TERMS AND CONDITIONS

Version 1.01

Effective March 5 2025

These Terms and Conditions (“Terms” or “Agreement”) apply to your use of the CleanSeed App. In these Terms, “Customer”, “user” or “you” means any person using CleanSeed.

PLEASE READ THIS AGREEMENT CAREFULLY. BY USING, DOWNLOADING OR ACCESSING CLEANSEED YOU ARE ENTERING INTO THIS AGREEMENT WITH US AND AGREE TO COMPLY WITH ALL OF ITS TERMS. THIS IS A LEGALLY BINDING AGREEMENT. IF YOU DO NOT AGREE TO THIS AGREEMENT, YOU MAY NOT USE CLEANSEED.

SECTION 12 HAS AN ARBITRATION PROVISION AND WAIVER OF CLASS ACTION RIGHTS. BY AGREEING TO THESE TERMS, YOU AGREE TO SUCH PROVISIONS.

1. Registration

In order to use CleanSeed, you must create an account and register with us (“Account”). You represent and warrant that: (i) you are of legal age to form a binding contract; (ii) you will provide us with accurate, current and complete registration information; (iii) your registration and your use of CleanSeed is not prohibited by law; and (iv) your registration uses an actual email address owned and operated by you. You are responsible for your own registration and all use of CleanSeed under it. You shall not share your password nor use CleanSeed through using the registration of any third party. Your registration is personal to you and is not transferable by you to any third party without our prior written consent.

2. Minors

Use of CleanSeed is limited to users who are at least 18 years old, although if you are 13 or more, but not yet 18, you may use CleanSeed if your parent or legal guardian agrees to this Agreement on your behalf. Use of the Service is not directed to users under the age of 13. If you are under the age of 13, you are not permitted to use CleanSeed, register as a Customer or send personal information to CleanSeed.

3. Proprietary Materials and Ownership

All the text, images, sound, music, marks, logos, compilations (meaning the collection, arrangement and assembly of information) and other content on CleanSeed (collectively, the “Content”), and all software embodied or used in CleanSeed (“Software”) is proprietary to us or to third parties and are protected by copyright and other intellectual property laws. Except as otherwise expressly permitted by these Terms, any use, exploitation, copying, making derivative works, transmitting, posting, linking, deep linking, redistribution, sale, decompilation, modification, reverse engineering, translation or disassembly of the Software or CleanSeed Content is prohibited.

4. License to Use the Service

We authorize you to access, view and use CleanSeed Content and Software (collectively, “Property”) solely to the extent necessary for you to use the Service. You may not remove any copyright, trademark or other proprietary notices that have been placed on the Property. Except as expressly permitted by these Terms, any modification, reproduction, redistribution, republication, uploading, posting, transmitting, distributing or otherwise exploiting the Property in any way is strictly prohibited.

You agree, and represent and warrant, that your use of the Service and the Property will be consistent with the foregoing license, covenants and restrictions and will neither infringe nor violate the rights of any other party or breach any contract or legal duty to any other parties. In addition, you agree that you will comply with all applicable laws, regulations and ordinances relating to the Service, the Property or your use of them, and that in using the Service you will not engage in any conduct that restricts or inhibits any other person from using or enjoying the Service.

You are responsible for obtaining and maintaining the computer, smartphone and other equipment you use to access the Service, and for paying for such equipment and any telecommunications charges. We are not liable for any loss or damage you suffer arising from damage to equipment used in connection with use of the Service.

5. Account Use; Award Redemption

5.1 – An account will be opened for you upon registration within the CleanSeed app. Your account status can be checked at any time from within the CleanSeed app.

5.2 – Individuals may only open one CleanSeed account. Attempts by a single person to open multiple accounts may result in suspension of all their accounts and awards.

5.3 – Award redemptions must be made within the CleanSeed app. You may be asked to confirm information about yourself and/or your household in order to redeem awards.

5.4 – CleanSeed coins, spins, sweepstakes entries, and other awards will be rewarded as described within the app.

