## Privacy Policy This Privacy Policy describes how Xpressive AI Inc. ("Xpressive AI," "we", “us” or "our") processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable our website, social media pages, our marketing activities, and other activities described in this Privacy Policy (collectively, the “Service”)). We may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information. We provide an AI video platform that enables users to use many personalized videos for their target audience. This Privacy Policy does not apply to information that we process on behalf of our business customers (such as businesses and other organizations) while providing our services to them. Our use of information that we process on behalf of our business customers may be governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of a business customer, please direct your concerns to that enterprise customer. The Service is designed for businesses and their representatives. We do not offer products or services for use by individuals for their personal, family or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as business representatives of the relevant enterprise customer and not their individual capacities. **Notice to European Users** : Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly) below. ## Index Personal information we collect How we use your personal information How we share your personal information Your choices Other sites and services Biometric Data Policy Security International data transfer Children Changes to this Privacy Policy How to contact us Notice to European Users ## Personal information we collect Information you provide to us. Personal information you may provide to us through the Service or otherwise includes: ``` - Contact data, such as your first and last name, email address, billing and mailing addresses, company name, company domain name, professional title, and phone number. ``` ``` - Demographic data, such as your city, state, country of residence, postal code, and age. ``` ``` - Profile data, such as the username and password that you may set to establish an online account on the Service and any other information that you add to your account profile. ``` ``` - Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise. ``` ``` - Job application data, such as professional credentials and skills, educational and work history, LinkedIn profile page, personal website, authorization to work in the U.S., immigration status, criminal history, and other information that may be included on a resume or curriculum vitae as well as in a cover letter. This may also include diversity information that you voluntarily provide. ``` ``` - Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history. ``` ``` - Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them. ``` ``` - User content data, such as the initial audio and video samples you provide (which may be considered “biometric data” as described further in the Biometric Data Policy below), the AI-generated videos you create through the Service, the business logo, contact information, and other distribution information you provide for any AI-generated videos, as well as any comments, questions, messages, works of authorship, and other files, content, or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data. - Payment data needed to complete transactions, including payment card information or bank account number. - Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection. ``` Information you provide to us. We may combine personal information we receive from you with personal information we obtain from other sources, such as: ``` - Public sources, such as government agencies, public records, social media platforms, and other publicly available sources. ``` ``` - Data providers, such as information services and data licensors that provide demographic and other information. ``` ``` - Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs. ``` ``` - Marketing partners, such as joint marketing partners and event co-sponsors. - Third-party services, such as social media services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated ``` ``` with your account on that third-party service that is made available to us based on your account settings on that service. ``` Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as: ``` - Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area. ``` ``` - Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them. - Location data when you authorize the Service to access your device’s location. ``` ``` - Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails. ``` Cookies and similar technologies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our **Cookie Notice**. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service. Data about others. We may offer features that help users invite their colleagues or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so. ## How we use your personal information We may use your personal information for the following purposes or as otherwise described at the time of collection: Service delivery and operations. We may use your personal information to: ``` - provide, operate and improve the Service and our business; - personalize the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service; - establish and maintain your user profile on the Service; ``` ``` - facilitate your invitations to colleagues or contacts who you want to invite to join the Service; ``` ``` - enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in; ``` ``` - communicate with you about the Service, including by sending service-related announcements, updates, security alerts, and support and administrative messages; ``` ``` - understand your needs and interests, and personalize your experience with the Service and our communications; and ``` ``` - provide support for the Service, and respond to your requests, questions and feedback. ``` Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business (e.g., by training our proprietary artificial intelligence technology). Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes: ``` - Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below. ``` ``` - Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest- based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section of our Cookie Notice. ``` To manage our recruiting and process employment applications. We may use personal information, such as information submitted to us in a job application, to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics. Compliance and protection. We may use your personal information to: ``` - comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations, or requests from government authorities; - protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); - audit our internal processes for compliance with legal and contractual requirements or our internal policies; - enforce the terms and conditions that govern the Service; and ``` ``` - prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft. ``` Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law. To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de- identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business. ## How we share your personal information We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection. Affiliates. Our affiliated companies, for purposes consistent with this Privacy Policy. Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research, and website analytics). Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe and Recurly. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy. Recurly may use your payment data in accordance with its privacy policy, https://recurly.com/legal/privacy. Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above. Third parties designated by you. We may share your personal data with third parties where you have instructed us or provided your consent to do so. We will share personal information that is needed for these other companies to provide the services that you have requested. Business and marketing partners. Third parties with whom we co-sponsor events, with whom we jointly offer products or services, or whose products or services may be of interest to you. Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service. Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us. Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above. Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in us, financing of us, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of us as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets. ## Your choices In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights below. Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account or by contacting us at [email protected]. Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt- out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. Cookies. For information about cookies employed by the Service and how to control them, see our **Cookie Notice**. Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit [http://www.allaboutdnt.com.](http://www.allaboutdnt.com.) Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services. Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party. Close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us. ## Other sites and services The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use. ## Biometric Data Policy for U.S. users We collect and processes information that may be considered “biometric data” under certain laws from individuals who use our Service. By accessing our Services and voluntarily providing User content data including such “biometric data,” you are providing your consent to our collection, use and disclosure of your information that may be considered “biometric data” as described in this Biometric Data Policy. ``` - Biometric Data. Biometric data is identifying information related to your biometric characteristics which may be used to identify you. Voiceprints (in audio samples you provide) and facial geometry (included in video samples you provide) are examples of common forms of biometric data that may be included in the User content data you provide in order to use the Service. We collect and uses certain information related to your physical characteristics, specifically included in the audio and video samples you upload in order to provide our Services. ``` ``` - Biometric Data Collection. When you sign up for a an account to use our Services, you may provide certain biometric data. For example, to use the Services, you may provide several audio and video recordings that include physical characteristics such as your voice and facial geometry. You may decline to provide your biometric data. However, if you decline to provide biometric data, certain Services that require the use of such data will become unavailable to you. You may also experience a loss of functionality of some or all of the Services that we provide. ``` ``` - Use of Biometric Data. We will create anonymized data to train AI models, provide the Services (e.g., make requested custom videos), and for compliance and protection purposes (as outlined above). ``` ``` - Security of Biometric Data. We take data security seriously and has implemented data security measures designed to secure biometric data as described in the Security section, below. ``` ``` - Biometric Data Sharing. We may work with certain third parties to provide the Services to you, but only as necessary to provide you with such Services. We have agreements with third parties that will receive your biometric data where the third party has a legitimate need to deliver the Services to you. These third parties are contractually obligated to protect your biometric data. In certain specific instances, we may disclose biometric data in cases where such disclosure is required by State or federal law, or municipal ordinance, or when required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction. ``` ``` - Retention. For any biometric data that we collect from you, we will retain such biometric data only until (a) the initial purposes for which we collected your biometric data has been satisfied (e.g., to provide our Services), or (b) one year following your last interaction with us (e.g., the last time you used our Service), whichever comes first. After such occurrence, we will delete your biometric data in accordance with applicable law. You may also request that we delete your biometric data by notifying us at [email protected] or closing your account. ``` ## Security We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information. ## International data transfer We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. Users in Europe should read the important information provided below about transfer of personal information outside of Europe. ## Children The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information. ## Changes to this Privacy Policy We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business. ## How to contact us ``` - Email: [email protected] ``` ## Notice to European Users General **Where this Notice to European users applies.** The information provided in this ‘Notice to European users’ section applies only to individuals located in the European Economic Area (EEA) or United Kingdom (UK) (i.e., “ **Europe** ” as defined at the top of this Privacy Policy). **Personal information.** References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” as defined in the “ **GDPR** ” (i.e., the General Data Protection Regulation 2016/ (“ **EU GDPR** ”)) and the EU GDPR as it forms part of the laws of the United Kingdom (“ **UK GDPR** ”) Under the GDPR, “personal data” means information about individuals from which they are either directly identified or can be identified. The personal information that we collect from and about you is described in greater detail in the section “Personal Information we collect”. **Controller.** Xpressive AI is the “controller” in respect of the processing of your personal information covered by this Privacy Policy for purposes of the GDPR. See the ‘How to contact us’ section above for our contact details. **Our GDPR Representatives**. We have appointed the following representatives in Europe as required by the GDPR – you can contact them directly should you wish: ``` Our Representative in the EU. Our EU representative appointed under the EU GDPR is DataRep. You can contact them: ``` ``` - By email to: [email protected] ``` ``` - By postal mail to: 2101 CityWest, Houston TX 77042 ``` ``` Our Representative in the UK. Our UK representative appointed under the UK GDPR is DataRep. You can contact them: ``` ``` - By email to: [email protected] ``` Our legal bases for processing In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use. Our legal bases for processing your personal information described in this Privacy Policy are listed below. ``` ● Where we need to process your personal information in order to deliver the Service to you, or where you have asked us to take specific action which requires us to process your personal information (“ Contractual Necessity ”). ● Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“ Legitimate Interests ”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below. ``` ``` ● Where