Privacy Policy

This Privacy Policy describes how we collect, use and share your personal data and personal information as defined under applicable data privacy laws (referred to herein as "personal data"), including (1) the types of personal data we collect, (2) from whom we collect personal data including our prospects, customers, partners, job applicants, users, and visitors as further described below ("you", "your", or "users"), (3) the purposes for which we collect it, including in connection with your use of our website(s), for marketing, job application, or other purposes as well as your use of our website in connection with our services offerings using our proprietary SaaS technology; providing support services; providing discussion boards and communication platforms; and collecting video, text, and images as may be shared by you (collectively, the "Service(s)", (4) how we use your personal data, (5) with whom we may share your personal data, (6) what choices are available to you with respect to the use of your personal data, and (6) our compliance efforts to protect your personal data.

• YOUR CONSENT: You consent and agree to the data collection and processing described in this Privacy Policy by visiting, accessing, and/or using our website or Services, and you represent that you are at least 18 years-old. Your use of the website and services is voluntary.
• CALIFORNIA USERS: If you are a California resident, see the California Notice for additional information about your rights and our disclosures. The California Notice is in addition to this privacy policy.
• CALIFORNIA USERS CHOICE AND OPTING OUT: See Section 8 for information about your choices regarding opting out of the sale of your personal data, opting out of cookies, opting out of specific types of advertising, and opting out of use of precise location.
• OTHER UNITED STATES USER RIGHTS: Rights under other US data protection laws are described in Section 9.
• ADDITIONAL RIGHTS FOR OPTING OUT: In addition to California residents' rights for opting-out, see your rights to opt-out in Section 6.
• EEA AND UK USERS RIGHTS: See EEA & UK Data Subject Rights in Section 7.
• CONTACT: If you have questions or wish to contact us, see Section 13.

We reserve the right to change this Privacy Policy from time to time. Please consult this Privacy Policy regularly for updates. See Changes to this Privacy Policy in Section 14.

POLICY OVERVIEW:

We (and the third party service providers we hire to perform business functions on our behalf) may collect, receive, process, and use various categories of personal data about you. The type of personal data we collect about you depends on the nature of your interactions with us and the purposes for which you are using the Services or website. Such personal data may include the following:

• Contact Information and Identifiers:
  • name
  • email address
  • address (residential or business)
  • telephone (home, business or mobile)
  • account identifiers such as social media accounts and user account information
  • Internet Protocol (IP) address
  • Unique device identification number
  • Unique cookie identifiers
• Demographic Information:
  • age range
  • general location
  • profession or employment related information
  • Social media information
• Professional or Employment Related Information: We collect employment information that you may share, such as your job title, department (such as finance, operations, etc.), and position, and we collect any other job-related information that you choose to share.
• Internet and Network Activity Information: When you visit our websites and use the Services, we and our service providers automatically collect and analyze certain information about your use of our websites and the device you used to access our websites including:
  • IP address
  • device type and model
  • network provider, browser type and language, the operating system of your device, applications
  • the date and time you are accessing our websites
  • interactions with our website such as articles downloaded, search terms entered, the content of any undeleted cookies that your browser previously accepted from us, and the referring website address
  • digital fingerprinting
• Information You Choose to Share: including video clips, images, photographs, and documents

Use Purposes: We, or the third parties use the above-referenced categories of personal data for the following purposes:

• To fulfil a contract, or take steps linked to a contract including:
  • validating information you provide to us;
  • communicating with you; and
  • administering our relationship as applicable
• As required by us to conduct our business and pursue our legitimate interests, in particular as necessary:
  • To operate the Services and website, by us and our third party service providers;
  • To allow access, enroll, and/or register as a user of the Services;
  • To target marketing and advertising activities to you from us or third parties, unless we require your consent;
  • For marketing purposes, such as to send you marketing, promotions, and our products which you may be interested in, unless we require your consent;
  • To validate information you provide to us;
  • To provide Services to our customers
  • To provide the findings and analysis to our customers, which they may use in any manner they choose;
  • To create statistical, aggregated, or other similar data derived from your use of the website or Services to improve, maintain, and support the Services;
  • To communicate with you regarding your use, participation, and interaction with our Services and website;
  • To customize the content you see or tailor the experience;
  • To enhance your experience in the use of our website or Services;
  • To ensure the technical functioning of the Services;
  • To develop and improve our Service;
  • To provide customer service and respond to your inquiries and requests;
  • To support, debug, and troubleshoot problems with the Services;
  • For job recruitment purposes;
  • To communicate with you about our relationship, such as updates to the Privacy Policy or our terms of service;
  • Monitor and detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • To enforce the legal terms that govern your use of the Services;
  • Auditing compliance with US data protection laws and other relevant standards; and
  • For any additional uses that are disclosed to you in any terms of service.
• For purposes which are required by law:
  • To verify your identity and comply with any data subject requests, if you make requests pursuant to this Privacy Policy.
• Where you give us consent:
  • where your consent is required, we will send you direct marketing in relation to our relevant Services;
  • where your consent is required, we place cookies and use similar technologies; and
  • on other occasions where we ask you for consent, we will use your personal data for the purpose which we explain at that time.
• No Automated Decision Making:
  • We do not take any decisions involving the use of algorithms or profiling that significantly affect you as an individual.

How We Communicate with You:

We may use your personal data to communicate with you using the following methods:

• "Push notifications" or text messages if you agree to such communications;
• Digital communication via the Services;
• Email communications; and
• Telephone if provided by you.

We collect personal data about you from various sources, directly and indirectly:

• Directly from You: For example, we may prompt you (or you may volunteer) to provide certain personal data if you register on our websites, or engage with our websites.
• Automatically from your devices for our Services: We use tracking tools like browser "cookies", pixels, and web beacons to automatically collect information about you, your device, and your usage when you interact with our Services, websites, online content, ads, or emails. A cookie is a small text file containing information that we can read later for our own business purposes. For the Services and associated websites, we use strictly necessary and statistical cookies to facilitate your access to our websites, improve your user experience, and analyze website traffic including to count visits and monitor traffic sources so we can measure and improve the performance of our site. These cookies help us to know which pages are the most and least popular and see how you move around the site. If you do not allow these cookies, we will not know when you have visited our site, and we will not be able to monitor its performance. We may share your site usage data with our analytics partners and service providers. In addition to strictly necessary and statistical cookies, for our marketing website found at https://oliv.ai, we also use marketing and preference cookies to personalize your experience, track your preferences (such as language), customize your experience, and track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share that information with other organizations or advertisers. These cookies are used to measure the overall effectiveness of our online content, advertising campaigns, and products and services we offer. To learn about your choices for these tracking tools, read Section 6 of this Privacy Policy. If you choose to decline cookies, you may not be able to sign in or use some of the interactive features offered on the website. For our marketing website, we also use standard Internet technologies, such as embedded links on web pages and other similar technologies to track usage across the application. We use web beacons in e-mail messages or newsletters to track whether you open the messages.
• Third Party Service Providers We Hire to Work on our Behalf: For example, vendors or service providers including hosting services providers, network providers, platform service providers, that host, manage, or maintain, analyze, translate, or provide other services for our Services server platform, infrastructure, or website or send promotional emails for us may collect and provide personal data about you including demographic, geo-location, behavioral, consumer preferences and internet activity related data. Our employment and recruiting vendors also provide personal data about you. Our marketing agencies, advertising technology vendors, and analytics providers may also provide us with personal data about you.
• Third Party Services Providers that you Elect to use with the Services: The Services integrate with certain third party products, services and applications ( "Third Party Services") to augment or enhance your use of the Services. You are responsible for enabling the integration of each Third Party Service with which you elect to use the Services and by doing so, you acknowledge that you are instructing us to share your data (including, to the extent necessary, any personal data) with the providers of such Third Party Services in order to facilitate the integration. You are responsible for notifying such Third Party Services providers of the integration. Such Third Party Services are not under our control and we are not responsible for any Third Party Services. Your use of the Third Party Services is governed by your agreement with, and all applicable terms and policies (including privacy and data gathering practices of), the providers of the Third Party Services. You acknowledge and agree that, for the purposes of Applicable Data Protection Laws, each of Company and the Third Party Services providers are not processors or subprocessors of personal data with respect to each other.