5.5 – Receipt images uploaded or otherwise provided through the app must legibly include the retailer name, all individual items purchased and their prices, the total amount paid and transaction date. If any of this receipt information is illegible or missing, your receipt may not earn awards.

5.6 – Receipt images must be uploaded within 14 days of the in-store transaction to be eligible for awards. The same receipt may not be uploaded more than once. Up to 3 receipts per retailer per transaction date may be eligible for awards. You may only submit real, unmodified receipts for shopping trips that you were part of.

5.7 – Receipts that earn awards are limited to receipts from specified eligible retailers and/or stores as detailed within the CleanSeed app; such eligible retailers or stores may be changed from time to time in our sole discretion.

5.8 – We reserve the right to change app functionality and Award redemption options

5.9 – We may suspend or eliminate your CleanSeed Account after three consecutive months of not uploading receipts or sharing data related to purchases.

5.10 – We may suspend or eliminate your CleanSeed Account if fraudulent activity is suspected and/or if receipts submitted are not the direct result of your shopping activity. Specifically, you may not submit receipts resulting from shopping trips that you were not a part of or that have been modified in any way.

6. Sweepstakes, Contests & Promotions

Any sweepstakes, contests or other promotions (collectively, “Promotions”) that may be offered via the Service may be governed by a separate set of rules that may have eligibility requirements, such as certain age or geographic area restrictions, terms and conditions governing the Promotions, use of submissions, and disclosures about how your personal information may be used. It is your responsibility to read these rules to determine whether or not you want to and are eligible to participate, register and/or enter, and to determine the applicable terms and conditions of the Promotion. By participating in a Promotion, you will be subject to those official rules, and you agree to comply with and abide by such rules.

7. Third Party Websites

CleanSeed may contain links to third-party websites. The linked sites are not under our control, and we are not responsible for the contents of any linked site. We provide these links as a convenience only, and a link does not imply our endorsement of, sponsorship of, or affiliation with the linked site.

8. Feedback Submitted to CleanSeed

We are pleased to hear from you and welcome your comments about the Service. If you submit ideas or suggestions for the Service (“Service Comments”), the Service Comments will be deemed, and will remain, our sole property. None of the Service Comments will be subject to any obligation of confidence and we will not be liable for any use or disclosure of any Service Comments.

9. Warranty Exclusions and Limitations of Liability

We do not warrant that CleanSeed will operate error-free or without downtime. We may pause or interrupt the Service at any time, and users should expect periodic downtime for updates to the Service. Because we do not control the security of the Internet, or other networks you use to access CleanSeed, we are not responsible for the security of information that you choose to share with us while it is being transmitted. Additionally, we are not responsible for any data lost during transmission. Your sole and exclusive remedy, and our sole and exclusive liability, for any breach of this Agreement or for any other cause of action shall be (at our option) to remedy the failure or to give you a credit for the amounts that may be owed to you as an award.

WE EXPRESSLY DISCLAIM ANY AND ALL WARRANTIES, WHETHER EXPRESS OR IMPLIED, INCLUDING: (i) ALL WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NONINFRINGEMENT, AND ANY AND ALL WARRANTIES ARISING FROM COURSE OF DEALING AND USAGE OF TRADE; (ii) THAT THE SERVICES, INCENTIVES AND THE PROPERTY WILL MEET YOUR REQUIREMENTS, WILL ALWAYS BE AVAILABLE, ACCESSIBLE, UNINTERRUPTED, TIMELY, SECURE OR OPERATE WITHOUT ERROR, (iii) AS TO THE RESULTS THAT MAY BE OBTAINED FROM THE OPERATION, USE OR OTHER EXPLOITATION OF THE SERVICES OR THE PROPERTY, AND (iv) AS TO THE ACCURACY OR RELIABILITY OF ANY INFORMATION OBTAINED FROM THE SERVICES OR THE PROPERTY. No advice or information, whether oral or written, obtained by you from or through the Service will create any warranty not expressly stated herein.

