Privacy Notice

When we use the term "personal information" in this Privacy Notice, we mean any data or information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or household or any other data or information that constitutes "personal data", "personal information," or "personally identifiable information."

We collect personal information in a variety of ways. For example, you may provide us your personal information when you register for an account, send us messages, subscribe to our mailing lists, social media accounts, newsletters or other forms of marketing communications, or use some other feature of our Service.

We may link or combine your activities and information collected from you on our websites and mobile apps with information we receive from third parties, as well as information we collect automatically through tracking technologies (defined below). This allows us to provide you with a personalized experience regardless of how you interact with us.

Personal Information Collected from You

We may collect the following categories personal information submitted to us by individuals through the Services:

• Contact Information, including first and last name, business email address, business postal address, employer, job title, your area of responsibility, company name, phone number, your country or region and communication preferences. We use this information to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences.
• Account Information, including first and last name, company name, employer, job title, business email address, user ID and password, profile information, account balances, payment and purchase history information, and any other information you provide to us. We use this information to administer your account, provide you with the relevant service and information, communicate with you regarding your account and your use of the Service, and for customer support purposes. Please note we utilize a third-party provider to process payments on our behalf and do not accept payment directly through our Services.
• Payment Information, if you sign up for one of our Services requiring payment (e.g., subscription services), we may collect the information provided in connection with such payment. Please note that we use third party payment processors to process credit card payments made to us. As such, we do not retain any personally identifiable financial information in connection with credit card payments, such as credit card numbers. Rather, all such information is provided directly by you to our third-party processor. The payment processor's use of your personal information is governed by their privacy notice.
• Inquiry and Communications Information, including information provided in custom messages sent through the forms, in chat messages, to one of our email addresses, or via phone. This also includes contact information provided on our Services. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.
• Newsletter, Marketing Emails, and Blog Information, including email address and applicable interests and communication preferences. We use this information to manage our communications with you and send you information about products and services we think may be of interest to you. If you wish to stop receiving email messages from us, simply click the "unsubscribe link" provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
• Information Collected Through the Use of the Service, including any files, documents, videos, images, data (including financial transaction data), or information you choose to upload or transmit through your communications with us or your use of the Site (collectively, "User Content"). User Content and any information contained in the User Content, including personal information you may have included, is stored and collected as part of the Service. We use the User Content to provide you with the Service.
• Feedback Information. We may also collect feedback and ratings you provide relating to our services or products. We use this information to communicate with you, to conduct market research, inform our marketing and advertising activities and improve and grow our business.
• Business Representative Contact Information. If you are a business representative, we collect your information in connection with the performance of the agreement or potential agreement with us. This information may include your first name, last name, company contact information (e.g., email, phone, address), job title, and any other information related to the performance of the agreement with us.
• Other Information that you provide to us online, by phone or in person, and use this information to respond to your request, provide you the requested services, and to inform our marketing and advertising campaigns.

Personal Information from Third Parties

We also obtain personal information from third parties; which we often combine with personal information we collect either automatically or directly from an individual.

We may receive the same categories of personal information as described above from the following third parties:

• CorgiAI Entities: We may receive personal information from other companies and brands owned or controlled by CorgiAI, and other companies owned by or under common ownership as CorgiAI. We use this information to provide and administer the Services.
• Your Employer / Company: If you interact with our Services through your employer or company, we may receive your information from your employer or company, including another representative of your employer or company. We use this information to operate, maintain, and provide to you the features and functionality of the Service.
• Service Providers: Our service providers that perform services solely on our behalf, such as survey and marketing providers and payment processors, collect personal information and often share some or all of this information with us. The information may include contact information, demographic information, payment information, information about your communications and related activities, and information about your orders. We may use this information to administer and facilitate our services, your orders, and our marketing activities.
• Information we receive from authentication services you connect to our Service: Some parts of our Service may allow you to login through a payment service provider ("PSP") authentication service such as Stripe. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, email address, address book and contacts, or other information. The data we receive is dependent on that third party's policies and your privacy settings on that third-party site. We use this information to operate, maintain, and provide to you the features and functionality of the Service. We may also send you service-related emails or messages (e.g., account verification, purchase confirmation, customer support, changes, or updates to features of the Site, technical and security notices).
• Other Sources: We may also collect Personal Information about individuals that we do not otherwise have from, for example, publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