We may share or disclose your personal data in the following instances:

• Business partners and marketing companies: With regard to our marketing website, we might share personal data with third party service providers that help us with our marketing efforts, including social media platforms, advertising networks, and ad tech companies. For example, we may share email addresses or other identifiers or contact information with social media platforms so they can serve our advertising to you on their platform. Personal data received by our third party service providers, partners, and other third parties may also be subject to their privacy policies.
• Our Service Providers: We engage service providers to process personal data on our behalf and help us pursue our business purposes, such as analytics, user support, billing and sales activities, data analysis, customer service engagement, email delivery, cloud hosting services, platform services, and marketing assistance. Such service providers may use such data for their own business purposes to enhance, improve, and deliver their services and in such case their use is governed by their privacy policy. For a list of our third party service providers who serve as subprocessors for our platform Services, as may be updated from time to time, please see https://trust.oliv.ai/subprocessors
• Your Third Party Services Providers: We may exchange or share your personal data with your Third Party Services providers to provide you with the Services.
• For Safety, Security, or Legal Compliance Purposes: We might share information in response to subpoenas, court orders, or other legal process (including for national security and law enforcement purposes); to establish or exercise our legal rights or the legal rights of a third party service provider, sponsor, customer, or other research provider (for example to enforce confidentiality or intellectual property rights); to defend against legal claims; or as otherwise required by law; to comply with applicable laws; to protect rights, safety and property of us, our customers, or others; and to respond to lawful requests from public authorities. We might also share personal data to prevent, detect, or investigate suspected fraud, violations of our terms of service, harassment, or illegal conduct.
• Mergers or Reorganizations: If we undergo a business acquisition, merger, or sale of assets, we may transfer your personal data to the successor entity. If we go out of business or enter bankruptcy, your personal data would be an asset transferred to or acquired by a third party.
• Other Disclosures: We may also share personal data for other reasons we may describe to you from time to time as permitted by law, including as disclosed in any conversation-specific disclosures.

Aggregated, Anonymous, or De-identified Statistical Data: We may collect, create, and use aggregated, anonymous, pseudonymous, or de-identified statistical data (including reports and other information derived from your personal data) to improve our Services. Aggregated anonymized information does not contain any personal data, and its use and disclosure are not subject to the terms of this Privacy Policy.

We believe it is important to give you choices about the use of your personal data. We will use your personal data as described in this Privacy Policy or as disclosed in any other terms of service or data protection agreements entered into between us. In the event of a conflict, the terms of service or data protection agreement will govern. If we want to use your personal data for a purpose not authorized in this Privacy Policy, we will first obtain your consent to do so.

• You Can Opt Out of Receiving our Marketing emails: We will respect your wishes not to receive, or stop receiving, marketing communications. You can opt out at any time by using the unsubscribe links or instructions at the bottom of our emails. Please note that we will continue to send you Services-related communications regardless of any such marketing-related request.
• Opt-Outs: The Services may include other options to select the "decline" or "opt-out" option for specified functionality or features, where available. Where we obtain your personal data from a third party services provider, we only process personal data you provide as directed by you.
• You may be able to Block or Remove Cookies through your Browser Settings: We use cookies and other tracking tools to help customize the Services and website and improve your experience, as well as analyze our performance and marketing activities. You may be able to block or delete cookies by going to the preferences, tools, or options menus of your Internet browser. If you choose to do so, some features of the Services may not function properly. Selections you make are device-specific and browser-specific, meaning that you may need to make your selections on each browser and on each device you use to access the Services or website.
• You can Opt Out of having your Online Behavior Recorded and Used for Interest-based Advertising Purposes: Some content or links, including advertisements on the marketing website, are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our websites or Services. The information they collect may be associated with your personal data or they may collect personal data about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third-party tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. To opt out from receiving interest-based advertising from participating companies, visit the opt-out mechanisms of the Digital Advertising Alliance (United States), the Network Advertising Initiative (United States), and the European Interactive Digital Advertising Alliance (European Union). The choices you make are both browser- and device-specific, meaning that you should exercise your preference on each browser and each device you use. If you clear cookies from your browser, you may need to exercise these choices again.
• Our Do-Not-Track Policy: Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature or setting that you can activate. This signals your privacy preference not to have data about your online browsing activities monitored and collected. 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. If a standard for online tracking is adopted that we must follow in the future, we will do so accordingly.
• California Opt Out: For information about additional opt out rights under California law, please see Section 8.