UNDER NO CIRCUMSTANCES WILL YOU BE ENTITLED TO RECOVER FROM US ANY INCIDENTAL, CONSEQUENTIAL, INDIRECT, PUNITIVE OR SPECIAL DAMAGES (INCLUDING DAMAGES FOR LOSS OF BUSINESS, LOSS OF PROFITS OR LOSS OF USE), WHETHER BASED ON CONTRACT, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY OR OTHERWISE ARISING FROM OR RELATING TO THE SERVICES OR THE PROPERTY, EVEN IF WE HAVE BEEN INFORMED OR SHOULD HAVE KNOWN OF THE POSSIBILITY OF SUCH DAMAGES.

OUR MAXIMUM LIABILITY TO YOU FOR ANY DAMAGES OR LIABILITY ARISING IN CONNECTION WITH THE SERVICE, WHETHER ARISING IN CONTRACT, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY OR OTHERWISE, SHALL BE A CREDIT OF ANY AMOUNT OWED. SOME JURISDICTIONS DO NOT ALLOW THE LIMITATION OR EXCLUSION OF WARRANTIES OR OF LIABILITY FOR CERTAIN TYPES OF DAMAGES, SO SOME OF THE ABOVE LIMITATIONS OR EXCLUSIONS MAY NOT APPLY TO YOU.

10. Digital Millennium Copyright Act

We comply with the provisions of the Digital Millennium Copyright Act applicable to internet service providers (17 U.S.C. §512, as amended).

Any notice alleging that materials hosted by or distributed through the Services infringe intellectual property rights must include the following information:

an electronic or physical signature of the person authorized to act on behalf of the owner of the copyright or other right being infringed;
a description of the copyrighted work or other intellectual property that you claim has been infringed;
a description of the material that you claim is infringing and where it is located on the Services;
your address, telephone number, and email address;
a statement by you that you have a good faith belief that the use of the materials on the Services of which you are complaining is not authorized by the copyright owner, its agent, or the law; and
a statement by you that the above information in your notice is accurate and that, under penalty of perjury, you are the copyright or intellectual property owner or authorized to act on the copyright or intellectual property owner’s behalf.

Counter Notices

If material that you have posted to the Services has been removed or disabled, you may file a counter notice pursuant to 17 U.S.C. §512 (g). To be effective, the counter notice must be a written communication sent to the designated agent address listed above that includes the following:

a physical or electronic signature of the subscriber;
identification of the material that has been removed or to which access has been disabled and the location at which the material appeared before it was removed or access to it was disabled;
a statement under penalty of perjury that you have a good faith belief that the material was removed or disabled as a result of mistake or misidentification of the material to be removed or disabled; and
your name, address, and telephone number, and a statement that you consent to the jurisdiction of Federal District Court for the judicial district in which the address is located or, if your address is outside of the United States, for any judicial district in which Company may be found, and that you will accept service of process from the person who provided notification under subsection 17 U.S.C. §512 (c)(1)(C) or an agent of such person.

11. Privacy Policy

We take user privacy very seriously and operate the Service under the Privacy Policy. Please read this policy carefully and note that it may be updated from time to time. By signing up for an Account or using the CleanSeed app, you agree that we may collect, use and disclose your information as described in the Privacy Policy.

12. Arbitration

This Agreement represents the entire agreement of the parties as to its subject matter, and supersedes all prior written and oral representations and discussions between the parties. If a matter arises that cannot be resolved between us with reasonable effort, you agree that all such disagreements or disputes that in any way involves the Service or this Agreement shall be resolved exclusively by final and binding administration by the American Arbitration Association (“AAA”), and will be conducted before a single arbiter pursuant to the applicable Rules and Procedures established by the AAA. You agree that the arbitration shall be held in New York, or at any other location that is mutually agreed upon by us. You agree that the arbiter will apply the laws of the State of New York consistent with the Federal Arbitration Act, and will honor and agree to all applicable statutes of limitation. You agree that, unless prohibited by law, there shall be no authority for any claims to be arbitrated on a class or representative basis, and arbitration only will decide a dispute between us. If any part of this Arbitration clause is later deemed invalid as a matter of law, then the remaining portions of this section shall remain in effect, with the exception of the class language referenced herein, in such case this entire section shall be deemed invalid.

