Data Protection and Privacy Policy

Arch-Intelligence’s Data Protection and Privacy Policy

Arch-Intelligence Ltd. (“Arch-Intelligence”, “we” or “us”) respects the privacy of users of its website at https://archintelligence.com (the “Site”) and related services (“User” or “you”) and are committed to protect the personal data that their Users share with them. We believe that you have a right to know our practices regarding the information we may collect and use when you visit and/or use our Site.

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use at https://archintelligence.com/terms-of-use/ (the “Terms of Use”), into which this Data Protection and Privacy Policy is incorporated by reference.

1. Your Consent (PLEASE READ CAREFULLY!)

BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS DATA PROTECTION AND PRIVACY POLICY (THE “DATA PROTECTION AND PRIVACY POLICY”), INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL DATA (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ACCESS OR USE THE SITE OR SERVICE.

FOR AVOIDANCE OF DOUBT, YOU HEREBY CONSENT TO THE COLLECTION, PROCESSING, TRANSFER AND USE OF YOUR PERSONAL DATA. YOU ALSO ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT REQUIRED TO PROVIDE US WITH YOUR PERSONAL DATA AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED TO US.

2. General Principles of Our Data Protection

1. We are committed to ensuring that your Personal Data and the privacy of your data is protected according to the appropriate industry standards and practices in relation to the data we collect, and all in correspondence to our relevant legal obligations.
2. This Policy further applies also to Arch-Intelligence’s use of cookies and tracking tools, as specified in detail in our Cookies and Tracking Tools Policy as we use cookies and tracking tools on the Site to distinguish you from other and to improve your use of our Site, and in some cases, certain features may not function if you remove the cookies from your browser.
3. We collect and process your Personal Data in good faith, in a proportionate manner according to the declared purpose, and with the appropriate technical and organizational measures in line with the state of the art measures, while taking into account the risks represented by our collection and processing and the nature of the Personal Data and data protected by us.

3. Which information we may collect on our Users?

We may collect two types of data and information from our Users:

1. Non-identifiable and anonymous information (“Non-personal data”). We are not aware of the identity of the User from whom we have collected the Non-personal data. Non-Personal data is any unconcealed information which does not enable the identification or the profiling of an individual User, and which is available to us while such User is entering into and/or using the Site. Non-personal data which is being gathered consists of technical information, behavioral information and aggregated information, and may contain, among other things, the activity of the User on the Site, type of operating system, User’s ‘click-stream’ or searches on the Site, type and version of browser, keyboard language, screen resolution, etc.
2. Personally identifiable information (“Personal data”). This information may identify an individual or may be of a private and/or sensitive nature.

• Users of the Site automatically provide their IP address, UDID and other unique identifiers, mainly for enhancing the User’s experience and for geo-location, advertising and security purposes as further detailed below.
• In addition, Personal data which is being gathered consists of any personal details provided consciously and voluntarily by the User:

• Personal data is collected from the details the Users provide whilst contacting us via the “Contact Us” online form on the Site’, including:

• full name and/or organization’s name,
• e-mail address; and
• any content included in the text you wish to insert into the “comment” box.
• Additionally, you may optionally provide your telephone number.

• Once your contact details are received by us, you hereby consent that our representative will be entitled to contact you for further communication according to your inquiry or request based on the contact information so provided. Our representatives may collect additional Personal data from you during such contact and we shall retain and process any such Personal Data to the extent it is relevant in respect to fulfilling your inquiry or request.

• Personal data is collected from the details the Users provide whilst either registering to download a trail version and/or purchasing a license to Product(s), which includes:

• the User’s first and last name,
• (where applicable) the organization in which he/she works,
• country and city of residence address,
• email address and billing information.

• When purchasing a license to use the Product(s), Users will be required to provide the abovementioned Personal data and may optionally provide their telephone number.
• When purchasing certain licenses, you may be prompted through further contact from Us to provide a password in order to register to our corporate/enterprise license control website.