Through the provision of our Services, we may also process deidentified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer or household. CorgiAI commits to maintain and use the information in deidentified form and will not attempt to reidentify the information, except in instances where necessary for determining whether the deidentification process used by CorgiAI satisfies the requirements under applicable law.

Personal Information Automatically Collected

We and our third-party providers may use (i) cookies or small data files that are stored on an individual's computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, "cookies") to automatically collect this personal information. We may also use this information to distinguish you from other users of our Services. This helps us monitor and analyze how you use and interact with our Services. It also helps us and our partners to determine products and services that may be of interest to you. For more information about these practices and your choices regarding cookies, please see our Cookie Notice.

Additional Uses of Personal Information

We may use personal information we collect to:

• Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested and to process transactions, including providing you with a white paper you have requested or an online product demonstration;
• Manage our organization and its day-to-day operations;
• Verify your identity and entitlement to products or Services, when you contact us or access our Services;
• Communicate with individuals, including via email, text message, social media and/or telephone calls;
• For marketing and advertising purposes, including to market to you or offer you through email, phone or text message information and updates on products or services we think that you may be interested in (where applicable, we may send you marketing messages if you have given us your consent to do so or where we have relied on the soft opt-in rule);
• Administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Services;
• Process payment for our Services;
• Identify and analyze how individuals use our Services;
• Conduct research and analytics on our customer and user base and our Services;
• Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
• Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
• Help maintain the safety, security and integrity of our property and Services, technology assets and business;
• To enforce our Terms of Use, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
• Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
• Comply with contractual and legal obligations and requirements;
• To fulfill any other purpose for which you provide personal information; and
• For any other lawful purpose, or other purpose that you consent to.

Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.

We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:

• CorgiAI Entities: We may share personal information with other companies owned or controlled by CorgiAI, and other companies owned by or under common ownership as CorgiAI, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
• Your Employer / Company: If you interact with our Services through your employer or company, we may disclose your information to your employer or company, including another representative of your employer or company.
• Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, employment application-related services, payment processing services, and administrative services.
• Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
• Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
  • in connection with the establishment, exercise, or defense of legal claims;
  • to comply with laws or to respond to lawful requests and legal process;
  • to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
  • to detect, suppress, or prevent fraud;
  • to protect the health and safety of us and others; or
  • as otherwise required by applicable law.
• With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual's consent or direction we may post their testimonial on our Sites or service-related publications.

You may control your information in the following ways:

• Access to Your Device Information. You may control the Services' access to your device information through your "Settings" app on your device. For instance, you can withdraw permission for the Services to access your network devices and geolocation and to integrate with your other applications.
• Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the "unsubscribe" link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
• SMS Text Messaging. You may opt-out of receiving promotional SMS text messages at any time. Please note that unsubscribing from promotional text messages will not prevent you from SMS texts from CorgiAI directly relating to your use of the Services, such as for account login (e.g. we may send you a security verification code). To unsubscribe from promotional SMS texts, you can reply STOP to any one of our promotional text messages. For more information, see our Terms of Use.
• Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at woof@corgilabs.ai. We may not be able to modify or delete your information in all circumstances.
• Cookies: If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies; however, doing so may negatively impact your experience using the services, as some features and services may not work properly. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

We will usually store the personal information we collect about you for no longer than necessary to fulfil the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal data for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.

To determine the appropriate duration of the retention of personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.

