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CollabScale Privacy Policy and Cookie Policy (KC 9-15-21 v1.1).docx
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CollabScale Privacy Policy and Cookie Policy

CollabScale, LLC (“CollabScale”) and (the “Site”) have established this Privacy Policy and Cookie Policy (collectively, the “Policy”), as amended from time to time, to govern how CollabScale collects, processes and/or uses information that CollabScale requests, receives and/or otherwise collects via the Site and/or any other CollabScale site, mobile application, or any other platform of any kind whether in existence now or hereinafter created (collectively referred to as the “Platform”). CollabScale is hereby providing this Policy to inform Users how CollabScale collects, processes, uses, shares and secures the personal information Users provide and to describe Users’ choices regarding use, access, and correction of their personal information. For purposes of this Policy, “Personal Information” shall mean and include any information relating or pertaining to an identified or identifiable natural person. This Policy does not apply to information that CollabScale collects through other channels, such as information collected offline, from other websites or from emails sent by Users to CollabScale, unless CollabScale expressly states at the time of collection that this Policy applies.

  1. Information CollabScale Collects.

To provide the CollabScale products and services and to otherwise operate the Platform, CollabScale must process information about Users. The type of information that CollabScale collects depends on how Users use and interact with the Platform, as set forth in this Policy.

  1. Information Users Provide to CollabScale.

When Users use the Platform and/or register for a Profile, Users provide personal information to CollabScale, which is collected for processing and use in accordance with this Policy. Because CollabScale changes its offerings and features from time to time, the personal information requested from Users may also change. Some of the situations in which Users will be requested to provide personal information are as follows:

  1. Creating User Profile and including public information and preferences
  2. Creating and posting Content and/or Submissions on the Platform
  3. Signing up for email notifications
  4. Completing forms related to available products and/or services on the Platform
  5. Sending messages through the Platform
  6. Contacting CollabScale for any type of technical support or customer service

Depending on how Users interact with the Platform, the personal information collected may vary. For example, creating a User Profile may only require an email address and password but completing a form related to receiving certain products or services may require Users to provide additional or different information, such as their name, phone number, and/or mailing address. CollabScale collects and stores certain information associated with actions that Users take, such as the time and duration of Users’ activity on the Platform and other information about Users’ behavior on the Platform. Because much of this information is necessary for CollabScale to provide Users with CollabScale’s products and services, if a User chooses to not share this information, they may not be able to use some features on the CollabScale platform.

If a User connects to the Platform using Facebook, Google+, or another social networking site (each, a “Social Networking Site”), CollabScale will receive information that the User has shared with and authorized the Social Networking Site to share with CollabScale, such as public profile information, birthday, current city, employment information, education information, and email address. When CollabScale receives this information, it utilizes this information for User Profile creation and to otherwise facilitate the User’s ability to use and interact with the Platform. This information is considered personal information and is subject to this Policy. Any information CollabScale collects from User’s Social Networking Site accounts will vary based on the privacy settings the User has set with the Social Networking Site. Accordingly, Users should consult the Social Networking Site’s privacy and data practices for more information. Users have the ability to disconnect their Social Networking Site account from a CollabScale Profile by changing the privacy settings in their Social Networking Site account. If a User comes to the Platform through a Social Networking Site, from other websites, or with devices that enable third parties to collect information from or about the User, such third parties will receive information about the User subject to the Social Networking Site’s and/or third parties’ respective privacy policies.

When User’s submit personal information to any third party and are informed at the time of collection that their information may be shared with CollabScale, CollabScale may collect that information for lawful marketing purposes.

Categories of personal information collected by CollabScale may include, but are not limited to, (i) security & Profile log-in information, such as login events, password changes, e-mail changes and mobile device information; (ii) Platform activity, such as specific pages the User viewed and interacted with on the Platform; (iii) marketing activity, such as marketing programs Users have joined, content Users have downloaded, and etc.; (iv) User feedback, such as feedback Users have provided to CollabScale via email, the Site, and/or other channels; (v) Content users have created, posted or submitted in any way on the Platform. CollabScale may also collect additional personal and demographic information that Users may choose to provide, as set forth below.

  1. Information CollabScale Collects Automatically.

When a User uses the Platform, their device is automatically providing information to CollabScale, so Collabscale can respond and customize responses to the User. The type of information CollabScale collects by automated means generally includes technical information about a User’s computer, such as their IP address or other device identifier, the type of device being used, and the operating system version. The information CollabScale collects also may include usage information and statistics about User interaction with the Platform. That information may include the URLs of the web pages that the User visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, location data (if the User has enabled access to their location on their mobile device), and other information about how the User used the Platform.