• Personal data is collected from the prospective Resellers who apply to us through an online form, which includes:

• the full name of the applicant on behalf of an organization;
• the name of the organization in which the Reseller works;
• and the Reseller’s country and city of residence, email address, password and billing information.
• The Reseller’s website;
• The country where the organizations main office is located.

• You may also provide additional optional information provide whilst applying to become a Reseller, including and the Reseller’s city of residence, sales area/s, additional information in the designated “text box” and method of hearing about Us.
• Once we review your application we may use your contact details as received by us to contact you, and you hereby consent that our representative will be entitled to contact you for further communication according to your inquiry or request based on the contact information so provided.
• Our representatives may then collect additional Personal data from you during such contact (direct, correspondence or automated link) and we shall retain and process any such Personal Data to the extent it is relevant, including billing information for your organization, and the password used for the Account designated to the Reseller.

• Please note that in order to provide certain services, such as to enable you to purchase a license to use the Product or to register as a Reseller, you will have the option to use certain Online Payment Processors (as defined below) which will require you to fill out a billing form wherein you will be required to provide to such Online Payment Processors certain Personal data (such as, a credit card number and other related billing information) (see Section 9 below regarding the payment method). We will not store such information on our servers. We only keep token information such Online Payment Processors provide us with (and where applicable, the last four digits of your credit card number), and such information is strictly secured.
• Personal data may be collected as part of any communications with Arch-Intelligence, by any means, including through our social network pages, by approaching our customer services, attending Arch-Intelligence events or during sales calls (such information may include marketing and communication data that includes your preferences in receiving marketing from us and your communication preferences).

1. We do not collect any Personal data from you or related to you without your approval, which is obtained, inter alia, through your active acceptance to the Terms of Use and the Data Protection and Privacy Policy.
2. Important Notes on Data Subject Rights:

• In the implementation of these data protection rights We are committed to providing a timely and transparent response to your requests, and upholding your right to contact Us.
• Any data subject rights that you wish to uphold by Us, may not be fulfilled if you do not provide Us with relevant and/or sufficient information required for us to identify you as the data subject of said Personal Data, and we shall inform you accordingly in such an event.
• If you believe Arch-Intelligence has violated any of your data subject rights, you are entitled to:

1. For EU countries – file a complaint to the Data Protection Authority in your jurisdiction of residence about the alleged data protection breach;
2. file a lawsuit to the courts of the state of your residence.

4. How Do We Collect Information on Our Users?

There are a few methods that we use:

1. We collect information through your entry and use of the Site and Products. In other words, when you are using the Site we are aware of it and may gather, collect and store the information relating to such usage.
2. We collect information which you decide to provide us voluntarily. For example, we collect Personal data when you contact us through the Contact Form or report a problem.
   We may gather, collect and store such information either independently or through the help of our authorized third-party service providers as detailed below.

5. What are the Purposes of the Collection of Information?

Non-personal data is collected in order to:

• Use it for statistical and research purposes and for customization and improvement of our Site and services.
• Enhance the User’s experience while using the Site.
• Keep the Site safe and secured and for prevention of fraud.

Personal data is collected in order to:

• Provide and personalize our Services to our Users.
• Verify the identity of our Products’ users and the validity of the Product’s license when the user signs in to the Product, as well as verifying User’s identity for the purpose of dealing with fraudulent use of our Products.
• Notify you that your trial license in one of our Products is about to expire and offer you to purchase a paid license and/or to extend the trial period.
• Respond to your inquiry and to contact you for marketing and sales purposes.
• Respond to you support request and provide you with technical assistance and support.
• Provide the Users with commercial materials, updates about Arch-Intelligence’s developments, new offerings, news regarding the Site and products, etc.
• Determine general geolocation information (i.e., country) from which the User’s computer is connected to the Internet in order for us to know the general location of our Site’s Users as well as in order to safeguard our Site.
• Conduct internal operations, including troubleshooting, data analysis, testing, research and statistical purposes, including in order to improve our products. Please note that in general we analyze aggregate data for such purposes, rather than specific user data, however we may need to analyze a specific case to address a specific problem;
• Comply with our legal obligations and in order to be able to protect our rights and legitimate interests;
• Email tracking – we may use tracking technology within the email we may send you in order to improve interactions with you and to better understand whether our emails were opened and read, and such tracking may include capturing the time and date in which you opened our email messages and the type of device you use to open such emails.
• To ensure the integrity, security and fulfillment of the Terms of Use and this Data Protection and Privacy Policy by your users, including but not limited to detecting, monitoring, and preventing fraud and/or monitoring account activity.