For example, if your personal information is subject to the EU GDPR or UK GDPR, the criteria used to determine the period for which personal data about you will be retained varies depending on the legal basis under which we process the personal data:

• Contract. Where we are processing personal data is based on contract, we generally will retain your personal data for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from our contractual relationship.
• Legitimate Interests. Where we are processing personal data based on our legitimate interests, we generally will retain such information for a reasonable period of time based on the particular interest, taking into account your fundamental interests and your rights and freedoms.
• Consent. Where we are processing personal data based on your consent, we generally will retain your personal data until you withdraw your consent, or otherwise for the period of time necessary to fulfil the underlying agreement with you or provide you with the applicable service for which we process that personal data.
• Legal Obligation. Where we are processing personal data based on a legal obligation, we generally will retain your personal data for the period of time necessary to fulfil the legal obligation.
• Legal Claim. We may need to apply a "legal hold" that retains information beyond our typical retention period where we face threat of legal claim or intent to establish a claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.

When an individual discontinues the use of our services, we will retain their personal data for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as, for any additional purpose based on the choices they have made, such as to receive marketing communications. In particular, we will retain personal data supplied when joining our services, including complaints, claims and any other personal data supplied during the duration of an individual's contract with us for the services until the statutory limitation periods have expired, when this is necessary for the establishment, exercise or defense of legal claims.

In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the personal data, as well as the potential risk of harm from unauthorized use or disclosure of your personal data.

Once retention of the personal data is no longer necessary for the purposes outlined above, we will either securely delete or deidentify the personal data or, if this is not possible (for example, because personal data has been stored in backup archives), then we will securely store the personal data and isolate it from further processing until deletion or deidentification is possible.

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child's parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.

Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to woof@corgilabs.ai.

We may choose or be required by law to provide different or additional information relating to the processing of personal information (as defined below) about residents of certain countries, regions or states. Please refer below for additional information that may be applicable to you:

10.1 United States

10.1.1 California

Shine the Light Disclosure. The California "Shine the Light" law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

10.1.2 European Economic Area, United Kingdom or Switzerland

If you are located in European Economic Area (Member States of the European Union together with Iceland, Norway, and Liechtenstein), United Kingdom, or Switzerland, please see the Additional European Economic Area, United Kingdom, and Switzerland Privacy Disclosures section for additional European-specific privacy disclosures.

These Privacy Disclosures set out information about how we use your personal data when you access our Service from the European Economic Area ("EEA"), United Kingdom ("UK"), and Switzerland. Please ensure that you have read and understood these Privacy Disclosures alongside our Terms of Service ("TOS") before you access or use the Service.

Personal Data: When we use the term "personal data" in these Privacy Disclosures, we mean information relating to an identified or identifiable natural person.

Controller: CorgiAI, Inc., a company duly incorporated and organised under the laws of the State of Delaware, having its registered address at 9450 South West Gemini Drive, PMB 48867, Beaverton, OR. 97008 is the "controller" responsible for the processing of personal data in connection with our Service. This means that we determine and are responsible for how your personal data is used.

Personal Data We Collect From You When You Use the Service, and How We Use It

We collect the categories of personal data set forth in the Personal Information Collected from You section of our Privacy Notice that you voluntarily submit directly to us when you use the Service.

The table at Annex 1 sets out further detail about the categories of personal data we collect about you and how we use that information when you use the Service, as well as the legal basis which we rely on to process the personal data and recipients of that personal data.

We will indicate to you, at the point that we collect personal data from you, if the provision of certain personal data is mandatory or optional. Some information, such as your name, address, payment transaction information, and information on your requested services, may be necessary for your use of certain features and functionalities of the Service. If you choose not to provide personal data marked as mandatory, we may not be able to provide those aspects of the Service to you, or to respond to your queries and other requests.

Information We Collect From Other Sources

We also collect personal data about you from other sources, as described in the Personal Information from Third Parties section of our Privacy Notice.