we need to comply with a legal or regulatory obligation (“ Compliance with Law ”). ● Where we have your specific consent to carry out the processing for the Purpose in question (“ Consent ”). ``` We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see the ‘How we use your personal information’ section above and the description of associated data sharing relevant to such purposes set out in the ‘How we share your personal information’ section also above. **Purpose Categories of personal information involved** ``` Legal basis ``` **Service delivery and operations** ``` - Contact data - Demographic data ``` ``` - Communications data ``` ``` - Job application data - Transactional data ``` ``` - Marketing data ``` ``` - User content data ``` ``` - Payment data ``` ``` - Data from Third Party Services ``` ``` - Device data ``` ``` Delivery and operations ``` ``` - Contractual Necessity. - Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our Service, our business and associated IT services, systems and networks. ``` ``` Personalization ``` ``` - Legitimate Interests. We have a legitimate interest in providing you with a good service via the Service, which is personalized to you and that remembers your selections and preferences. ``` ``` - Consent, in respect of any optional processing relevant to personalization (including processing directly associated with any optional cookies used for this purpose). ``` **Research and development** ``` - Any and all data types relevant in the circumstances ``` ``` - Legitimate Interests. We have legitimate interest in researching users’ use of our Service and developing our Service accordingly, including through the use of artificial intelligence technologies. ``` **Direct marketing** (^) - Contact data - Demographic data - Transactional data - Marketing data - **Legitimate Interests**. We have a legitimate interest in promoting our operations and goals as an organization and sending marketing communications for that purpose. - **Consent,** in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications. **Interest-based advertising** - Contact data - Demographic data - Transactional data - Marketing data - Device data - Online activity data - Location data - **Consent** ``` Purpose Categories of personal information involved ``` ``` Legal basis ``` ``` Service improvement and analytics ``` ``` - Contact data - Demographic data ``` ``` - Communications data ``` ``` - Transactional data - Marketing data ``` ``` - User content data ``` ``` - Device data ``` ``` - Online activity data ``` ``` - Communication interaction data ``` ``` - Legitimate Interests. We have a legitimate interest in providing you with a good service and analysing how you use it so that we can improve it over time, as well as developing and growing our business. ``` ``` - Consent , in respect of any optional cookies used for this purpose. ``` ``` Compliance and protection ``` ``` - Any and all data types relevant in the circumstances ``` ``` - Compliance with Law. ``` ``` - Legitimate Interests. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety. ``` ``` Further uses - Any and all data types relevant in the circumstances ``` ``` - The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the personal information was collected. - Consent , if the relevant further use is not compatible with the initial purpose for which the personal information was collected. ``` Retention We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for the ‘Compliance and protection’ purposes outlined above. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. When we no longer require the personal information that we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you. Other information **No obligation to provide personal information.** You do not have to provide personal information to us. However, where we _need_ to process your personal information either to comply with applicable law or to deliver our Service to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Service to you. We will notify you if this is the case at the time. **No sensitive information.** We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership, or biometric or genetics characteristic other than as requested by us as part of the Service) on or through the Service, or otherwise to us. If you provide us with any such sensitive personal information to us when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service. **No automated decision-making and profiling.** As part of the Service, we do not engage in automated decision- making and/or profiling, which produces legal or similarly significant effects. We provide our analysis to our business customers and our business customers make decisions that may affect you. **Security**. We have put in place procedures designed to deal with breaches of personal information. In the event of such breaches, we have procedures in place to work with applicable regulators. In addition, in certain circumstances (including where we are legally required to do so), we may notify you of breaches affecting your personal information. Your additional rights **General.** European data protection laws may give you certain rights regarding your personal information in certain circumstances. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold: ``` - Access. Provide you with information about our processing of your personal information and give you access to your personal information. - Correct. Update or correct inaccuracies in your personal information. ``` ``` - Delete. Delete your personal information where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). - Transfer. Transfer to you or a third party of your choice a machine-readable copy of your personal information which you have provided to us. - Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it. - Object. Object to our processing of your personal information where we are relying on Legitimate Interests ``` - you also have the right to object where we are processing your personal information for direct marketing purposes. ``` - Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time. ``` **Exercising These Rights.** You may submit these requests by contacting us. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated. **Your Right to Lodge a Complaint with your Supervisory Authority**. Although we urge you to contact us first to find a solution for any concern you may have, in addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence. ``` - For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en ``` ``` - For users in the UK – the contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/ ``` Data Processing outside Europe We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe. Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented: ``` - Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time), such as the EU-U.S. Data Privacy Framework or the UK Extension thereto. ``` ``` - Transfers to territories without an adequacy decision. o We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S.). o However, in these cases: ``` ```  we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or  in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer. ``` You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. # Cookie Notice Notice last updated: March 11th, 2024 **1. Information on how we use cookies.