Aggregage Privacy Policy

Effective Date: November 19, 2020

1. The Scope of this Policy

This Privacy Policy covers any Personal Information we obtain when you visit us, use our services, or access the features on the websites that Aggregage, Inc. (“Aggregage” or “we” or “us”) owns or controls (today or in the future), including https://www.aggregage.com/ (collectively, the “Sites”). You can access the Sites in many ways, including from a computer or mobile phone, and this Privacy Policy will apply regardless of the means of access. This Privacy Policy also governs the use of Personal Information we obtain from you from any third party site or application where we post content or invite your feedback or participation, including, but not limited to, Twitter, Facebook, and LinkedIn. Aggregage cannot control the privacy policies or practices of such sites or of companies Aggregage does not own or control, and cannot control the actions of people Aggregage does not employ or manage. You should always check the privacy policies of these sites and your privacy settings.

2. The Information We Collect

Personal Information

When you use our Sites, you may choose to provide certain information directly to us to request more information or services, including the following Personal Information:

• first name, last name;
• password;
• email address;
• work address;
• phone number;
• job title
• job level
• job role
• department
• company name
• company size
• company industry,
• professional interests,
• and other related business/professional information.

You are not required to provide all Personal Information identified in this Privacy Policy to use our Sites
or to interact with us, but certain functionality will not be available if you do not provide certain
Personal Information. For example, if you do not provide certain Personal Information, we may not be
able to respond to your requests, perform a transaction with you, or provide you with marketing that
we believe you would find valuable.

Usage Information

We may also use cookies and other technologies to automatically gather information about how you use the Sites, including:

• new or returning visitor;
• time of visit;
• duration of visit;
• pages viewed;
• where you found the Sites (search, direct, social media, etc.);
• country you’re visiting from; and
• technology you’re using (browser, screen resolution, etc.).

We only use, share, and store Personal Information consistent with this Privacy Policy.

3. How We Collect Your Personal Information

We collect Personal Information when you:

• visit our Sites;
• request information;
• fill out a form; and
• participate in surveys or promotions.

We also collect information in several ways by your use of the Sites. When you access the Sites, our servers log your IP address, the URL of your request and other information that is provided in the HTTP header. When you conduct searches on the Sites, we may log the search terms that you use. Also, our third-party service providers may ask you voluntarily to provide Personal Information on their websites and may share such Personal Information with us, as governed by their respective privacy policies. Our use of information received from a service provider will be dictated by the service provider’s privacy policies and not this Privacy Policy. Aggregage collects this information in order to provide information about our products and services that will meet the expectations of our users.

In accordance with the sub-section below, “Social Media Sites” we may also collect Personal Information
from third party social media networks.

Cookies

A “cookie” is a small data file stored on your web browser or on your mobile device that allows us to recognize your computer or mobile device when you visit the Sites by associating identification numbers with other user information you have provided us. Some cookies will remain on the hard drive of your computer or mobile device for the duration of your browser or user session, while others will remain until deleted by you. You may also be able to configure your computer or mobile device to limit the collection of these “cookies,” but that limitation may also limit our ability to provide all the services or functionality of the Sites. Some third party service providers may use “flash cookies,” which are saved on your computer, but cannot be rejected, disabled, turned off, opted out of, or deleted in the same way as regular cookies. To learn how to manage your flash cookie settings, visit the Flash player settings page on Adobe’s website.

Google Analytics

This Sites use Google Analytics (and in the future may use other similar sites or services), a web analytics service provided by Google, Inc. (“Google”), to better assist Aggregage in understanding how the Sites are used. Google Analytics will place cookies on your computer that will generate information that we select about your use of the Sites, including your computer’s IP address. That information will be transmitted to and stored by Google. The information will be used for the purpose of evaluating consumer use of the Sites, compiling reports on Sites’ activity for Aggregage’s use, and providing other services relating to Site activity and usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note that by doing so, you may not be able to use the full functionality of the Sites. The use of cookies by Google Analytics is covered by Google’s privacy policy.
You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

4. How We Use Your Personal Information

Aggregage collects and uses your Personal Information for the following purposes:

• to personalize user experience;
• we may use information in the aggregate to understand how users as a group use the services and resources provided on our Sites;
• to improve our Sites;
• to improve customer service;
• to more effectively respond to your customer service requests and support needs;
• to share your information with third parties;
• to administer a content, promotion, survey or other Site feature;
• to send you information you have agreed to receive about topics we think will be of interest to you; and
• if you decide to opt-in to our mailing list, you will receive emails that may include company news, updates, related product or service information, etc. If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or you may contact us via our Sites.