In addition to the options stated above, you may contact/send us notices as described in Section 13, "How to Contact Us."

We operate the websites and Services platform in the United States and, depending on your country of residence, the submission of personal data to our websites or Services platform may involve the collection of such personal data in the United States for our processing. Your personal data may be processed by personnel operating in the United States who work for us or one of our third party service providers or by our personnel and personnel of our third party service providers who may access your personal data remotely globally. As a result, your personal data may be subject to access by and disclosed to the U.S. government and law enforcement agencies according to U.S. laws. If we collect your personal data as a service provider on behalf of a third party, the third party may access and transfer your personal data to locations and countries as described in the third party's privacy policy.

Since your privacy is important to us, we want you to be fully aware of the data protection rights that may be available to you under EEA and UK law if applicable, including the EU General Data Protection Regulation ("GDPR"), the UK General Data Protection Regulation and the Data Protection Act 2018 ("UK GDPR") (collectively as "EU DPLs"). As used herein, "EEA" refers to the European Economic Area.

Lawful basis for processing your personal data in EEA & UK:

We process personal data, as defined under the EU DPLs, on the following legal bases (for more detail about the types of personal data we collect for each legal bases, see Section 2):

• Contract: Where it is necessary to process your personal data for us to perform a contract you have agreed to enter into with us. If you do not provide your personal data to us, we will not be able to carry out our obligations under the terms of the contract.
• Legitimate Interests: We are permitted to process your personal data if it is based on our legitimate interests, such as to understand our users, promote our Services and websites, and operate and maintain our Services and websites. Examples of when we rely on our legitimate interests to use your personal data include: when we analyze what content has been viewed on our websites, to carry out marketing analyses so that we can make our marketing more relevant to your interests and preferences, for internal administrative purposes to operate our business, to respond to your inquiries and to resolve complaints, for security and fraud prevention, and to ensure that our Services and websites are safe and secure and used in line with our contracts with you. You can object to the processing that we carry out on the grounds of legitimate interests. See the subsection "Rights of data subjects" below to find out how.
• Consent: Where you have given us consent to do so, we provide you, or permit third parties on our behalf to provide you, with information about goods or services which we feel may interest you. You have the right to withdraw your consent. Please see the subsection "Rights of EEA & UK Data Subjects" to find out how.
• Legal Claims: We may need to process your personal data to defend or establish a legal claim (for example, claims relating to the sale of our goods and services under contract law).

Rights of EEA & UK Data Subjects:

Users accessing Services from the EEA & UK are entitled to the following rights where the EU DPLs apply (which may be exercised against us or, if we are not the controller):

• The Right to be Informed – You have the right to be provided with clear, transparent, and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Privacy Policy.
• The Right to Access – You have the right to request access to your personal data that is within our possession.
• The Right to Rectification – You have the right to request that we correct any personal data you believe is inaccurate. You also have the right to request that we complete the personal data if you believe it is incomplete.
• The Right to Erasure – This is also known as the "right to be forgotten." You have the right to request that we erase your personal data, if there is no compelling reason for us to keep using it or if it is no longer necessary in relation to the purposes for which it was originally collected or otherwise processed. This is not a general right to erasure; there are exceptions.
• The Right to Restrict Processing – You have the right to request that we restrict the processing of your personal data. If you choose to restrict this processing, we may not be able to provide you with certain services. We may keep lists of people who have asked to restrict processing in order to make sure the restriction is respected in the future.
• The Right to Object to Processing – You have the right to object to certain types of processing of your personal data, in particular processing based on our legitimate interests. You also can object at any time to your personal data being used for direct marketing purposes (including profiling related to such direct marketing). Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
• The Right to Data Portability – You have the right to request that we transfer the personal data we have about you to another organization, or directly to you, in a format that is easily readable and transferrable where we have relied on your consent or on our contract with you to process your data.
• The right to refuse or withdraw consent – You have the right to refuse to provide and withdraw your consent to processing of your personal data at any time with effect for future processing.