6. Data Subject Rights You are Entitled to

You have certain rights in relation to the Personal Data that we hold about you, as detailed below:

• Consent – We will only process your Personal Data if you have consented to such processing, unless We are otherwise legally authorized or obliged to collect and further process Personal Data relating to you any of your rights below.
  If we process data solely based on your informed consent, We will only use the data for the purposes stated in the consent procedure and within the scope outlined below.
• Withdrawal of consent – You may revoke or withdraw your consent at any time by contacting and requesting so from Us, and We will stop processing your Personal Data unless We are legally obliged or authorized to continue processing your information, including for ongoing legitimate business interests, which we will notify you in our response to your request, where applicable.
• The Right of Deletion (“To be Forgotten”) and Right of Rectification – You may also request the erasure or correction of all or part of your Personal Data that is held by Us.

Upon your request, We will accommodate your request and delete (or alternatively equivalently irreversibly anonymize) or correct your Personal Data or remove from part or all of our records, as per your request, as soon as reasonably possible and when technically feasible, and unless there is an overriding legal interest or other authorized basis for the continuation of the processing of your Personal Data, which we shall notify you in response to your request.

Please be aware that in the event of deletion or correction of Personal Data upon your request, We may not be able to further provide you the services you applied for through the Site, in whole or in part and by requesting such deletion/correction, you irrevocably agree and waive any claim against Arch-Intelligence’s inability to provide the services through the Site.

• Transparency and Data Portability. You are entitled to ask us for information about what type of Personal Data about you has been collected by Us.
  You are also entitled to obtain (in a commonly used and machine-readable form) and reuse your Personal Data as you have provided to us (following your consent or to allow us to perform services under a contract) and which We process, for your own purposes across different services and free of charge, subject to technical feasibility and lawfulness considerations.
• Automated decision-making. We. shall not intentionally take any potentially damaging decision concerning you because of using automated processing and decision-making operations without human intervention; and commits that where such will be implemented we will give you the opportunity to obtain human intervention in such a decision, express your point of view, and obtain an explanation of the decision.

7. How you can assist Protecting your Information

You can follow some simple steps to keep your information secure. When you create your Account as Reseller and/or account, choose a strong password that is unique to this account and do not share your password any other personal. If you suspect that someone else has got access to your password, make sure that you change it immediately.

If you receive an email that looks suspicious, e.g. refers to an order you do not recall making or requesting information already provided, or you have doubts as to whether an email was actually sent by Us, please contact us and report this.

8. Sharing Information with Third Parties

Arch-Intelligence will not share any Personal data it collects with any third party, other than in the following circumstances:

(a) when you provide us with your contact details via the Sites or make certain requests for support related to our products or services and we wish to respond to your request/inquiry through one of our authorized resellers or technical support subcontractors;

(b) to satisfy any applicable law, regulation, legal process, subpoena or governmental request;

(c) to enforce this Data Protection and Privacy Policy and/or the Terms of Use, including investigation of potential violations thereof;

(d) to detect, prevent, or otherwise address fraud, security or technical issues;

(e) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment;

(f) to protect the rights, property, or personal safety of Arch-Intelligence, its Users or the general public;

(g) by virtue of undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Arch-Intelligence, so long as such acquirer maintains the same data protection and privacy terms hereunder; or

(h) pursuant to your explicit approval prior to the disclosure.