13. Suspension; Modifications and Termination

We reserve the right to suspend your Account and/or access to the Service at any time. We reserve the right to terminate or modify this Agreement, terminate the Service or modify any features or aspects of the Service, or modify its policies at any time. Any such termination will not affect any awards you have earned prior to termination. If you earn an award or use the Service, you shall be bound by the version of the Agreement in effect at the time of your award. If we make changes that materially affect your use of the Service, we will post a notice of the change on or within CleanSeed. You are under an obligation to review the current version of this Agreement and other published policies before using the Service. Sections 2, 3, 5, 7-12, 14 and 15, any accrued rights and remedies hereunder, and any other provisions that by their nature require survival in order to be effective, shall survive the termination or expiration of this Agreement.

14. Force Majeure

In no event shall we be liable for any failure to comply with this Agreement to the extent that such failure arises from factors outside our reasonable control.

15. Third Party Beneficiaries

The provisions of this Agreement are entered into for the benefit of us and our third party licensors and each of them shall have the right to enforce such provisions of this Agreement directly against you to protect their interests. Except as stated in the preceding sentence, there shall be no third party beneficiaries to this Agreement.

16. Miscellaneous Provisions.

No delay or omission by us in exercising any of our rights related to noncompliance or default by you with respect to any of the terms and conditions of this Agreement will impair any such right or be construed to be a waiver thereof. Any waiver by us of any of the covenants, conditions or agreements to be performed by you will not be construed to be a waiver of any succeeding breach thereof or of any other covenant, condition or agreement herein. If any provision of this Agreement is found by a court of competent jurisdiction to be invalid or unenforceable, then this Agreement will remain in full force and effect and will be reformed to be valid and enforceable while reflecting the intent of the parties to the greatest extent permitted by law. Except as otherwise expressly provided herein, this Agreement sets forth the entire agreement between us regarding its subject matter, and supersedes all prior promises, agreements or representations, whether written or oral, regarding such subject matter. You shall not assign or transfer this Agreement or any right or obligation hereunder to any third party.

17. Choice of Law

Any disputes arising out of or related to this Agreement and/or your use of CleanSeed shall be governed by the laws of the State of New York, without regard to its choice of law rules and without regard to conflicts of laws principles (except that the Arbitration provisions in Section 12 shall be governed by the Federal Arbitration Act).

Privacy Policy

Version 1.01

Effective March 5, 2025

Introduction

This Privacy Policy applies to your use of the CleanSeed App. This Privacy Policy describes how we collect, use, share and secure the personal information we may collect when you use the Platforms. It also describes your choices regarding use, access, deletion, and correction of your personal information. We will review the notice regularly and publish updates as required by law, statute and/or regulation where your rights will be no less than what is required by law, statute, and/or regulation.

When you use CleanSeed, we collect information related to your purchase and consumer behavior to the extent you choose to share it with us. We use this information as part of the products and services we make available to our clients (such as agencies, brands, manufacturers and retailers) to help them better understand consumer behavior and the markets in which they do business.

This Policy does not cover our clients’ use of your personal information outside of the products and services we may provide them. We are not responsible for the privacy practices of our clients. Further, you may elect to participate in surveys, contests, sweepstakes, or other programs that may be offered or sponsored by third parties. Any such participation will be subject to the privacy statements of those relevant third parties.

If you are a California consumer, please see the section of this Privacy Policy called “For California Consumers” for more information about your privacy rights.

PERSONAL INFORMATION WE MAY COLLECT AND HOW WE MAY USE IT

We may collect your information in several ways, including the following:

Information You Provide Us Directly. We collect personal information you choose to provide us directly, for example when you share purchase receipts with us or when you answer survey questions.
Information We May Collect Through Automated Technologies. We may collect personal information through the use of cookies, tags, web beacons and other technologies. We may also collect unique device identifiers and may collect geolocation information if we have the appropriate legal basis to do so.
Information We May Receive from Other Parties. We may combine the information we receive from you with information we receive from other sources.

