX”, “we”, “us”, or “our”) collects, uses, discloses, and protects personal information when individuals interact with those services, including our websites, applications, and client-facing platforms.
You may be using a website or Shop experience operated or branded by one of our clients. In those cases, Darwin CX provides the underlying technology and services that support the collection and use of personal information and the management of privacy preferences on the client’s behalf.
By using these services, you acknowledge that your personal information will be handled as described in this Privacy Policy.
Where privacy choices are presented, Darwin CX may collect and apply your preferences to ensure your selections are respected.
We encourage you to review both this Privacy Policy and any applicable client privacy policy to understand how your information is used.
If you have any questions, please contact us at privacy@darwin.cx.
2. Scope of This Policy
This Policy applies to personal information collected through:
Where Darwin CX provides services on behalf of clients, including client-branded websites and Shop experiences, Darwin CX typically act as a data processor, processing personal information on the client’s instructions.
In these cases, the relevant client privacy policy will also apply, and the client may act as the primary data controller responsible for determining how personal information is used.
Processor Role and Instructions
When processing personal information on behalf of clients, Darwin CX does not determine the purposes of processing and acts only on the client’s documented instructions, except where otherwise required by law.
This Policy does not apply to third-party websites.
3. Personal Information We Collect
We collect personal information to operate and improve our services.
Information You Provide
You may provide information such as:
Information Collected Automatically
We may collect technical and usage information, including:
4. Cookies and Similar Technologies
We use cookies and similar technologies to operate our services, understand usage, and support marketing.
In some cases, these technologies are used within client-branded websites or Shop experiences powered by Darwin CX. In those situations, Darwin CX may apply cookies and similar technologies on behalf of the client.
Consent and Implementation Models
Depending on the configuration of the relevant client implementation, consent management and tracking technologies may be managed either by Darwin CX or by the client.
Cookies are small data files stored on your device when you visit a website.
We use the following categories of cookies:
These cookies are managed in accordance with your privacy preferences, which you can update at any time through Privacy Settings, available on our websites and platforms.
Essential Services (Always Active)
Required for the website to function, including security and core operations. These cannot be disabled.
Analytics and Performance Cookies
Used to understand how users interact with services and improve functionality.
Targeted Advertising Cookies
Used to support advertising and measure effectiveness based on user interactions.
We do not set non-essential cookies without your consent where required. These cookies are managed in accordance with your privacy preferences, which you can update at any time through Privacy Settings, available on our websites and platforms.
5. Consent and Preference Management
Where required, we obtain your consent before collecting or processing personal information through cookies or similar technologies.
When you interact with services provided by Darwin CX, including client-branded websites and Shop experiences, Darwin CX may:
These preferences are applied in accordance with applicable legal and jurisdictional requirements and the configuration of the relevant client implementation.
You can manage your preferences at any time through Privacy Settings, available on our websites and platforms.
6. How We Use Personal Information
We do not sell or rent personal information.
We use personal information to:
We may also use aggregated or de-identified data for analysis.
7. How We Share Personal Information
We may share personal information with:
Service Providers
Third parties that support our services (for example, hosting, analytics, communications, and security). These providers are required to protect personal information.
Affiliates
Companies within the Darwin CX group, where necessary.
Legal and Business Purposes
Where required or permitted by law, including:
8. Your Choices
Email Communications
You can opt out of email communications using the unsubscribe link or by contacting us.
Privacy Requests and Data Subject Rights
You may submit requests to exercise your privacy rights, such as accessing, correcting, or deleting your personal information, through Privacy Settings, where available, or by contacting privacy@darwin.cx. Available options may vary based on your location and applicable laws.
How Requests Are Handled
Where Darwin CX processes personal information on behalf of a client, privacy requests may be handled by the client, by Darwin CX, or jointly, depending on the system or service through which the request is submitted.
If a request is submitted directly to a client, the client may provide the request to Darwin CX where action is required within Darwin CX systems.
Darwin CX will process such requests in accordance with the client’s instructions and applicable agreements.
Where Darwin CX receives a request directly relating to client-controlled data, Darwin CX may notify the relevant client and process the request in coordination with them, or as otherwise required by applicable law.Darwin CX’s ability to act on certain requests may depend on receiving sufficient information and instructions from the relevant client.
Who to Contact
Depending on the context in which your personal information is processed, you may also need to contact the organization whose website or service you are using (the “client”), as they may act as the primary controller of your data and may handle certain requests directly.
9. Data Security
We use appropriate physical, administrative, and technical safeguards to protect personal information.
No system is completely secure, and transmission over the Internet cannot be guaranteed.
10. Data Retention
We retain personal information only as long as necessary for the purposes described in this Policy, unless required or permitted by law.
11. Location and International Transfers
Darwin CX operates globally and provides services across multiple jurisdictions.
When delivering services to clients, Darwin CX typically acts as a data processor, processing personal information on documented instructions from the client.
Personal information may be:
This may include information such as names, contact details, account identifiers, and usage-related information.
Data Residency and Storage
Personal information is stored and processed in cloud environments selected to support applicable data residency requirements agreed with the client.
Where configured, data is designed to remain within the source jurisdiction (for example, Canada, the United States, the United Kingdom, or Germany).
Our platform is designed to avoid routine transfers outside the agreed jurisdiction where feasible.
International Transfers
Personal information is not transferred internationally unless required for service delivery or permitted by the client.
Where transfers occur, we apply appropriate safeguards, including:
Enforcement of User Preferences
We apply user privacy and consent choices in line with applicable legal requirements.
Where users provide consent preferences:
12. Individuals in the European Union and United Kingdom
Darwin CX processes personal information in the European Union and the United Kingdom in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR).
Darwin CX acts as a data controller for its own activities and as a data processor when acting on behalf of clients.
We process personal data based on lawful grounds such as:
Individuals may request access, correction, deletion, portability, restriction, or objection through Privacy Settings, available on our websites and platforms, or by contacting privacy@darwin.cx, and may lodge a complaint with a supervisory authority.
13. Canadian Residents
Darwin CX complies with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws.
Canadian residents may request access to or correction of their personal information through Privacy Settings, available on our websites and platforms, or by contacting privacy@darwin.cx, and may lodge a complaint with the Office of the Privacy Commissioner of Canada.
Quebec Residents
Darwin CX also complies with Quebec’s Act Respecting the Protection of Personal Information in the Private Sector, as amended by Law 25.
Quebec residents may request access to, correction, or deletion of their personal information through Privacy Settings, available on our websites and platforms, or by contacting privacy@darwin.cx, and may lodge a complaint with the Commission d’accès à l’information du Québec.
14. California Privacy Rights
Darwin CX does not sell personal information and does not discriminate against individuals who exercise their rights under applicable law.
15. Accessibility
This Policy is available in alternative formats upon request.
16. Changes to This Policy
We may update this Policy from time to time. Updates will be posted on our websites.
17. Contact Us
For privacy-related questions or requests:
privacy@darwin.cx
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