Note, that we collect, hold and/or manage Personal data through Arch-Intelligence’s authorized third parties vendors of certain products or services (such as, hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction, as further elaborated in section 17 below.

For avoidance of doubt, Arch-Intelligence may use Non-personal data and transfer and disclose it to third parties at its discretion.

9. Payment

We accept certain online payment methods, using our “Online Payment Processors”, which enable Users to remit payments securely online using a credit card or bank account. We may add or change the Online Payment Processors at our sole discretion.

Arch-Intelligence is not affiliated with such Online Payment Processors, as each is an independent contractor, and neither is the agent or employee of the other, and neither is responsible in any way for the actions or performance (or lack thereof) of the other.

The use of the Online Payment Processors is at the User’s discretion and sole liability and risk. It is the User’s responsibility to abide by all the terms specified by the Online Payment Processors in their terms of use and privacy policies, including but not limited to any age restrictions specified therein. You acknowledge that you are fully assuming the risks of conducting any transactions via the Online Payment Processors.

10. Social Features

The Site may include social media features (“Social Features”). The Social Features are operated or allow for social integration with certain third party social networks or third party platforms (“Social Network”). These Social Networks are created and maintained by third parties who are not affiliated with and/or controlled by Arch-Intelligence.

If you enable this integration with such Social Networks, your use of the Social Features is subject to the applicable third party Social Network’s terms of use and privacy policies. You should ensure that you read their terms of use and privacy policies to understand how they treat your information and in order to understand the methods for changing the privacy or sharing settings on such services.

If you do not agree to the practices described in such terms you should not interact with such Social Networks, however you may find that you are not able to enjoy all the features that may be made available via the Site following such integration, if so selected by You.

You understand that where you allow interaction with any third party Social Network, we may share data about you with your contacts (and vice versa) in order that you may enjoy social elements. This data may include, without limitation, your name and your social media profile picture.

By using the Social Features you hereby agree and understand that the applicable Social Networks or Platforms may collect certain Personal data, such as your IP address, Non-personal data and may set cookies and/or other web tracking technologies to enable the functionality of the Social Features. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the third party that provides the Social Features.

You hereby understand and agree that when you share content via Social Networks that your content may become public and others may re-post-it.

11. Deletion or Modification of Personal data

In any event, if for any reason you wish to delete or modify Personal data, please send us an e-mail with adequate details of your request to: contacts@arch-intelligence.com and we will make reasonable efforts to modify or delete any such Personal data pursuant to any applicable privacy laws.

Note that unless otherwise explicitly specified herein and/or unless you instruct us otherwise, we may retain your Personal data for as long as reasonably required for the purposes of which such Personal data was collected, all as permitted under any applicable privacy laws.

Aggregated and/or anonymous information derived from your use of the Site may remain on our servers indefinitely.

Please note that the laws of your local jurisdiction may provide you with certain privacy related rights, such as a right of access, right of rectification, right to erasure, right to restrict processing, right of data portability and right to object to processing of Personal data.

If you wish to exercise such rights and find that you are unable to do so via the Site, please send us an email with adequate detail of your request to contacts@arch-intelligence.com.

12. Minors

The Site is intended for Users over the age of sixteen (16). Therefore, Arch-Intelligence does not intend and does not knowingly collect Personal data from children under this age.

We reserve the right to request proof of age at any stage so that we can verify that minors under this age are not using the Site. If we learn that we collected Personal data from minors under the age of sixteen (16) we will delete that information as quickly as possible.

Please contact Arch-Intelligence at contacts@arch-intelligence.com if you have reasons to suspect that Arch-Intelligence collected Personal data from minors under the age of sixteen (16) and we will delete that information as quickly as possible.