We may make onward transfers of your personal data to third party service providers acting on our behalf as described in Section 4. Under the EU – US Data Privacy Framework and the UK Extension to the EU-U.S. DPF, as defined below, with respect to personal data that is subject to EU DPLs, we remain liable for such onward transfers to such third party service providers to the same extent as we are liable for our own processing activities under the EU DPLs and pursuant to the EU – US Data Privacy Framework and the UK Extension to the EU-U.S. DPF.

If you are not satisfied with our response to your complaint or believe our processing of your personal data does not comply with the applicable EU DPLs, you can make a complaint to your data protection authority.

Please note your rights in relation to your personal data are not absolute. We may, for example, deny you access to your personal data when required or authorized by law, or if granting access would have an unreasonable impact on another individual's privacy.

We will retain and use your personal data as long as necessary to comply with our legal and business obligations, provide the Services, resolve disputes, and enforce our agreements.

EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, (Collectively, as the "Data Privacy Framework (DPF)"):

We may transfer personal data from the European Economic Area and the United Kingdom to other countries, some of which have not yet been determined by the European Commission to have an adequate level of data protection. For example, their laws may not guarantee you the same rights, or there may not be a privacy supervisory authority there that is capable of addressing your complaints. When we engage in such transfers, we use a variety of legal mechanisms, including contracts such as the standard contractual clauses published by the European Commission under Commission Implementing Decision 2021/914, to help protect your rights and enable these protections to travel with your data. To learn more about the European Commission's decisions on the adequacy of the protection of personal data in the countries where Company processes personal data, see this article on the European Commission website: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

Company complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. Company has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) and the UK Extension to the EU-U.S. DPF with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and the UK Extension to the EU-U.S. DPF, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

If you have a question or complaint related to participation by us in the DPF Frameworks, we encourage you to contact us – please refer to Section 13 below: How to Contact Us. For any complaints related to the DPF Frameworks that we cannot resolve directly, we have chosen to cooperate with the relevant EU Data Protection Authority, or a panel established by the European data protection authorities, for resolving disputes with EU individuals and the UK Information Commissioner (for UK individuals). Please contact us if you'd like us to direct you to your data protection authority contacts. As further explained in the DPF Principles, binding arbitration is available to address residual complaints not resolved by other means. We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Your California Privacy Rights

The California Consumer Privacy Act, Cal. Civ. Code §§ 1798.100 et seq. ("CCPA") is a U.S. law enacted in the State of California, which went into force on January 1, 2020. It expands upon the privacy rights available to certain California consumers, and requires certain companies to comply with various data protection requirements. Please also visit the final CCPA Regulations and the California Privacy Rights Act ("CPRA"). The CPRA provisions went into effect on December 16, 2020, with the remaining provisions of the CPRA operative on January 1, 2023.

Pursuant to the California data protection laws, California residents have the right to be provided with the information and to exercise the rights as set forth in this Section 8 below.

We handle personal data on behalf of our third parties (such as third party service providers, customers, etc.) as described at the outset of this Privacy Policy under the subheading "Third Parties." The privacy policies of those third parties control their use of your personal data, and you should contact them with any questions about that personal data.

We use personal data provided on your behalf by your Third Party Services providers to provide the Services.

