Privacy Policy

Last edited September 2021

Mindr Inc. and its affiliates (“Mindr”) are committed to respecting the privacy of your information. This Privacy Policy describes your privacy rights regarding Mindr’s collection, use,storage, sharing, and protection of your personal information and/or data. Itapplies to Mindr’s website and all related platforms, websites, applications,services, tools, modules, integrated application sites and remote services,servers, and services residing on servers owned and/or operated by thirdparties (collectively, our “Sites and Services”) where this policy isreferenced, regardless of how you access or use them. Before you use or submitany information through or in connection with the Sites and Services, pleasecarefully review this Privacy Policy. By using any part of our Sites andServices, you agree to the terms of this Privacy Policy and consent to theprocessing of your personal information as described here. IF YOU DO NOT AGREETO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SITES OR SERVICES.

Throughout this Privacy Policy,we use the term “personal information” to describe information that can beassociated with a specific person and can be used to identify that person. Wedo not consider personal information to include information that has been madeanonymous or aggregated so that it can no longer be used, whether incombination with other information or otherwise, to identify a specific person.

Information we collect whenyou use our Sites and Services.

We collect certain personallyidentifiable information that you submit through the Sites and Services, aswell as other non-personally identifiable information that we collect throughcookies and other tracking technology, as more particularly described below. Wemay collect information about the way you interact with our Sites, Services,content and advertising. This may include, but is not limited to, device ID,device type, machine ID, geo-location information, computer and connectioninformation, present and former actions taken using sites or accounts linked toany of your accounts with Mindr Sites or Services, statistics on page views,traffic to and from our Sites, IP address, ad data, and standard web loginformation, and any telephone number you provide us or from which you may callor otherwise contact us.

You are not required to providepersonal information that we request, but if you chose not to do so, in manycases we will not be able to provide you with our products and services orrespond to any queries you may have.

Information we collect fromother sources.

We may also obtain informationfrom or about you in other ways. For example, we may verify user informationwith a service provider or combine your information with additional informationwe collect from other third parties or sources, as authorized and permitted bylaw. Also, we collect the information you send to us such as correspondence,customer satisfaction surveys or customer service communications, testimonialsor user content such as photos, blogs and writings.

How We Use Information.

Our primary purpose in collectingpersonal information is to provide you with a safe, efficient and customizedexperience. We may use the information we collect to:

provide and improve the Sites andServices, including to develop new features or services, to take steps tosecure the Sites and Services, and for technical and customer support;

create your account, processtransactions and facilitate and/or customize your use of the Sites andServices;

prevent, detect and investigatepotentially prohibited or illegal activities, and enforce any of our useragreements;

customize, measure and improveour Sites and Services and advertising, including to monitor traffic throughour Sites and Services;

contact you to tell you about ourservices and those of our corporate family, service updates, targeted marketingand promotional offers based on your communication preferences;

contact you to resolve disputes,collect fees, and troubleshoot problems with your account or our sites,services, applications or tools, or for other purposes authorized by law;

contact you at any telephonenumber using auto-dialed or pre-recorded message calls or SMS or other textmessages (if applicable) for the purposes described in this Privacy Policy orour User Agreement;

for analytics, research andreporting, including to analyze and derive insights from your use of the Sitesand Services; and

compile aggregate user data thatis stored in our databases, which may be used for marketing and other purposesrelated to our Sites and Services.

Further, if you attend an eventsponsored or hosted by Mindr, you grant Mindr the right to use any photos,videos or audio taken of you or your dependents at the event for Mindr’spromotional and advertising purposes and otherwise on the Sites and Serviceswithout any compensation to you, and you waive any rights or privacy, publicityor any similar rights that you may have in connection with such photos, videoor audio.

How we share information.

We share information between oursystems and that of third parties so as to allow us to test, develop, market ordeploy new or existing Sites and Services. We make every attempt to remove useridentifiable information from the data that we collect and share with thirdparties. However, for some services information like names, address and other transaction-relateddata might be shared for the purposes of completing transactions authorized byyou. We may also disclose personal information to respond to legal requirements(for example, in response to requests by federal, state or local authorities,including tax authorities, subpoenas, court orders or other legal process) orin the good-faith belief that disclosure is legally required, enforce ourpolicies, establish or exercise our legal rights or protect anyone’s rights,property or safety. We may also disclose your information with current orfuture affiliated companies. Aggregate analytics data may be used to improveour Sites and Services, and may also be disclosed to affiliates, partners,subsidiaries, subscribers, or other third-parties for our or their benefit.

We may also share your personalinformation with:

Service providers under contractwho help with our business operations (such as fraud detection, credit cardprocessing, or bill collection).

Co-brand partners for certainsites or events. When we identify a co-brand partner for a site or event, youagree that we may share contact information and transaction data (excludingcredit or debit card numbers) with that partner. Information shared with aco-brand partner is subject to their privacy policy. We do not control theprivacy policies of co-brand partners and we encourage you to review theirprivacy policies.

Marketing partners for certainsites or events where you agree during checkout that you would like yourinformation shared for their marketing purposes. We may share your contactinformation and transaction data (excluding credit or debit card numbers) withthe marketing partner identified in checkout. Information shared with amarketing partner is subject to their privacy policy. We do not control theprivacy policies of marketing partners and we encourage you to review theirprivacy policies.

