1. INFORMATION COLLECTION TECHNOLOGIES

The technologies we use for automatic information collection may include:

• Cookies (or mobile cookies): We may use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. The purpose of a cookie is to tell the web server that you have returned to a specific page. You can accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Services or the Services overall. 

• Retargeting/Advertising Cookies:Retargeting/Advertising cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. 

• Web Beacons: The Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related Services

• Social Ad Services: We may also use re-marketing through social media tracking cookies and pixel-based retargeting services. This means that if you provided your consent to any social media Services (the “Social Ad Services”) to be provided with personalized commercial offers, you may be served with ads (including advertisements of third parties) based on your access to the Services, outside of the Services and across the internet. In such event, the Social Ad Services, will place cookies on your web browser and use such cookies to serve you ads based on past visits to our Services. 

Please visit the Social Ad Platforms Privacy policy to find out how they use such information:

• Google: https://policies.google.com/technologies/ads
• TikTok: https://www.tiktok.com/legal/page/us/privacy-policy/en
• Facebook: https://www.facebook.com/about/privacy/
• Instagram: https://help.instagram.com/478880589321969/
• X (Formerly Twitter): https://business.twitter.com/en/help/ads-policies/other-policy-requirements/policies-for-conversion-tracking-and-tailored-audiences.html

• Mobile Device Identifiers. Mobile device identifiers help Pelagion learn more about our users’ demographics and internet behaviors. Mobile device identifiers are data stored on mobile devices that may track mobile device and data and activities occurring on and through it, as well as the applications installed on it. Mobile device identifiers enable collection of Personal Information (such as media access control, address, and location, and tracking data, including without limitation IP address, domain server, type of device(s) used to access the Services, web browser(s) used to access the Services, referring webpage or other source through which you accessed the Services, other statistics and information associated with the interaction between your browser or device and the Services).

• Cross Device Matching. To determine if users have interacted with content across multiple devices and to match such devices, we may work with partners who analyze device activity data and/or rely on your information (including demographic, geographic and interest-based data). To supplement this analysis, we may also provide de-identified data to these partners. Based on this data, we may then display targeted advertisements across devices that we believe are associated or use this data to further analyze usage of Services across devices.

2. CHANGING YOUR DATA COLLECTION SETTINGS

We strive to provide you with choices regarding the Personal Information you provide to us. You may need to adjust the settings on your computer and/or device to restrict the collection of information by the Services, but this may prevent you from accessing all the features of the Services.

• Tracking Technologies: You may be able to set your browser or device to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Services may then be inaccessible or not function properly.

• Location Information: You can choose whether to allow the Services to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts or all of the Services may be inaccessible or not function properly.

• Social Ad Platforms: If you wish to opt-out of re-targeting and tracking functionality of the Social Ad Platforms, you may do so through each platform directly. PLEASE NOTE that these tracking and targeting by Social Ad Platforms, is provided pursuant to your engagement with the Social Ad Platforms and the actual nature and scope of Personal Information collection and processing performed by such Social Ad Platforms may not be fully known to us. If you would like to learn more or make further inquiries with respect to such nature or scope, please refer to each Social Ad Platforms directly.

You can decide whether to accept cookies through your internet browser’s settings. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on your browser software) allow you to decide on acceptance of each new cookie in a variety of ways. You may also be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. You can also delete all cookies that are already on your computer. Although you are not required to accept cookies, if you block, reject, or delete them, you may have to manually adjust some preferences every time you visit a site and some of the Services and functionalities may not work.

To explore what cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about cookies, including information about how to manage and delete cookies, visit: http://www.allaboutcookies.org/.

3. THIRD-PARTY AUTOMATIC INFORMATION COLLECTION

When you use the Services or its contents, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

• Advertisers, ad networks and ad servers;
• Analytics companies;
• Your mobile device manufacturer;
• Your mobile service provider; and/or
• Your Internet provider.

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your Personal Information or they may collect information about your online activities over time and across different platforms, mobile applications, and other online sites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ 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.

4. HOW WE USE YOUR INFORMATION

We use information collected as described in this Privacy Policy for the following:

• Operation

• Operate, maintain and improve the Services;
• Provide you with the Services and its contents, and any other information, products or services that you request from us;
• Send you reminders, technical notices, updates, security alerts, support and administrative messages and marketing messages;
• Answer your questions and respond to your requests;
• Ensure that content from the Services is presented in the most effective manner for you and for your computer or device for accessing the Services;
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Terms and Conditions;
• Notify you when there are changes to any products or services we offer or provide though the Services; and
• To maintain the security of Services.