Categories of personal data: We and our service providers may collect personal data for our business or commercial purposes (as those terms are defined in applicable law) and a detailed list of the categories of personal data which we collect can be found in Section 1. Some of the personal data that we process may include sensitive information as defined by CCPA including account log-in information, geo-location and health or medical information.

Purposes of Collection: We collect your personal data for the business and commercial purposes described in Section 2 above.

How personal data is Collected: We collect the above categories of personal data from the sources described in Section 3 of this Privacy Policy.

Who we Share personal data with: We may disclose each of the above categories of personal data for the business and commercial purposes described in this Privacy Policy to the extent permitted by applicable law to the categories of third parties as described in Section 4 above.

You have the right to know whether your personal information is being sold. For example, under the CCPA, your personal information is "sold" when it is provided to a third party for monetary or other valuable consideration for a purpose. Please note a "sale" does not include when we disclose your personal information at your direction, to a third party service provider for a specific business purpose or when otherwise permitted under law.

Notice and Right to Request: You have the right to request access to your personal data that is within our possession.

Shine the Light Notice: California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of "personal data" (as defined by this law) to third parties for their direct marketing purposes. To make such a request, please send an email to our contact found at Section 13 below. Indicate in your email that you are a California resident making a "Shine the Light" inquiry.

Privacy Rights for Californians

If you are a resident of California, you can also make the following more specific requests with respect to your personal data:

• Access – You can request that we disclose to you the categories of personal data we collected about you, the categories of sources from which we collected the personal data, the categories of personal data we disclosed, our business or commercial purpose for collecting the personal data, the categories of third parties with whom we shared the personal data, and the specific pieces of personal data we collected about you over the past 12 months.
• Deletion – You can request that we delete your personal data that we maintain about you, subject to certain exceptions.
• Do Not Sell My Personal Information or Opt-Out Rights – You can request that we not sell your personal data by contacting us using the methods specified below. For purposes of this Privacy Policy, "sell" means the sale of your personal data to an outside party for monetary or other valuable consideration, subject to certain exceptions. Please note that if you would like to opt out of cookie-based tracking for advertising purposes (which might be considered a "sale"), you will need to separately visit www.aboutads.info/choices and https://optout.privacyrights.info to opt out of certain uses of cookies for advertising purposes. Your selections are specific to the device, website, and browser you are using. Your selections are also deleted (lost) whenever you clear your browser's cache.
• Right to Correct – You have the right to request correction or changes of your personal data if it is found to be inaccurate or out of date.
• Right to Limit Use of Sensitive personal data – You can request that we use your sensitive personal data as defined under California data protection laws (such as precise geo-location) for limited purposes, such as providing you with the services.

Notice of No Discrimination: We will not discriminate against you because you made any of these requests.

Process and Contact Information to Send Notices to Us:

• Where to Send Notice: If you would like to exercise any of these rights, please submit a request by email to us at our contact described in Section 13 below.
• How we Handle Requests: We may deny certain requests, or fulfil a request only in part, based on our legal rights and obligations. For example, we may retain personal data as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.
• Verification of Identity: We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps may vary depending on the sensitivity of the personal data and whether you have an account with us.
• Authorized Agent: California residents may designate an authorized agent to make a request on their behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent.

As used herein, "US data protection laws" means any applicable United States data privacy or data protection laws, including but not limited to (i) California Consumer Privacy Act (the "CCPA"), including the California Privacy Rights Act ("CPRA"); (ii) the Colorado Privacy Act ("CPA"); (iii) the Virginia Consumer Data Protection Act ("VCDPA"); (iv) the Connecticut Data Privacy Act ("CDPA"); (v) the Utah Consumer Privacy Act ("UCPA"); and any corresponding or similar United States state or federal laws or regulations relating to the use or protection of data including any amendment, update, modification to or re-enactment of such laws.

Please note that the rules implementing some of these laws have not yet been finalized and additional states are in the process of enacting similar laws. We are continuously working to better comply with these laws, and we will update our processes, disclosures, and this notice as these implementing rules are finalized.