The table at Annex 1 sets out further detail about the categories of personal data we collect about you and how we use that information when you use the Service, as well as the legal basis which we rely on to process the personal data and recipients of that personal data.

Information We Collect About You Automatically

We also automatically collect personal data indirectly about how you access and use the Service, and information about the device you use to access the Service.

The table at Annex 2 sets out further information about the categories of personal data we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal data and recipients of that personal data.

We may link or combine the personal data we collect about you and the information we collect automatically.

We may anonymise and aggregate any of the personal data we collect (so that it is no longer linked to you and does not identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Service. We may also share such anonymised and aggregated information with others.

Recipients of Personal Information

We may share your personal data with the categories of third parties described in the Our Disclosure of Personal Information section of our Privacy Notice (as required in accordance with the uses set out in Annex 1 and Annex 2).

Legal Bases for Processing

We only process and retain your personal information as permitted under applicable law. For example, we will only process your information where we have established a lawful basis to do, as follows:

• When it is necessary for the performance of a contract to which you are party, or to take steps at your request prior to agreeing a contract: This applies to any processing where you sign a contract with us, for example when you become our customer, participate in our affiliate or premium partner program, or deliver services to us as a vendor or contractor. This may also include our Terms of Use.
• We have a legitimate interest which we believe outweighs your interests or fundamental rights and freedoms. This applies to the following processing activities:
  • When we communicate: To respond to your inquiries and, on some occasions, keep records in case of complaints or legal claims.
  • When you use our Services: When you access and use our Services, we process technical and analytics data to see if and how our Services can be improved, so that we can offer you a better user experiences in the future.
  • Global Suppression List: Avoid contacting you again if you have withdrawn your consent to marketing-related activities.
  • Marketing to existing customers (unless you have consented to such marketing): To find, customize and offer products and services we hope you find useful and relevant, i.e., provide you with excellent customer service.
  • Sharing personal information with other parties: To run our business efficiently and securely.
• Your consent: Wherever you clearly consent to the processing, for example when you sign up for our newsletters or events, request a demo, free trial or a download, or submit a survey. Here, your consent is implied, meaning that you consent by submitting a particular form. We also rely on your consent for using cookies and other technologies on our website and here you explicitly agree to these. Note that your default setting depends on your location (country), as the rules for using such technologies vary across jurisdictions.

We are subject to a legal obligation: For any processing where we need to comply with laws and regulations related to bookkeeping, accounting, taxation and employment, for example for keeping records.

Marketing and Advertising

From time to time we may contact you with information about our services, including sending you marketing messages and asking for your feedback on our services. Most marketing messages we send will be by email. For some marketing messages, we may use personal data we collect about you to help us determine the most relevant marketing information to share with you.

We will only send you such messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails.

Cookies and Similar Technologies Used on Our Services

Our Services use cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together "cookies") to distinguish you from other users of our Services. This helps us to provide you with a good experience when you browse our Services and also allows us to monitor and analyse how you use and interact with our Services so that we can continue to improve our Services. It also helps us and our partners to determine products and services that may be of interest to you. Please see our Cookie Notice for more information about these practices and your choices regarding cookies.

Tracking Technologies Used in Our Emails

Our emails may contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you.

Most popular email clients will allow you to block these pixels by disabling certain external images in emails. You can do this through the settings on your email client – these generally give you the option of choosing whether emails will display "remote images", "remote content" or "images" by default.

Some browsers also give you the option of downloading and installing extensions that block pixels and other tracking technologies.

Processing Method

Personal data will be processed with IT-based tools and/or processed manually for the length of time needed to achieve the purpose for which it was collected. In particular, personal data collected for the purposes outline in the Our Collection and Use of Personal Information section of the Privacy Notice will be also processed with the usage of automated mechanisms based on procedures and logics that are strictly related to the purposes specified.