• Usage and Analytics

• Estimate our audience size and usage patterns;
• Perform analytics and conduct customer research;
• Analyze advertising effectiveness; and
• Communicate and provide additional information that may be of interest to you about us and any of our partners.

• Location: We will use location data for the following reasons:

• To provide the Services targeted to the city in which you are located;
• To display information that is relevant to your particular location.
• To maintain the security of Services.

5. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

The Personal Information you provide to us whether voluntarily or automatically, may be used and disclosed without limitations, in the following instances:

• To other Users – Your Personal Information may be shared voluntarily if you message or otherwise communicate with other Users;

• With vendors who provide services for us (who are required to protect thePersonal Information)– We may share Personal Information for business purposes with service providers that provide us with services for the purpose of operating the Services, opening, and operating your account, as well as providing ancillary services and solutions. These include, among others, hosting services, billing and payment processors and vendors, community management services, data and cybersecurity services, web analytics and performance tools, translation tools, IT and SaaS services, session recording, communication systems, mailing systems, data optimization and marketing services, data enrichment services, legal and financial advisors or technical consultants. All credit, debit, or prepaid card information collected by Pelagion, or any applicable payment processor will be stored and processed in compliance with applicable payment card industry standards. Consistent with applicable legal requirements, we take appropriate technical and organizational measures to require third parties to adequately safeguard your personal information and only process it in accordance with our instructions;

• To report or collect on debts owed to us;

• To comply with legal requirements – We may be required to disclose Personal Information to a prospective buyer or buyer of Pelagion or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all our assets; as part of bankruptcy, liquidation or similar proceeding, for the enforcement of law, regulations, court orders, subpoena, a warrant during the course of a legal proceedings or otherwise; in order for us to protect and safeguard our copyright, trademarks, legal rights, intellectual property rights or safety; or in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States.

6. HOW WE DISCLOSE YOUR NON-PERSONAL INFORMATION

We may also disclose Non-Personal Information:

• For the same reasons, we might share Personal Information;
• With our advertisers for their own analysis and research;
• To facilitate targeted content and ads; or
• With Third-Party Ad Servers to place our ads on the Services and on third-party platforms or mobile applications.

7. HOW TO ACCESS, UPDATE, WITHDRAW CONSENT OR DELETE YOUR INFORMATION

If law applicable to you grants you such rights, you may ask to access, correct, or delete your Personal Information that is stored in our systems or that we otherwise control. You may also ask for our confirmation as to whether we process your Personal Information or ask to withdraw any consent you have previously provided to Pelagion in connection with our use and processing of your Personal Information. Subject to the limitations in law, you may request that we update, correct, or delete inaccurate or outdated information. You may also request that we suspend the use of any Personal Information the accuracy of which you contest while we verify the status of that data.

If you wish to exercise any of these rights or withdraw your consent, please contact us at [email protected]. When handling these requests, we may ask for additional information to confirm your identity and your request. Please note, upon request to delete your Personal Information, we may retain such data in whole or in part to comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates, or as we are otherwise permitted under such law applicable to you. While we strive to honor all reasonable requests, please be aware that we backup the data to prevent accidental or malicious destruction of your information. Information on backup servers may take some time to be completely deleted from the system. If you request that we remove you from our system and delete all your information, please note that you may still receive materials while your request is being processed.

If you request that your information be deleted, we may keep your information for a period of time. However, if you request to delete your information, your Personal Information will not be used by us or our third-party providers for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.

8. SECURITY AND DATA RETENTION

The security of your Personal Information is important to us. We seek to protect your Personal Information from unauthorized access, use and disclosure using appropriate physical, technical, organizational, and administrative security measures based on the type of Personal Information and how we are processing that data. We endeavor to follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and in storage. For example, the Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Information. We maintain what we consider industry standard backup and archival systems. Although we work to protect the security of the data that we hold in our records, for example, by making good faith efforts to store Personal Information in a secure operating environment that is not open to the public, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot and do not guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.