Other third parties to whom youexplicitly ask us to send your information (or about whom you are otherwiseexplicitly notified and consent to when using a specific service).

Other business entities, shouldwe plan to merge with or be acquired by that business entity or sell assets.Should such a combination occur, we will require that the new combined entityfollow this privacy policy with respect to your personal information. If yourpersonal information will be used contrary to this policy, you will receiveprior notice.

Legal Basis for ProcessingPersonal Data.

The law in some jurisdictionsrequires us to tell you about the legal grounds that we rely on to use ordisclose your personal information. To the extent those laws apply, our legalgrounds for processing such information are:

1.      HonoringContractual Commitments to You. Much of our processing of information is tomeet our contractual obligations to provide products and services to customers.

2.      LegitimateInterests. In many cases, we handle information on the grounds that it furthersour legitimate interests in commercial activities in ways that are notoverridden by the interests or fundamental rights and freedoms of the affectedindividuals, including without limit: customer service; marketing andadvertising; protecting our users, personnel and property; analyzing andimproving our business; and managing legal issues.

3.      LegalCompliance. We need to use and disclose information in certain ways to complywith our legal obligations.

4.      Consent.Where required by law, and in some other cases where legally permissible, wehandle information on the basis of consent. In such cases, you have the rightto withdraw your consent at any time.

Cookies and web beacons.

When you first use our Site andServices, Mindr may send a cookie to your computer that identifies you as aunique user. We may use session cookies (which expire once you close your webbrowser) and persistent cookies (which stay on your computer until you deletethem) to store your preferences, identify you and maintain your signed-instatus, and provide you with a more personal and interactive experience. Youcan set your browser to refuse cookies or delete persistent cookies byfollowing your browser’s help instructions. If you choose to disable cookies,some of our services may not work properly. We may also use web beacons whichare typically small graphic objects or pixels that are embedded in a web page.These web beacons allow us or our provider(s) to check that a user has viewed aweb page.

Accessing and changingpersonal information.

You can request informationregarding and change your account information by contacting Mindr. To theextent any such information is stored in your account profile, we can assistyou in changing your address, telephone number, email address, password, creditcard information, Social Security Number or Taxpayer ID (if applicable) andprivacy and communications preferences.

We may communicate with you atvarious times, with administrative emails or phone calls, about transactionsand service announcements, customer service responses and promotional emailslike special offers, newsletters and updates. You can choose to stop receivingpromotional emails at any time simply by contacting us or using an email’sunsubscribe function. You may not opt out of receiving administrative messagesor customer service responses. If you have agreed to receive marketingcommunications through check-out with our partners, you must change yourcommunication preferences with them directly.

Security and Retention.

Your information is stored on ourservers located in the United States. We treat data as an asset that must beprotected and use tools (encryption, passwords, physical security, etc.) toprotect your personal information against unauthorized access and disclosure.However, as you probably know, third parties may unlawfully intercept or accesstransmissions or private communications, and other users may abuse or misuseyour personal information that they collect from the site. Therefore, althoughwe work very hard to protect your privacy, we do not promise, and you shouldnot expect, that your personal information or private communications willalways remain private.

We retain information as long asit is necessary and relevant for our operations. In addition, we may retainpersonal information from closed accounts to comply with the law, preventfraud, collect any fees owed, resolve disputes, troubleshoot problems, assistwith any investigation, enforce our user agreements and take other actionspermitted by law.

Third Parties.

Except as otherwise expresslyincluded in this Privacy Policy, this document addresses only the use anddisclosure of information we collect from you. If you disclose your informationto others, whether they are buyers or sellers on our Site or other sitesthroughout the internet (including the ones we link to), different rules mayapply to their use or disclosure of the information you disclose to them. Mindrdoes not control the privacy policies of third parties, and you are subject tothe privacy policies of those third parties where applicable. We encourage youto ask questions before you disclose your personal information to others.

Children’s Privacy. TheSites and Services are not intended for children under the age of 18. Moreover,Mindr does not knowingly collect personal information (as defined in theChildren’s Online Privacy Protection Act) from children under the age of 13. IfMindr becomes aware that it has collected personal information from childrenunder the age of 13, Mindr will take steps to delete such information inaccordance with its legal obligations.

California Privacy Rights.

California law gives residents ofCalifornia the right under certain circumstances to request information from usregarding the manner in which we share certain categories of personalinformation (as defined by applicable California law) with third parties fortheir direct marketing purposes. We may share your personal information withthird parties.  This use and sharing ofyour personal information is not intended to permit them to use thatinformation for their own direct marketing purposes, however we encourage youto confirm their privacy policies directly. If you have agreed to receive direct marketing communications with ourpartners, you must change your communication preferences with them directly.

Privacy Policy Updates.

If we decide to change ourprivacy policy, we will post those changes on this site and notify you ofmaterial changes with an alert on the site or a communication to you. Changestake effect 30 days after they are posted to the Site. This policy was lastupdated effective September 20th, 2021.

Questions.

Should you have any questions orconcerns regarding this policy, please contact us at legal@mindrglobal.com.