5. How We Share Your Personal Information

We use your personal information to provide the Sites to send communications to you about new services, features, or enhancements that may be of interest to you and to handle your customer service questions or issues. We will also share the personal information we collect from you under the following circumstances:

• Protection of rights. We will share personal information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is appropriate to enforce the Terms and Conditions or any other agreement, understanding or arrangement between you and the Sits, including any investigation of potential violations thereof, (iii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Site, or (iv) such action is appropriate to protect the rights, property or safety of the Company, its employees, users of the Sites or others.
• Asset transfers. If we become involved in a merger, acquisition or other transaction involving the sale of some or all of the Company’s assets, user information, including personal information collected from you through your use of the Site, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you through email and/or a prominent notice on the Apps and/or Site.
• Service Providers. We may share your personal information with service providers (including our affiliates that provide services on our behalf) that we engage for the purpose of processing information on our and your behalf. Additionally, we may partner with other companies to process, analyze, and/or store data. While providing services for us, these companies may access your personal information. To the extent applicable, we require these entities to comply with this Privacy Policy and appropriate confidentiality and security measures.

Aggregage also may disclose your Personal Information:

• to third parties for marketing or any other legally permissible purpose at our sole discretion (if you are a user from the European Union, we will ask for your consent before doing this);
• to our subsidiaries and affiliates with assurances they will treat your Personal Information consistent with this Privacy Policy;
• to a third party or parties, with your consent and where disclosure is required or permitted by law; and
• if, in the reasonable judgment of Aggregage, it is necessary to enforce compliance with our internal policies or to protect our Sites, customers, or others.

Third party websites

In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us. Notably, we use SendGrid to facilitate our email communications. You can view SendGrid’s Privacy Policies here: https://sendgrid.com/policies/privacy/.
In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
Once you leave our Sites or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our Sites’ terms.

Social Media Sites

We work with third parties, including social network sites like Twitter, Facebook and LinkedIn. We provide access to our Sites by third parties and business partners so we can generate interest in our products among members of your social networks and to allow you to share product interests with friends in your network.
The use of any features made available to you on our Sites by a third party may result in information being collected or shared about you by us or by the third party. Information collected or shared through any such third party features is considered public information by us because the Social Media Sites made it publicly available. If you do not want us to be able to access information about you from Social Media Sites, you must instruct Social Media Sites not to share the information. Aggregage is not responsible for how these third parties may use information collected from or about you, so be sure to review the privacy policies and privacy settings on your social networking sites to make sure you understand the information they are sharing. If you do not want a Social Media Site to share information about you, you must contact that site and determine whether it gives you the opportunity to opt out of sharing such information. However, we do identify any areas on our Sites where third parties share information about you.
We use features on Social Media Sites that allow you to express positive opinions about our products or services. Those Social Media Sites may collect or register your views about our products and make those views available to Aggregage and on public portions of the Social Media Sites. If you do not wish any of this to happen, you should not express your views about our products on Social Media Sites, you should not buy our products through Social Media Sites, and you should review your privacy settings on such Social Media Sites. We are not obligated to display your name or other identifying information, account name, profile photo or other information or content on our Sites even if you express an opinion about one of our products or have consented to our use of such information or content. We reserve the right to remove the information of any person for any reason. We may also remove from our Sites, in our sole discretion, any product offering or any photo or product description relating thereto. If you would like us to delete the data we have collected about you that we have received through any social media provider or Social Media Site, please contact us. However, if your information is deleted you may not have access to certain promotions, product information or opportunities as a result.

Links

The Sites may list or link to third party products or services. Aggregage does not have any control over the quality, safety or legality of the items advertised, the truth or accuracy of the listings, the ability of suppliers to sell items or the ability of buyers to buy items. For these reasons, Aggregage and its affiliates cannot ensure that a buyer or supplier will actually complete a transaction. Aggregage will not be a party to any transactions between you and such third parties and any correspondence concerning such transactions should be conducted between you and the third party.

6. How We Protect Your Information

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Information, username, password, transaction information and data stored on our Sites.
Sensitive and private data exchange between the Sites and their users happens over a SSL secured communication channel and is encrypted and protected with digital signatures.
The personal information that you provide to us is stored on servers, which are located in secured facilities and protected by protocols and procedures designed to ensure the security of such information. However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect user information, we cannot ensure or warrant the security of any information you transmit to us or through the use of any of the Sites and you acknowledge and agree that you provide such information and engage in such transmissions at your own risk. Once we receive a transmission from you, we will endeavor to maintain its security on our systems.
In the event that personal information you provide to us is compromised as a result of a breach of security, when appropriate we will take reasonable steps to investigate the situation, notify you and take the necessary steps to comply with any applicable laws and regulations.

7. Children’s Information

The Sites are not directed to children under the age of 13. Children under the age of 13 are prohibited from submitting any personally identifiable information to Aggregage through the Sites. If you believe a child has provided us with information, contact us at privacy@aggregage.com.