If at any time we believe that the security of your Personal Information may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances. If we have your email address, we may notify you by email to the most recent email address you have provided us. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your email account. You consent to our use of email as a means of such notification. If you prefer for us to use the U.S. Postal Service to notify you in this situation, please email us at [email protected]. Please include your address when you submit your request. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this email address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your Personal Information.

We may retain Personal Information about you consistent with all internal policies and procedures. We may retain Personal Information to comply with our legal obligations, resolve disputes or collect fees owed, or as is otherwise permitted or required by our data retention policies and procedures.

9. COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS

We represent and warrant that we will comply with all applicable laws, rules, regulations, directives, and guidelines regarding the collection, use and disclosure of data collected from or about Users or specific devices which apply to the services utilized hereunder. The term “Rules” shall include, without limitation, (i) United States Federal Trade Commission Laws regarding the collection, use and disclosure of data from or about users and/or specific devices; (ii) the Children’s Privacy Protection Act of 1998 (“COPPA”); (iii) any state data privacy laws, and (iv) the Rules of any other jurisdiction, including the United Kingdom General Data Protection Regulation (“UK GDPR”) and the European Union General Data Protection Regulation (“EU GDPR”), rules, regulations and/or directives promulgated by a pertinent Data Protection Act, and all amendments and updates to them or  regulations as replaced or superseded from time to time. Under GDPR, you have the following rights to your personal data:

• Right to information
• Right to correction or deletion,
• Right to restriction of processing,
• Right to refusal of processing,
• Right to data portability.

You also have the right to lodge a complaint about our processing of your personal data with a data protection regulatory body.

• CALIFORNIA ‘DO NOT SELL MY INFO’ NOTICE (PRIVACY NOTICE FOR CALIFORNIA CONSUMERS)

We may work with Google, Facebook and other companies that use information collected from cookies and similar technologies to try to make the ads you see online more relevant to your interests.  This is called interest-based advertising. Our use of these services may constitute a “sale” of Personal Information as defined under the California Consumer Protection Act (CCPA).  You can opt-out of the use of your information for interest-based advertising by:

• Browser settings.  Blocking third party cookies in your browser settings.
• Privacy browsers/plug-ins. Using privacy browsers or ad-blocking browser plug-ins that let you block advertising trackers.
• Platform settings. Using the opt-out settings offered by some of the advertising companies that we work with.
• Ad industry tools.  Opting out of interest-based ads from companies participating in the following industry opt-out programs:
  • Network Advertising Initiative: https://optout.networkadvertising.org/?c=1
  • Digital Advertising Alliance: aboutads.info, which will allow you to opt-out of interest-based ads served by on websites by participating members.
  • AppChoices:https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members.

Mobile settings.  Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes. You will need to apply these opt-out settings on each device from which you wish to opt-out.  Not all companies that serve interest-based ads participate in these opt-out programs, so even after opting-out, you may still receive some cookies and interest-based ads from other companies.  If you opt-out of interest-based advertisements, you will still see advertisements online, but they may be less relevant to you.

If we share information with the data providers described above, it may also constitute “sales” as defined under the CCPA.   Any information shared with third parties is controlled by each data provider and you may need to opt-out from each data provider individually.

The above describes our practices currently and during the 12-month period preceding the date on which this Privacy Policy was last updated.

Your CCPA rights. As a California resident, you have the following rights as of January 1, 2020:

• You can request the following information about how we have collected and used your Personal Information during the past 12 months:
  • The categories of Personal Information that we have collected.
  • The categories of sources from which we collected Personal Information.
  • The business or commercial purpose for collecting and/or selling Personal Information.
  • The categories of third parties with whom we share Personal Information.
  • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information disclosed to each category of third-party recipient.
  • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third-party recipient. 

• Access.  You can request a copy of the Personal Information that we have collected about you during the past 12 months.

• Deletion.  You can ask us to delete the Personal Information that we have collected from you by emailing us at [email protected].

• Opt-out.You can opt-out of any “sale” of your Personal Information as defined in the CCPA.

• Non-discrimination.  You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA. 