** Our website and our emails (the “ **Site** ”) may use various cookies which allow us to distinguish you from other users of our Site, which helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. We use cookies to provide the content and functionality of our Site (strictly necessary cookies) and, with your permission, to personalize the content and advertisements that appear when you visit our Site and to analyze the traffic on the Site. In addition, we share information about your use of our Site with our third-party advertising partners and analytics providers, who may combine this information with other data that you provide to them or that they have collected when you use their services. You have the right to withdraw your consent at any time. You do not need to allow cookies to visit most of the Site. However, enabling cookies may allow for a more tailored browsing experience and is required for certain parts of the Site to work. For further information about this cookie notice, please contact us at [email protected]. Please refer to our **Privacy Policy** for more information on our privacy practices. **2. What are cookies and similar technologies?** When we refer to “cookies” in this cookie notice, we are referring to both cookies themselves (as described below) and the other similar technologies listed below. ``` - Cookies , these are small data files containing a unique identifier that are placed on your computer or mobile device when you visit a website. ``` ``` - Local storage technologies , like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications. ``` ``` - Web beacons , also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked. ``` ``` - Session-replay technologies , such as those provided by Hotjar and Log Rocket that employ software code to record users’ interactions with the Services in a manner that allows us to watch DVR-like replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls, and keystrokes/key touches during those sessions. You can learn more about Hotjar at https://www.hotjar.com/legal/policies/privacy/ and LogRocket at https://logrocket.com/privacy/. ``` Cookies and these similar technologies enable operators or websites to recognize your device and collect information from it when you interact with them and serve different purposes, like helping us understand how our Site is being used, letting you navigate between pages efficiently, remembering your preferences, improving your browsing experience, and showing you advertisements that are more relevant to you. **3. Key concepts** ``` - First-party cookies are those set by a website that is being visited by the user at the time (e.g., cookies placed by us). ``` ``` - Third-party cookies are cookies that are set by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets a cookie through that website, this would be a third- party cookie. ``` ``` - Persistent cookies are cookies that remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie. ``` ``` - Session cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted. ``` **4. Changing your cookie and advertising choices** _Blocking web beacons, pixels/images/clear gifs_ Most browsers, email clients, and devices allow you to configure your device to prevent images from loading which can block these technologies. To do this, follow the instructions in your particular browser, email client or device settings. _Session replay opt-out_ You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our Sites and Hotjar’s use of tracking cookies on other websites at https://www.hotjar.com/policies/do-not-track/. _Browser Settings_ Please note that internet browsers allow you to change your cookie settings. These settings are usually found in the ‘options’ or ‘preferences’ menu of your internet browser. In order to understand these settings, the following links may be helpful. Otherwise, you should use the ‘Help’ option in your internet browser for more details: ``` - Cookie settings in Edge - Cookie settings in Firefox ``` ``` - Cookie settings in Chrome ``` ``` - Cookie settings in Safari ``` However, please note that if you use your browser settings to block all cookies (including strictly necessary cookies), you may not be able to access all or parts of our Site. _Advertising choices._ You may be able to limit use of your information for interest-based advertising through the following settings/options/tools: ``` - Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies. ``` ``` - Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option at the following websites: ``` ``` o Google: https://adssettings.google.com/ o Facebook: https://www.facebook.com/about/ads - Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs: o Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp o Digital Advertising Alliance: optout.aboutads.info. o AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance. ``` ``` - 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 and browser from which you wish to limit the use of your information for interest-based advertising purposes. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above. **5. Your consent** We will only place optional categories of cookie (i.e., those other than the ‘Strictly necessary cookies’ described below) on your device with your prior consent. **6. Can I withhold and withdraw my consent?** If you do not wish to give consent or wish to withdraw your consent to any optional categories of cookie, you can do so via the information under ‘Changing your cookie and advertising choices’ above. Please note that disabling these cookies will affect the functionality of the Site and may prevent you from being able to access certain features on the Site. For example, we may not be able to recognise your device and you may need to log in every time you visit our Site. **7. What type of cookies do we use and why?** We use the following categories of cookies: - **Strictly necessary cookies** : These cookies are necessary for the Site to function (such as by helping to ensure that the content of a page loads quickly and effectively) and cannot be switched off in our systems. - **Analytics cookies**. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Site. They help us to know which pages are the most and least popular and see how visitors move around the Site and gather information on error messages. If you do not allow these cookies we will not know when you have visited our Site, and will not be able to monitor its performance. - **Functional cookies**. These cookies enable the Site to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, some or all of these services may not function in an optimized fashion. - **Advertising cookies**. These cookies record your visit to our Site, any pages you have visited and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. This information will also be shared with third parties for this purpose (such as our advertising technology partners). These cookies may be set through our Site by our advertising technology partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other websites. If you do not allow these cookies, you will experience less targeted advertising. **8. Retention** A cookie will exist for different periods of time depending on the purpose of the cookie. For example, a session cookie which enables the Site to operate will only exist on your device whilst you browse our Site, but other cookies will remain on your device for longer such as some functionality cookies which need to stay on your device so that the Site can recognise you when you return. **9. Keeping our cookie notice up to date** We may need to update our cookie notice from time to time (including if we decide to use cookies differently), so please check this cookie notice on a regular basis for any changes. Any changes will be updated here, or a replacement notice notified to you.