To the extent required by applicable law, we will only collect, use, and share your personal information where we are satisfied that we have an appropriate legal basis to do so. The chart below summarizes when we collect personal information, the types of personal information we collect and how we use the personal information. We also may use the information in other ways for which we provide specific notice at the time of collection.

When We Collect Personal Information

The Types of Personal Information We Collect

How We Use Personal Information

The Legal Basis for Using Personal Information

Personal information we collect by cookies or similar technologies when you visit our Platforms.

We may collect information related to your use of our websites including where you came from, login details, pages you looked at, duration of your visit, geographic location, and/or the links you click. Technical information collected may include your browser type and operating system, device information, and your Internet Protocol (“IP”) address.

We may use this information to tailor our websites for you, that is to show you recommendations, marketing, or content based on your profile and interests. This data also allows our websites to function properly, that is to ensure the proper display of content, create and remember your account login details, improve our site and keep our site secure and safe and to protect against fraud. This data may also be used to show online ads and content on social media platforms or other sites. You can change your cookie consent preferences at any time by following the Do Not Sell or Share My Personal Information link at numerator.com. Otherwise, you can opt out of targeted advertising by using the function available on our websites (where applicable), or in your browser settings. For opting out of targeted advertising on social media platforms, please visit the relevant social media platform to explore the options they may provide.

Our legal basis to use this information includes (1) your consent when it is required under applicable law and (2) our legitimate interests, including to improve our sites and services, to better engage with you, and to secure our sites.

Personal Information we collect when you use our websites and apps (“Platforms”).

When you use our Platforms (for example, by uploading your purchase-related information or answering survey questions), we may ask you to provide:

· Identifiers, such as first and last name, mailing address, email address, and date of birth;

· Research information, such as information about your activities, behaviors, preferences, and interests, and any content you produce for a research project (e.g., photos, videos, opinions, comments, and project diaries);

· Geolocation data;

· Financial information, such as hashed credit card information, purchase history from receipts, and electronic receipts;

· Demographic information, such as, education, occupation, income, nationality, citizenship, country of residence, ethnicity, gender, and family information;

· Health-related information, such as physical activities; Application or device usage data;

· Social media data (where you use your social media login or share this personal data with us); and

· Your grocery, drugstore, or other store loyalty card numbers.

Only if you have provided us with your consent to do so, we may obtain access to your email account to collect information from your email related to your digital shopping history. If you consent to this process, we may automatically collect information from your emails about purchase transactions including receipts, details of what was purchased, the merchant from which the goods/services were purchased, the amount spent and the date of the purchase. Consent for this process is controlled by you. You may withdraw your consent to us at any time by updating your consent settings.

Only if you have provided us with your consent to do so, we may obtain access to one or more of your merchant accounts (e.g., Amazon.com) to collect information from your account related to your digital shopping history. If you consent to this process, we may automatically collect information from your account about purchase transactions including receipts, details of what was purchased, the merchant from which the goods/services were purchased, the amount spent and the date of the purchase. Consent for this process is controlled by you. You may withdraw your consent to us at any time by updating your consent settings.

We use the information we collect to manage your account(s). For example, we use the information you provide us and the purchase information you have chosen to provide us with, or otherwise authorized us to collect, in order to track, process, post and fulfill rewards you earn and to provide customer service. In addition, we may use this information to keep you informed of new features and product developments as well as to provide more relevant offers to you.

We also may use this information to provide clients with anonymous market research reports and consumer insights. For example, “What percentage of Females in the Midwest buy Brand X products?”

We also may share this information in other ways as described below under the heading “How We May Share Your Information With Third Parties”

Our legal basis for using this information includes (1) your consent when it is required under applicable law and (2) our legitimate interests, including to improve our sites and services, to better engage with you, and to secure our Platforms and services; and (3) performance of a contract so you can receive rewards related to your use of our Platforms

Personal information we collect and use when you subscribe to receiving our marketing communications.

We collect first and last name, organization name, gender, email address, mailing address, username and password, preferences, and other information you have chosen to share with us about yourself.