8. California Residents’ Privacy Rights

California Consumer Privacy Act

The California Consumer Privacy Act of 2018 (the “CCPA”) is a California law that gives California residents (“consumers”), the right to learn about and control certain aspects of how a business handles the personal information that a business collects about them. Pursuant to the CCPA, effective January 1, 2020, consumers whose personal information have been collected by us, have certain rights, including:

• The right to know the categories of personal information we’ve collected and the categories of sources from which we got the information;
• The right to know the business purposes for sharing personal information;
• The right to know the categories of third parties with whom we’ve shared personal information;
• The right to access the specific pieces of personal information we’ve collected; and
• The right to delete your information.
• California residents also have the right to not be discriminated against if they choose to exercise their privacy rights.

To learn more about these rights, your personal information under the CCPA, please visit our California Privacy Rights homepage. You can also email us at privacy@aggregage.com with any questions.
To exercise your right to opt-out of the sale of personal information, please email us at privacy@aggregage.com and mention the email address you would like to opt-out from sharing personal information of.

Shine the Light

Additionally, if you are a California resident, you have the right to request information from us regarding the manner in which Aggregage shares certain categories of Personal Information with third parties for their direct marketing purposes, in addition to the rights set forth above. Under California law, you have the right to send us a request at the designated address listed below to receive the following information:

• The categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
• the names and addresses of the third parties that received the information; and
• if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.

This information may be provided in a standardized format that is not specific to you. The designated email address for these requests is: privacy@aggregage.com.

Do Not Track

Also, please note that we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.

9. European Users’ Privacy Rights

Legal Basis for Processing Information

If you are located in the EEA or Switzerland, we rely on several legal bases to process your Personal Information. These legal bases include where:

• The processing is necessary to perform our contractual obligations, such as to provide you with our services;
• You have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes we obtain your consent for from time to time);
• The processing is necessary to comply with a legal obligation, a court order or to exercise or defend legal claims;
• The processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, and developing our services, marketing new features or products that may be of interest, and promoting safety and security as described above.

If you have any questions about this, or would like further information concerning the legal basis on which we collect and use your Personal Information, please contact us by emailing privacy@aggregage.com.

Data Retention

If you are an Aggregage customer, we will retain your Personal Information as long as we are providing the services to you. We retain Personal Information after we cease providing services to you, even if you close your Aggregage account, to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention. We also retain Personal Information to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods that we support. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

Rights Under the General Data Protection Regulation

If you are located in the EEA or Switzerland, you have the following rights in respect of your Personal Information that we hold:

• Right of access. The right to obtain access to your Personal Information.
• Right to rectification. The right to obtain rectification of your Personal Information without undue delay where that Personal Information is inaccurate or incomplete.
• Right to erasure. The right to obtain the erasure of your Personal Information without undue delay in certain circumstances, such as where the Personal Information is no longer necessary in relation to the purposes for which it was collected or processed.
• Right to restriction. The right to obtain the restriction of the processing undertaken by us on your Personal Information in certain circumstances, such as where the accuracy of the Personal Information is contested by you, for a period enabling us to verify the accuracy of that Personal Information.
• Right to portability. The right to portability allows you to move, copy or transfer Personal Information easily from one organization to another.
• Right to object. You have a right to object to processing based on legitimate interests and direct marketing.
• Withdrawing consent.  If our processing of your Personal Information is based on your consent,
  you have the right to withdraw your consent at any time. Please note that if you withdraw your
  consent, this will not affect the lawfulness of our processing of your information on the basis of
  your consent before the point in time when you withdraw your consent.

If you wish to exercise one of these rights, please email us at privacy@aggregage.com. Please note, some rights may be limited, and we may need to retain certain Personal Information, as required or permitted by applicable law. You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Transfer of Personal Information Outside of Europe

We take steps to ensure that we handle your Personal Information subject to appropriate safeguards. As a US company, most of our operations are conducted in the United States and in order to provide the Sites, Personal Information will be processed in the United States, where laws regarding processing of Personal Information may be less stringent than the laws in your country. We provide appropriate protections for cross-border transfers as required by applicable law for international data transfers. With respect to transfers originating from the European Economic Area we implement the standard contractual clauses approved by the European Commission. Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below.

Automated Decision-Making

We do not use automated decision-making without human intervention, including profiling, in a way
that produces legal effects concerning you or that otherwise significantly affects you.

10. Changes to this Privacy Policy

You acknowledge that this Privacy Policy is part of the Terms and Conditions for your use of the Sites, and you agree that using the Sites signifies your assent to Aggregage’s Privacy Policy. Aggregage reserves the right to change this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it and under what circumstances we disclose it. As we may make changes from time to time without notifying you, we suggest that you periodically consult this Policy. Your continued use of the Sites after the effective date of any modification to the Policy will be deemed to be your agreement to the changed terms.

11. Contact Us

If you have any questions about your privacy or security on our Sites, please contact us using the following information:

Aggregage, Inc.

P.O. Box 49172

Los Angeles, CA 90049-9998