In addition to the privacy rights of California residents as described in Section 8, US residents of other states have the right to be provided with the information and to exercise the rights as set forth in Section 8 above or as more specifically set forth in the applicable US data protection laws. Such rights include the following:

• Right to Access Your Data: You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your personal data. You can make this request by contacting us as described in Section 13.
• Right to Know: You have the right to know what personal data we process and how we process your personal data. For more information see Sections 1, 2, 3, and 4.
• Opt Out: You may have the right to opt out of the processing of personal data. For more information see Section 5. You can make this request by contacting us as described in Section 13.
• Right to Data Portability: You may have the right to a "portable" copy of your personal data that you have submitted to us. Generally, this means you have a right to request that we move, copy, or transmit your personal data stored on our servers or information technology environment to another service provider's servers or information technology environment. You can make this request by contacting us as described in Section 13.
• Right of correction: You have the right to request correction or changes of your personal data if it is found to be inaccurate or out of date. You can make this request by contacting us as described in Section 13.
• Right to Delete Your Data: You have the right to request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions. You can make this request by contacting us as described in Section 13.

Nevada: You have the right to opt-out of the sale of your personal data. See Section 5 for more information on exercising your right.

Process and Contact Information to Send Notices to Us:

See Section 13, "How to Contact Us" to contact/send notices to us. For unique state requirements, see below.

Colorado residents: You may submit a request to exercise your rights to know/access or delete your personal data through submitting a request via email to us as described in Section 13. Please note that the right to appeal a decision to deny processing using the subject line: "DSR Appeal.'' You may also contact the Colorado Attorney General if you have concerns about the result of the appeal.

We have implemented technical and organizational security measures designed to help protect against unauthorized access, unauthorized alteration, disclosure, or destruction of information. Unfortunately, no data transmission over the Internet can be guaranteed to be entirely secure, and we cannot and do not guarantee or warrant the security of any information that you transmit on or through our websites or Services.

We try to restrict access to information to only those employees, contractors, service providers and agents who need to know that information in order to help us provide the Services, and consistent with the level of sensitivity of such data.

Please note that the security of your personal data collected via the Services depends, in part, on your ensuring that any of your IDs and passwords are kept confidential and secure and that you adhere to the restrictions on password and ID-sharing set forth in our Terms of Service.

Our websites and Services contain business-related content and are specifically aimed at and designed for use by adults. We do not knowingly solicit or collect personal information (as defined by the Children's Online Privacy Protection Act, COPPA) from or about individuals under the age of 13 years. If we become aware that a visitor is under the age of 13 and has registered without prior verifiable parental consent, we will remove their personally identifiable registration information from our files. If you are the parent or guardian of a person under the age of 13 who has provided personally identifiable information to us without your approval, please inform us by contacting us, and we will remove such information from our database.

Our websites and Services may contain links to third party websites or services. These third parties are bound by their own privacy policies. We are not responsible for the privacy practices of others. When you leave our websites or Services to visit a third party website or service, please read their privacy statements. This Privacy Policy applies solely to personal data collected by us through the Services, and not to any personal data collected by the operators of third party websites or services. The inclusion of a link on the website/Service does not imply endorsement of the linked website or service by us or by our affiliates.

This Privacy Policy applies to the websites and Services of Company. Company maintains an active privacy and data protection compliance program. The Data Protection Officer is responsible for implementing and overseeing the administration of this Privacy Policy. If you have any questions about this Privacy Policy or how we process your personal data, please email us at [email protected], or contact us at:

4 Peddlers row Unit 44
Newark DE 19702
United States

Please note that once you contact us to exercise any of your rights, we may require additional information and documents, including personal data, in order to authenticate and validate your identity and to process your request. We will then retain such additional data for legal purposes (e.g., as proof of the identity of the person submitting the request).

This Privacy Policy may change from time to time. If we make any changes to this Privacy Policy, we will post any changes on this page. Where we make any material changes to this Privacy Policy, we will make a more prominent notice in compliance with applicable laws. Your continued use of our websites or Services following such posts or notices will signal that you have read and understand such changes. Please refer to the "Effective Date" above to see when this Privacy Policy was last updated.