We may use this information to send you marketing communications (where you have asked us to) which may be tailored to you based on your preferences and the personal data we know about you.

Our legal basis for using this information includes (1) our legitimate interests which include to improve our sites and services and better engage with you and (2) your consent (if required by law) to receive marketing communications from us.

Personal information we collect and use when you contact our support team

We may collect first and last name, email address, phone number, date of birth, information about your activities and interests, and other information you have shared with us about yourself in relation to your inquiry.

We use this information to communicate with you about your use of our services and may use it to verify your identity for compliance reasons

Our lawful basis to use this information includes (1) performance of contract to provide you with our service (2) our legitimate interests which include to improve our services, to better engage with you and to secure our sites.

Personal information we collect from third parties

We may collect demographic information such as education, occupation, income, nationality, citizenship, country of residence, ethnicity, gender, and family information and other publicly available information (for example, electoral register information about you from third party companies that specialize in collecting this type of information).

We may combine this information about you with other information about you that we collect as described above. We use this information to provide our clients with anonymous market research reports and consumer insights.

We also may share this information in other ways as described below under the heading “How We May Share Your Information With Third Parties” .

Our legal basis for using this information includes (1) your consent when it is required under applicable law and (2) our legitimate interests, including to improve our sites and services, to better engage with you, and to secure our sites, apps, and services; and (3) performance of contract so you can receive rewards related to your use of our app.

COOKIES AND SIMILAR TECHNOLOGIES

When you visit our websites or click on a banner advertisement, we and our partners, affiliates, or analytics or service providers may obtain certain information by automated means, such as cookies or similar technologies, that helps us improve the quality of our sites and services, and the online experience of our visitors and users. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies.

We use browser session cookies, which are temporary cookies that are erased from your device’s memory when you close your Internet browser or turn your computer off, and persistent cookies, which are stored on your device until they expire, unless you delete them before that time. We group browser cookies on our site into three categories, which you can manage:

Required cookies: These cookies are necessary to enable the basic features of our site to function, such as allowing images to load or allowing you to select your cookie preferences.
Functional cookies: These cookies allow us to analyze your use of our site to evaluate and improve our performance. They may also be used to provide a better customer experience on our site. For example, remembering your log-in details or providing us information about how our site is used.
Advertising cookies: These cookies may be used to share data with advertisers so that the ads you see are more relevant to you, allow you to share certain pages with social networks, or allow you to post comments on our site.

If you are located in the UK or the EU, we only use cookies and similar technologies that are not strictly necessary for our site to function if you give your consent. If you give your consent, you can change your consent preferences at any time by following the Do Not Sell or Share My Personal Information link at numerator.com.

HOW WE MAY SHARE PERSONAL INFORMATION WITH THIRD PARTIES

We may share aggregated and anonymized insights and reports about consumer and purchase behavior with clients, affiliates, partners, or other third parties for research, marketing, analysis and other purposes.

From time to time, we may share personal information related to your purchase or receipt information and/or survey responses with clients or other third parties for advertising, marketing research or analytics purposes (e.g., to help them better understand consumer preferences or segments, or serve more relevant advertising or measure advertising effectiveness) or to help us better understand the accuracy of such information or responses. In these cases, we limit the types of identifiers we may share (e.g., mobile ad ids, hashed emails, etc.) and restrict the ways in which third parties may use this data. We will only engage in this type of sharing if we have obtained your consent to do so or if we believe we have another appropriate legal basis to do so or are otherwise permitted to do so under applicable law.

We may share information we obtain with third party service providers or data processors that provide services on our behalf, such as data analytics and IT services. These third parties have agreed to confidentiality restrictions and have agreed to use any personal information we share with them, or which they collect on our behalf, solely for the purpose of providing the contracted service to us.

We may share information with government organizations and agencies, law enforcement and regulators (1) to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies; (2) to establish, exercise or defend our legal rights; (3) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; or (4) in connection with an investigation of suspected or actual illegal activity.

If, in the future, we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may disclose/transfer the information we have collected from you to the acquiring company.

In addition to the above, we may share personal information about you with others to the extent you consent to such sharing.