  1. Automated Data CollabScale Collects.

  1. Cookies. Technology known as cookies, web beacons, locally shared objects (sometimes called “flash cookies”), mobile identifiers and similar technologies (collectively referred to as “Cookies”) are collected, stored and used by CollabScale and its partners, which includes but is not limited to advertising, marketing and analytics providers (collectively referred to as the “Ad Partners”). CollabScale and its Ad Partners use Cookies to remember Users’ settings and for authentication and analytics. These technologies may be used to analyze trends, administer the Platform, track Users’ interactions with the Platform and to gather demographic information about CollabScale’s collective User base. CollabScale’s Ad Partners may also use Cookies to deliver advertisements to CollabScale Users. The User is able to control the use of Cookies at the individual browser level, but if a User chooses to disable Cookies, it may limit their ability to use certain features or functions on the Platform and related products and services.         
  1. Log File Information. Log file information is automatically reported by a User’s browser or mobile application each time the User accesses the Platform. For example, when a User accesses any part of the Platform, CollabScale servers will automatically record certain information that the User’s web browser sends when the User visits the Platform. These server logs include information such as the User’s web request, Internet Protocol (“IP”) address, browser type, referring/exit pages and URLs, number of clicks, domain names, landing pages, and pages viewed.

  1. Device Information. CollabScale collects information about the device a User is using to access the Platform, including but not limited to the type of device, operating system, settings, unique device identifiers, and IP address. Whether CollabScale collects some or all of this information often depends on what type of device the User using and its settings. Certain types of information are available depending on whether the User is using a Mac or a PC or an iPhone or Android phone. CollabScale collects the device type and any other information the User chooses to provide, such as username, geolocation, or email address. CollabScale also uses mobile analytics software to allow CollabScale to have a better understanding of and make necessary improvements to the functionality of its mobile software on phones. This software records information such as how often Users use the Platform on phones, the events that occur within a User’s use of the Platform on phones, aggregated usage, performance data, and from where any Platform applications were downloaded. CollabScale does not link the information it stores within the analytics software to any personally identifiable information Users submit within the Platform, including but not limited to mobile applications.        
  1. How CollabScale Uses Information.

CollabScale uses the information it collects to provide products and services to Users. In order for CollabScale to best provide these products and services (and assist in it being feasible to do so), it is essential that CollabScale collects and uses the information as set forth in this Policy. 

CollabScale processes User information in accordance with its Terms of Use and/or in accordance with alternative legal bases for collecting and using information, such as User consent, fulfilling legal requirements, and etc. CollabScale also may use personal information to provide Users with personalized content, services and offers of services provided by CollabScale, in addition to other promotional content and services provided by CollabScale’s Ad Partners.

When CollabScale collects information that does not identify a specific natural person (“Non-Personal Information”), it may use and disclose this information for any purpose at all whatsoever, unless such use is otherwise prohibited by this Policy or applicable law. Examples of Non-Personal Information include but are not limited to the following: physical location information; demographic information (gender, date of birth, ZIP codes and etc.); or any other personal information that has been anonymized, aggregated or de-identified. If CollabScale combines any Non-Personal Information with a User’s personal information (such as combining a User’s ZIP code with their name), CollabScale will consider such combined information as Personal Information and will use and disclose such Personal Information in accordance with this Policy. Similarly, if applicable law requires CollabScale to treat certain Non-Personal Information as Personal Information, then CollabScale will use and disclose this information as Personal Information in accordance with this Policy.

  1. How CollabScale Shares Information.

CollabScale works with third-party partners that help CollabScale improve its products and services, which makes it possible for CollabScale to operate its business and provide its products and services to Users. CollabScale does not sell User’s Personal Information and imposes strict restrictions on how its Ad Partners, affiliates and any third-parties to which User information is shared is allowed to use and/or further disclose User information. Below is a summary of some of the ways CollabScale gathers information and the types of third parties with which such information may be shared.

  1. Analytics Services Providers. 

CollabScale compiles and provides aggregated statistics and insights to help understand how Users are engaging with posts, listings, videos and other content on and off the Platform. For example, CollabScale works with analytics services providers to determine the number of Users that have viewed or interacted with the Platform in any way, as well as aggregate demographic and other information to help understand User interactions with the Platform.

  1. Advertisers. 

CollabScale provides its Ad Partners with reports about the kinds of Users that are seeing the Ad Partners’ ads and how these ads are performing. In no circumstances does CollabScale share information that personally identifies Users (such as User’s names and/or email addresses that could be used to contact Users directly or identifies who they are) unless the User gives CollabScale permission. CollabScale provides general demographic and interest information to its Ad Partners, such as that an ad was seen by a female between the ages of 25 and 34 that lives in Austin and likes yoga to help Ad Partners understand their audience. CollabScale also confirms which ads led to Users making a purchase or having some interaction with an Ad Partner.

  1. Measurement partners. 

CollabScale shares information about Users with companies that aggregate data to provide analytics and measurement reports to its Ad Partners.

  1. Partners offering goods and services on the Platform. 

When Users buy something from an Ad Partner or other type of CollabScale partner, the creator of this content may receive User’s public information and other information that the User has shared, in addition to any information needed by the User to complete the transaction, including shipping and contact details.