13. Security

We take reasonable measures to maintain the security and integrity of our Site and your information against loss, alteration, theft or to prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur. What we can guarantee is that we will not sell, share, transfer or use the data We collect from you for purposes other than those purposes stated expressly herein above.

ARCH-INTELLIGENCE SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION.

14. Third Party Service Providers

While using the Site we may be using third party service providers, who may collect, store and/or process the information detailed herein. Arch-Intelligence uses commercially reasonable efforts to engage with third parties that post a Data Protection and Privacy Policy governing their collection, processing and use of non-personal and personal data. Such software may include without limitation:

• AWS, whose Data Protection and Privacy Policy can be found at: https://aws.amazon.com/privacy/.

Please read such third party service providers’ terms of use and privacy policies to understand their privacy practices.

15. Links to Third Party Websites

Certain links provided in the Site permit Users to leave our Site and enter non-Arch-Intelligence sites or services. Those linked sites and services are provided solely as a convenience to you. Those linked sites and services are not under the control of Arch-Intelligence and it is not responsible for the availability of such external sites or services, and does not endorse and is not responsible or liable for any content advertising, products, services or other information on or available from such linked sites and services or any link contained in a linked site or service. Arch-Intelligence reserves the right to terminate any link at any time. You further acknowledge and agree that Arch-Intelligence shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such linked sites or resource.

Most of such linked sites and services provide legal documents, including terms of use and Data Protection and Privacy Policy, governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information they are collecting.

16. Cookies and Local Storage

When you access or use the Site, we and/or our third party service providers may use industry-wide technologies such as cookies, web beacons, pixels, clear gifs and other similar tools (or other similar technologies), which store certain local information on your device (“Local Storage”) which may enable us, inter alia, to recognize your device from those of other Users of the Site, to improve the Site’s performance, to deliver a better and more personalized service according to the User’s individual interests and the device or browser used, to track Users’ use of the Site, to gather information about the Users’ approximate geographic location (e.g. city), to prevent fraud and/or abuse, to estimate our audience size and usage pattern and perform other analytics, to develop our Site and to serve targeted advertisements.

For more information, please refer to our “Cookies and Tracking Tools Policy”, at: https://archintelligence.com/cookies-and-tracking-policy/

17. Data Transfer

We do not sell, trade, or otherwise transfer to outside parties your Personal Data, except as specifically stated in this Policy.

The above statement does not include trusted third parties, and prior to such transfers those parties are contractually obliged to keep your Personal Data confidential and to not use it for any purpose other than to fulfill their obligations to us in relation to the provision of our services to you.

In order to provide the Site, we may transfer information collected about you, including Personal data, to affiliated entities, or to other third party service provides (as provided herein) who assist us in operating our services, conducting our business, or servicing you.

Be advised that notwithstanding, We may share your information with subcontractors and other partners across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information.

When we transfer our European customers’ Personal Data outside of the EEA or a Country subject to a decision by the European Commission that the country to which our customers’ data is transferred provides an adequate level of data protection, only if it is strictly necessary, and in any such case we will vet and check such third parties data protection practices beforehand and verify that the requisite contractual obligations according to the applicable data protection law are executed in in order to make all possible efforts to ensure the protection of our customers’ data prior to such transfers.

Notwithstanding the above, all our subcontractors and other third parties will be subject to contractual obligations limiting their use of your Personal Data and subjecting their activities to the applicable data protection and privacy legislations applicable to your personal data and further to the foregoing all our subcontractors will be subject to non-disclosure and non-use obligations.

Be advised that We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity or behavior of any user suspected to have engaged in illegal behavior and thereby we may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety.

However, non-personally identifiable user information may be provided to other parties for analytics, trends study, or other uses, as previously established is one of the purpose of use herein above.

18. Direct Marketing

You hereby agree that we may use your contact details you provided us with (including, without limitation, e-mail address and phone number) for the purpose of providing you commercial and/or non-commercial materials related to our current and/or future products and services.