TRANSFERRING PERSONAL INFORMATION GLOBALLY

International data transfers

We may transfer to and store the personal information we collect in countries other than the country in which the personal information was originally collected in accordance with applicable law. Those countries may not have the same data protection laws as the country in which the personal information was provided. When we transfer personal information to recipients in other countries, we will protect the personal information as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for the transfer of personal information..

If you are located in the European Economic Area (“EEA”) or the UK we comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries located outside the EEA or the UK respectively. In all such cases, we will only transfer your personal information if:

The country to which the personal information will be transferred has been granted a European Commission or Information Commissioner’s Office adequacy decision;
We have put in place appropriate safeguards in respect of the transfer, for example EU Standard Contractual Clauses; or
One or more of the derogations for specific situations provided by law applies, for example because the transfer of personal information is necessary for us to establish, exercise or defend against legal claims.

SECURITY AND RETENTION OF YOUR PERSONAL INFORMATION

We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized access, destruction, loss, alteration, disclosure and use.

Subject to applicable law, we will retain your information for as long as your account is active, as needed to provide you services and to fulfill the purposes for which the data was collected, or otherwise for the time period reasonably necessary to achieve the purposes described in this Privacy Policy or any other notice provided at the time of collection. We may keep data longer if we have a legal obligation to keep it or to maintain necessary records for legal, financial, compliance, or other reporting obligations, in accordance with applicable statutes of limitation and records retention requirements under applicable law, and to enforce our rights and agreements.

DIRECT MARKETING

How we use personal information to keep you up to date with our services

We may use personal information to let you know about our services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communications channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activities with you.

We also work with third parties, such as promotional partners and others with whom we have marketing or other relationships, to tell you about products and services that they believe would be of interest to you.

At any time you can update or correct your personal profile, or change your preferences for the way in which you would like us to communicate with you. You can ask us to stop sending you email marketing at any time by following the unsubscribe link you will find on all the email marketing messages we send you. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g. email).

LINKS TO THIRD-PARTY SITES AND SERVICES

For your convenience and information, or in connection with your use of our Platforms, our Platforms may provide links to or plug-ins of non-Numerator websites, apps and services that may be operated by companies not affiliated with us (including but not limited to bulletin boards, chat rooms and other online forums). The privacy practices of the relevant third parties, including details on the information they may collect about you, is subject to the privacy statements of these parties, which we strongly suggest you review. We are not responsible for the privacy practices of any non-Numerator websites, apps or services.

CHILDREN’S INFORMATION

None of our products or services are directed to or intended for use or purchase by children. Accordingly, we do not knowingly solicit or collect, either online or offline, information from children under the age of 13. If you believe that we might have any information from a child under age 13.

CHANGES TO THIS PRIVACY POLICY

Please note that this Privacy Policy may change from time to time so please review it frequently. We will post any Privacy Policy changes on this page.

ACCESS, DELETION, AND/OR CORRECTION OF YOUR PERSONAL INFORMATION

Upon request, we will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by logging into your account and contacting us through our support channels. We will respond to your request within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, verify your identity, or may need to retain your personal information in order to continue providing a service. You can unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails. You also may update certain of your account details and settings by logging into your account on the Services.

If you are a California resident, please see the California Consumer Privacy Statement section of this Privacy Policy for more information about your privacy rights.

If you are a Colorado, Connecticut, Utah, or Virginia resident, subject to applicable law, you may have the right to: (1) request access to, or correction or deletion of, your personal information; or (2) opt out of the processing of your personal information for purposes of targeted advertising, or the sale of your personal information.

LEGAL RIGHTS AVAILABLE TO EU AND UK DATA SUBJECTS

Subject to applicable law, you may have the right to:

Request confirmation of and access to the personal information we maintain about you;
Request rectification of your personal information if it is inaccurate or outdated;
Request erasure of your personal information in certain circumstances specified by applicable law;
Request the restriction of the processing of your personal information;
Object to our processing of your personal information on grounds relating to your particular situation;
Receive a copy of your personal information in a structured, commonly used, machine readable format, and, in some cases, have that personal information transmitted to another organization; and
Where you have given us consent to process your personal information, withdraw your consent at any time.