Storing and Transferring Your Personal Information

Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

International Transfers of Your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, including in the United States. If you are accessing our Services from the EEA, UK or Switzerland, your personal information will be processed outside of the EEA, the UK and Switzerland.

In the event of such a transfer, we ensure that: (i) the personal information is transferred to countries recognised as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard contractual clauses adopted by the European Commission. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this Privacy Notice.

Your Rights in Respect of Your Personal Data

In accordance with applicable privacy law, you have the following rights in respect of your personal data that we hold:

1. Right of access. You have the right to obtain:
   1. confirmation of whether, and where, we are processing your personal data;
   2. information about the categories of personal data we are processing, the purposes for which we process your personal data and information as to how we determine applicable retention periods;
   3. information about the categories of recipients with whom we may share your personal data; and
   4. a copy of the personal data we hold about you.
2. Right of portability. You have the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
3. Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal data we hold about you without undue delay.
4. Right to erasure. You have the right, in some circumstances, to require us to erase your personal data without undue delay if the continued processing of that personal data is not justified.
5. Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.
6. Right to withdraw consent. There are certain circumstances where we require your consent to process your personal data. In these instances, and if you have provided consent, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data before your withdrawal.

You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

If you wish to exercise one of these rights, please visit our Privacy Rights Requests Center.

Due to the confidential nature of data processing we may ask you to confirm your identity when exercising the above rights.

You also have the right to lodge a complaint to your local data protection authority. If you are based in the European Union, information about how to contact your local data protection authority is available here. If you are based in the UK or Switzerland, your local data protection authorities are the UK Information Commissioner's Office (https://ico.org.uk/global/contact-us/) and the Swiss Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/address.html).

Annex 1 – Personal Information You Provide to Us

Annex 2 – Personal Information Collected Automatically

Unless otherwise expressly stated, terms in this notice have the same meaning as defined in the Privacy Notice.

1. Scope of Notice

This Cookie Notice supplements the information contained in the Privacy Notice and explains how we and our business partners and service providers use cookies and related technologies in the course of managing and providing our online services and our electronic communication to you. It explains what these technologies are and why we use them, as well as your rights to control our use of them.

In some cases, we may use cookies and related technologies described in this Cookie Notice to collect personal information, or to collect information that becomes personal information if we combine it with other information. For more details about how we process your personal information, please review the Privacy Notice.

2. What Are Cookies and Related Technologies

As is common practice among websites, our Services use cookies, which are tiny files downloaded to your device that allow us and our third-party partners to collect certain information about your interactions with our email communications, websites and other online services, and that improve your experience. We and our third-party partners and providers may also use other, related technologies to collect this information, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, "cookies").

We use the following types of cookies:

1. Strictly necessary cookies. These cookies enable core functionality such as security, network management and accessibility. You may disable these by changing your browser settings, but this may affect how the Services function. The legal basis for our use of strictly necessary cookies is our legitimate interests, namely being able to provide and maintain our Services. Please see the website Cookies Chart for more information.
2. Functional cookies. These enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in. The legal basis for our use of functionality cookies is our legitimate interests, namely being able to provide and maintain our Services. Please see the website Cookies Chart for more information.
3. Analytical/performance cookies. These cookies allow us to recognize and count the number of visitors to our Services, and to see how visitors move around our Services when they are using them. This helps us to improve the way our Services work, for example, by ensuring that users are finding what they are looking for easily. If you are accessing our Services with a European IP address, you have been asked to consent to the use of these cookies. You are free to deny your consent. Please see the website Cookies Chart for more information.
4. Targeting cookies. These cookies record your visit to our Services, the pages you have visited and the links you have followed. They are used to track visitors across our Services. If you are accessing our Services with a European IP address, you have been asked to consent to the use of these cookies. You are free to deny your consent. Please see the website Cookies Chart for more information.