You may submit a request to exercise your right to information, access, or deletion by emailing to [email protected] with “Privacy” in the subject line.  We reserve the right to confirm your California residency to process these requests and will need to confirm your identity.  Government-issued identification may be required.  We will only accept deletion requests through email designated in this subsection. You may designate an authorized agent to make a request on your behalf by providing a valid power of attorney or other proof of authority acceptable to us in our reasonable discretion, the requester’s valid government-issued identification, and the authorized agent’s valid government-issued identification.  You can submit a request to opt-out of sales of your Personal Information as described above.  We cannot process your request if you do not provide us with sufficient information to allow us to understand and respond to it.  In certain cases, we may decline your request as permitted by law.

• PRIVACY NOTICE FOR COLORADO RESIDENTS

As a Colorado resident you have the following rights regarding your personal data under the Colorado Privacy Act (the “CPA”) effective as of July 1, 2023:

The CPA grants consumers, or the parents or guardians of children under 13, the right to:

• Opt out of processing Personal Data or authorize another person to opt-out on their behalf, for (a) targeted advertising; (b) personal data sales; or (c) profiling, which has legal or other significant effects on the consumer, as defined by the CPA.
• Know whether a controller processes their personal data;
• Access, correct, and delete their personal data; and
• Obtain a copy of their personal data in a commonly used and machine-readable format, known in other jurisdictions as the right to data portability, up to two (2) times per year.

The CPA defines personal data as any “information that is linked or reasonably linkable to an identified or identifiable individual.” Based on this definition, personal data may include information such as individual’s name, email address, phone number, credit card details, IP address, identification number.

Additionally, “sensitive data”, refers to a distinct category of personal data that is considered confidential. We would need your explicit consent to collect any of the following:

• Any data revealing racial or ethnic origin;
• Sexual orientation;
• Religious beliefs;
• Physical or mental health diagnosis;
• Citizenship standing;
• Biometric or genetic data; or
• Personal data obtained from a known child.

For Colorado residents who wish to exercise their rights under this section, you may contact us at [email protected].

• PRIVACY NOTICE FOR CONNECTICUT RESIDENTS

As a Connecticut resident you have the following rights regarding your personal data under the Connecticut Data Privacy Act (“CTDPA”) effective as of July 1, 2023. The CTDPA provides Connecticut residents with the following rights regarding the personal data:

• Right to confirm and access. The CTDPA grants consumers the right to access data from data controllers.
• Right to correct. CTDPA provides consumers with the right to correct any inaccuracies in their data.
• Right to data portability. Connecticut consumers can ask for a copy of the user data their company has saved and move it to another company.
• Right to delete. The CTDPA gives consumers the right to delete personal data that they have provided to companies.
• Right to opt-out. The act provides consumers with the right to opt-out of having their data processed for profiling, sale of data, and targeted advertising.

Connecticut residents may exercise any of their rights under this section by sending an email to [email protected]. We will promptly respond to a consumer’s request within 45 days after receiving the request. If reasonably necessary to comply with your request, we may extend this deadline by an additional 45 days upon notice to you stating the reason we need such extension. Note that we may charge a reasonable fee if you make more than one request within a 12-month period or if the request is “manifestly unfounded, excessive, or repetitive.”

• PRIVACY NOTICE FOR NEVADA RESIDENTS

This section outlines certain rights for Nevada residents. We comply with the requirements as defined under Nevada’s Privacy Law, which provides Nevada residents with choices regarding how we share and collect personal information from you in the course of providing requested services. If you are a Nevada resident, you have the right to submit a verified request to us, directing us not to make any sale of certain Personal Information that we have or will collect about you. The Services does not currently engage in the “sale” (as defined by Nevada law) of personal information.

“Nevada Personal Information” includes personally identifiable information about a Nevada consumer collected online, such as an identifier that allows the specific individual to be contacted. Nevada Personal Information also includes any other information about a Nevada consumer collected online that can be combined with an identifier to identify the specific individual. Unless otherwise stated, the Services does not sell any “Covered Information”, as defined under Chapter 603A of the Nevada Revised Statutes.

For Nevada residents who wish to exercise their rights under this section and/or for information regarding the categories of Nevada Personal Information that we collect, please contact [email protected]. Please indicate that you are a Nevada resident making a “Nevada Opt-Out” request, and include your name, telephone number and the email address used to access our site. We will respond to requests within 60 days and no more than 90 days after a request is submitted.

• PRIVACY NOTICE FOR UTAH RESIDENTS

This section applies solely to Utah residents. It applies to Personal Data we collect as a business; it does not apply to Personal Data we collect or otherwise process as a service provider.