If you consider that we have processed your personal information in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you also may lodge a complaint with the data protection supervisory authority in your country.

If you have any questions, concerns or complaints regarding our compliance with this Policy, the information we hold about you or if you wish to exercise your rights, we encourage you to first contact us. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.

FOR CALIFORNIA CONSUMERS – CALIFORNIA CONSUMER PRIVACY STATEMENT

Pursuant to the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (the “CCPA”), this section provides additional information to California consumers whose personal information we may collect. This section supplements the information provided elsewhere in the Privacy Policy and applies solely to California consumers. This section does not apply to our personnel or job applicants.

This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the CCPA.

Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement) the following categories of personal information about you:

Identifiers: including real name, postal address, unique personal identifier (such as cookies, mobile ad identifiers and similar technology), internet protocol address, email address, and other similar identifiers
Protected Classifications: characteristics of protected classifications under California or federal law
Commercial Information: commercial information, including products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
Geolocation Data
Sensory Information: photos and videos, when you choose to share them with us
Employment Information: professional or employment-related information that you choose to share with us
Additional Data Subject to Cal. Civ. Code § 1798.80: such as physical characteristics or description, education
Inferences: inferences drawn from any of the information identified above

We may use, and may have used during the previous 12 months, these categories of personal information for the purposes described in our Privacy Policy (under the heading “Personal Information We May Collect And How We May Use It”), including for the following business purposes that are specified in the CCPA:

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
Helping to ensure security and integrity, detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
Debugging to identify and repair errors that impair existing intended functionality
Undertaking internal research for technological development and demonstration
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
Managing our relationships with current or prospective partners, corporate customers and vendors and other business partner personnel.

We do not collect or process sensitive personal information for purposes of inferring characteristics about consumers.

To the extent we process de-identified information, we will maintain and use the information in de-identified form and will not attempt to reidentify the information unless permitted by applicable law.

Sources of Personal Information

During the 12-month period prior to the last Updated date of this California Consumer Privacy Statement, we may have obtained personal information about you from the following categories of sources:

Directly from you, such as when you upload your purchase-related information, photos, and videos, or when you answer survey questions
Your devices, such as when you visit our Platforms
Service providers, contractors, and other vendors who provide services on our behalf
Operating systems and platforms
Data brokers

Sale or Sharing of Personal Information

As further described in our Privacy Policy under the heading “How We May Share Personal Information With Third Parties”, from time to time (including during the 12-month period prior to the Last Modified date of this California Consumer Privacy Statement), we may disclose each of the above categories of personal information to third parties.

Under the CCPA, the terms “sell” and “share” are broadly defined to include several different kinds of data disclosures with third parties for monetary or other valuable consideration. Under these definitions, we may sell or share your personal information in exchange for monetary or non-monetary consideration in the following ways:

(a) We may allow certain third party online advertising services to collect your personal information via automated technologies on our sites or services. We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the 12-month period prior to the Last Modified date of this California Consumer Privacy Statement) the following categories of personal information about you to online advertising services: Identifiers, Commercial Information, Online Activity and/or Inferences; and

(b) We may disclose personal information related to your purchase or receipt information and/or survey responses to clients or third parties for advertising, marketing research or analytics purposes (e.g., to help them better understand consumer preferences or segments or serve more relevant advertising). In these cases, we limit the types of identifiers we may share (e.g., mobile ad ids) and restrict the ways in which third parties may use this data. We will only engage in this type of sharing if we have obtained your consent to do so or if we are otherwise permitted to do so under applicable law. Depending on what you provide consent for, or as otherwise permitted by applicable law, we may share each of the above listed categories of personal information with clients or other third parties.

You have the right to opt out of these disclosures of your information, as detailed below.

We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.

Disclosure of Personal Information

During the 12-month period prior to the Last Modified date of this California Consumer Privacy Statement, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

Category of Personal Information

Categories of Third Parties

Identifiers

· Our affiliates and subsidiaries