You may withdraw your consent by sending a written notice to Arch-Intelligence’s e-mail address that appears in the Site or alternatively follow the instructions for removing yourself from the mailing list which are available in the message transmitted to you.

19. Changes to the Data Protection and Privacy Policy

The terms of this Data Protection and Privacy Policy will govern the use of the Site and any information collected therein. Arch-Intelligence reserves the right to change this policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this policy on the homepage of the Site and/or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such substantial changes will take effect seven (7) days after such notice was provided on our Site or sent by e-mail, whichever is the earlier. Otherwise, all other changes to this Data Protection and Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Site after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by law and without any prior notice.

20. Got any Questions?

If you have any questions (or comments) concerning this Data Protection and Privacy Policy, you are most welcome to send us an email to the following address: contacts@arch-intelligence.com and we will make an effort to reply within a reasonable timeframe.

Additional Privacy Protection Terms for California Residents

21. General

Beginning January 1, 2020, the California Consumer Privacy Act (“CCPA”) gives California residents certain rights with respect to the processing of personal data (known as “personal information” under the CCPA).

This supplement provides additional privacy disclosures and privacy protection provisions in light of the CCPA for California residents accessing our website.

22. Personal Information Collected and Processed

The section titled “Information We Collect” sets forth the categories of personal information that We collect and process about you, a description of each category, and the sources from which we obtain each category.

23. Requests to Exercise Your Rights under the CCPA

You are afforded and entitled to forward us requests to exercise your rights as a California resident. We will not discriminate against you for exercising any of your rights under the CCPA:

• You may make a verifiable consumer request related to your personal information twice per 12-month period.
  Please note, if you do not have an Account as Reseller or a corporate/enterprise user to our designated license control website, we may not have enough information about you to verify your identity to exercise your rights under the CCPA and may ask you to provide personal identification information in order to verify your identity.
• You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
• Right To Know – Under the CCPA, you have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months prior to the date of your request, and ask that we provide you with the following information:

• The Categories of and specific details of the personal information we have collected about you.
• The Categories of sources from which we collect personal information about you.
• The Purposes for collecting personal information as per 1 and 2 above.
• The Categories of third parties with which we shared your personal information.
• Categories of personal information disclosed about you for a business purposes.

• If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.
• To make a verifiable request for information about the personal information we have collected about you, please forward a request through your Account as a Reseller and/or your user on our license key control website and/or email or send us a request through the “Contact Us” online form or at: contacts@arch-intelligence.com.
• Right To Delete – You also have a right to request that we delete personal information, subject to certain exceptions.
  To make a verifiable request for information about the personal information we have collected about you, please forward a request through your Account as a Reseller and/or your user on our license key control website and/or email or send us a request through the “Contact Us” online form or at: contacts@arch-intelligence.com.

Household Requests – We do not collect household data and only process information about individual users making orders and/or operating an account on our website. If all the members of a specific household makes a Right to Know or Right to Delete request, we will respond to each such request individually and not process all the data as a “Household”.

24. Disclosures of Personal Information for a Business Purpose

In the preceding 12 months, We have disclosed certain data from the following categories of personal information to the categories of recipients listed in Section 14 of our Data Protection Privacy Policy “Third Party Service Providers” for one or more business purposes:

• User Data
• Analytics
• Payment and Purchase Data

25. Sale of Personal Information

We do not sell personal information. We have taken substantial steps to identify and remediate any data sharing arrangements that could constitute a “sale” under the CCPA.

While we do not sell any personal information directly, but we do provide Usage Data to analytics and advertising partners to enable us to provide you with interest-based advertising.

If you prefer not to receive interest-based advertising, please opt out by going to your account privacy settings and using the tailored ads opt out toggle as further elaborated in our Cookies and Tracking Tools Policy.

We will continue to update our business practices as regulatory guidance becomes available and provides clarity on what constitutes a sale transaction, particularly in the advertising ecosystem.

Last Revised: April 15, 2022