3. What We Collect When Using Cookies

We and our third-party partners and providers may use cookies to automatically collect certain types of usage information when you visit or interact with our email communications and Services, such as:

• Information the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, for example, a persistent device identifier or an AdID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
• Information about the way you access and use our services, for example, the site from which you came and the site to which you are going when you leave our services, how frequently you access the Services, whether you open emails or click the links contained in emails, whether you access the services from multiple devices, and other browsing behavior and actions you take on the Sites.
• Information about how you use the Service, such as the pages you visit, the links you click, the ads you view and click on, videos you watch, and other similar actions. We may also use third-party tools to collect information you provide to us or information about how you use the Services and may record your mouse movements, scrolling, clicks and keystroke activity on the Services and other browsing, search or purchasing behavior. These tools may also record information you enter when you interact with our Services or engage in chat features through our Service.
• Information about your location, such as general geographic location that we or our third-party providers may derive from your IP address.
• Analytics information. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the services and to understand more about the demographics of our users. You can learn more about Google's practices at http://www.google.com/policies/privacy/partners and view its opt-out options at https://tools.google.com/dlpage/gaoptout.

All of the information collected automatically through these tools allows us to improve your customer experience.

4. How We Use Information Collected Via Cookies

We use cookies for a variety of reasons outlined below:

• If you create an account with us, we will use cookies for the management of the signup process and general administration. These cookies will usually be deleted when you log out; however, in some cases, they may remain in order to remember your site preferences when logged out.
• We use cookies when you are logged in so that we can remember you. These cookies are typically removed or cleared when you log out to ensure you can only access restricted features and areas when logged in.
• The Services offer newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
• The Services may offer payment capabilities and some cookies are essential to ensure that your order is remembered between pages so that we can process it properly.
• When you submit data through a form, such as those found on the contact pages or comment forms, cookies may be set to remember your user details for future correspondence.
• In order to provide you with a great experience on the Services, we provide the functionality to set your preferences for how the Services run when you use it. In order to remember your preferences, we need to set cookies so that this information can be called whenever you interact with a website page.
• We use cookies to provide and monitor the effectiveness of our Services, monitor online usage and activities of our Services, and facilitate the purposes identified in the How We Use Your Personal Information section of our Privacy Notice.
• We may also use the information we collect through cookies to understand your browsing activities, including across unaffiliated third-party sites, so that we can deliver information about products and services that may be of interest to you.
• Tracking technology used in emails helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and help us understand if you have opened and how you interacted with our email.

Please note that we link some of the personal information we collect through cookies with the other personal information that we collect about you and for the purposes described in our Privacy Notice.

5. Third-Party Data Collection and Online Advertising

We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the Sites, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.

We may engage in the following:

• Social Media Widgets and Advertising. Our Services may include social media features, such as the Facebook "Like" button, Pinterest, Instagram, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.
• Social Media Platforms. We may display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, LinkedIn, and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.
• Third Party Partners. We work with a variety of third-party partners to provide advertising services. For example, we use Google Analytics to recognize you and link the devices you use when you visit our Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's website, "How Google uses data when you use our partners' sites or apps" located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics' currently available opt-outs, including the Google Analytics Browser Ad-On here: https://tools.google.com/dlpage/gaoptout/.

We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI's online resources at http://www.networkadvertising.org/choices.

6. Your Choices About Cookies

If you would prefer not to accept cookies, most browsers will allow you to change the setting of cookies by adjusting the settings on your browser to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Be aware that disabling cookies may negatively affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionalities and features of the Services.

Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

If you are located in the EEA, UK, or Switzerland, you may take advantage of Your Online Choices. This service allows you to select tracking preferences for most of the advertising tools. As such, it is recommended that you make use of this resource in addition to the information provided in this document.

Online Ads. To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance's (DAA) resources and/or the Network Advertising Initiative's (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting "limit ad tracking" (iOS) or "opt-out of interest-based ads" (Android). You may also be able to opt-out of some, but not all, interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties' opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA's Principles.

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