If you are a Utah consumer, as that term is defined under the Utah Consumer Privacy Act (“UCPA”), you may have certain rights. Utah law may permit you to request that we:

• Confirm whether or not we are processing your Personal Data and provide you with access such Personal Data;
• Correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of the Personal Data;
• Delete your Personal Data;
• Provide you a copy of Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business, where our processing is carried out by automated means; and
• Opt out of the processing of the Personal Data for purposes of targeted advertising, the sale of Personal Data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services.

You may also exercise your Utah consumer rights by emailing us at [email protected]. You will be required to verify your identity before we fulfill your request. To do so, you will need to demonstrate that you have access to the email address used to create your account  or provide us with certain account information, such as the full name and email address you used to create your account. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization for the agent to act on your behalf, however, you will still need to verify your identity directly with us. We may use your Personal Data to send you targeted advertising. (as that term is defined in the UCPA).  To opt out of targeted advertising, email us at [email protected].

• PRIVACY NOTICE FOR VIRGINIA RESIDENTS

As a Virginia resident you have the following rights regarding your personal data under the Virginia Consumer Data Protection Act (the “VCDPA”) effective as of January 1, 2023:

• Right to Confirm if a controller is processing you Personal Data and to access Personal Data;
• Right to correct inaccurate Personal Data;
• Right to delete;
• Right to obtain a copy of your Personal Data in portable Format; and
• Right to Opt-Out of the processing of Personal Data for purposes of targeted advertising, sale, or profiling with legal or other significant effects.

We may collect, use, and disclose your personal data for business purposes.  A summary of the categories of personal data collected and the purposes for which it is used can be found below. To exercise any of your rights under VCDPA, please submit an email to [email protected].

The VCDPA applies to individuals who are Virginia residents, acting in an “individual or household” context, but does not apply to individuals acting in a commercial context (i.e., as a representative of a business) or employment context.

Depending on the specific service or product you use, the categories of Personal Data collected may include:

• Personal identifiers such as your name, address, email, and payment information
• Commercial information such as the records of the products and services you purchase and use, and
• Internet or other electronic activity such as your interaction and usage with our websites, apps and advertisements and information about and on your device. 

Additionally, “sensitive data”, a category of personal data, would include the following:

• Personal data revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, citizenship, or immigrations status;
• The processing of genetic or biometric data for the purposes of uniquely identifying a natural person;
• The personal data collected from a known child; or
• Precise geolocation data.

Depending on the specific service or product you use, we may use your personal data for various business purposes, including (a) to provide, manage, support and improve our products and services, (b) to maintain and service your account, (c) to verify you, your account activity and your information, (d) to detect, investigate and report fraud, abuse or illegal use of our products and services or customer accounts, (e) to provide customer service, (f) to provide advertising and marketing to our customers, and (g) to measure our marketing campaigns and to audit consumer interactions.

10. CHILDREN’S PRIVACY

The Services are not directed to or intended for use by children under 13 years of age. If you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Information. By accessing, using and/or submitting information to or through the Services, you represent that you are not under the age of 13.  If we learn that we have received any Personal Information directly from a child under age 13 without first receiving his or her parent’s verified consent, we will use that Personal Information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services. We will then subsequently delete that child’s Personal Information. If you believe that a child under 13 may have provided us with Personal Information, please contact us at [email protected].

11. UPDATES TO THIS POLICY

We reserve the right to change, modify, update, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to this page. When we do update it, for your convenience, we will make the updated policy available on this page. If you opt out of receiving communications, you may not receive certain notifications, however, they will still govern your use of the Services, and you are responsible for proactively checking for any changes. We encourage you to check this Privacy Policy frequently to stay up to date on any changes. You can determine if changes have been made by checking the effective date on the Privacy Policy. Continued use of the Services after the effective date of any change in this Privacy Policy will constitute acceptance of such changes and it will signify that you agree to abide by and be bound by the modified Privacy Policy.

12. CONTACT US

If you have questions, comments, or concerns regarding this Privacy Policy, please contact us and we will respond to your request within a reasonable timeframe. Please include the following information in your request (a) Your name; (b) Your contact information, including phone number, mailing address, and email address; and (c) the precise nature of your request, inquiry, or complaint.

By email: [email protected]