  1. Vendors and service providers. 

CollabScale provides information and content to vendors and service providers that support CollabScale’s business, such as by providing technical infrastructure services, analysis related to how CollabScale’s products and services are used, and/or to provide User support.        

  1. The Legal Basis on Which CollabScale Processes User’s Personal Data.

CollabScale collects and processes User’s Personal Information on several different legal bases, depending on the nature of Personal Information provided to CollabScale and the type of processing involved.

  1. Performance of a Contract.

The majority of Personal Information processed by CollabScale is necessary for CollabScale to properly perform its agreements with Users, such as its Terms of Use and this Policy, or to take certain action(s) at the request of a User.

  1. Legitimate Interest.

CollabScale may process User’s Personal Information as necessary for legitimate interests pursued by CollabScale, such as sending Users marketing about its products and services or where CollabScale believes Users have a reasonable expectation that CollabScale will perform a particular type action on their behalf.

  1. Compliance with a Legal Obligation.

CollabScale may process Personal Information as is necessary to facilitate CollabScale’s compliance with a legal obligation.  

  1. Consent.

CollabScale may also rely on User’s consent to process their Personal Information. If CollabScale requires User’s consent to collect and process certain Personal Information, CollabScale will request the User’s consent at the time CollabScale requests this Personal Information to be provided, and processing this Personal Information will only be performed if User’s give their consent, unless CollabScale has another lawful basis on which to rely. Users may withdraw their consent, as further detailed in this Policy.

  1. Additional Personal and Demographic Information Users May Elect to Give CollabScale.

As part of CollabScale’s initiative to incorporate more transparency in the influencer and collaborator space, CollabScale may give Users the opportunity to provide personal diversity and inclusion (“D&I”) information. 

CollabScale may ask Users to provide (and CollabScale may subsequently collect) certain categories of D&I information such as, but not limited to, the following:

  1. D&I Information Principles

CollabScale recognizes that some of these categories of information are sensitive and personal, so CollabScale will be transparent in how this data is collected and processed so that Users can make an informed decision whether or not they want to provide this information to CollabScale.

CollabScale also wants Users to know the following: 

  1. Users are not obligated to provide this information to access or use the CollabScale Platform.
  2. CollabScale will only collect and process D&I information based on User’s explicit consent.
  3. Users will have the option at any time to remove previously supplied D&I information or to update D&I information that may have changed.
  4. CollabScale may employ physical, electronic, and managerial measures to safeguard the information CollabScale collects online. However, Users should know that no company can fully eliminate security risks, and CollabScale cannot make guarantees about any part of its Platform or related products or services.
  5. CollabScale may use D&I data only for the purposes described in this Policy unless CollabScale notifies Users at the time of collection that CollabScale may use the D&I information in some other manner.
  6. CollabScale takes precautions to ensure that Users’ decision to provide their D&I information does not inadvertently negate User’s anonymity or reveal their identity on CollabScale’s platform. However, there are two instances in which disclosure of a User’s identity may occur:
  1. If a User, regardless of the risks of identification, affirmatively wishes to have their opinions and experiences heard, CollabScale may provide the option for such User to opt into the disclosure of their D&I data in a manner and to an extent that the User’s identity may be discoverable on the Platform. These choices will be conspicuously marked and will require User’s consent to verify Users’ understanding, intention, and acceptance of this risk of identification.
  2. CollabScale will not sell or transfer Users’ D&I information to a third-party in a way that would purposefully risk Users’ anonymity. CollabScale may, however, disclose D&I information to one of CollabScale’s affiliates or service providers to enable such affiliate or service-provider to process data for purposes that are consistent with this Policy. CollabScale may also anonymize and/or aggregate data and make it available to third parties and the public as described in this Policy.

  1. Cookie Policy and Ad Choices.

This Cookie Policy describes how CollabScale uses Cookies and similar technologies.

  1. Cookies.

Cookies are small pieces of data that are stored on User’s computer, mobile phone, or other device when they first visit a page. CollabScale uses cookies, web beacons, locally shared objects (sometimes called “flash cookies”), mobile identifiers and similar technologies to help CollabScale recognize Users on the Platform, enhance User’s experience, understand usage of the Platform, and show Users relevant advertising. Cookies may also be set by other websites or services that run content on the page a User is visiting. After a User registers on the Platform, CollabScale may connect information it collects from the Cookies set by CollabScale and its partners with other information received from a User. The provision of data via Cookies is voluntary except for those Cookies that CollabScale places on a User’s device because CollabScale needs this information for the performance of the Platform and its services.

  1. What types of Cookies does CollabScale use?

CollabScale uses two types of Cookies on the Platform: “session cookies” and “persistent cookies.” Session Cookies are temporary Cookies that remain on a User’s devices until a User leaves the Platform. A persistent Cookie remains on a User’s device until the User manually deletes it.

  1. What does CollabScale use Cookies for?

Cookies transmit information about Users and their use of the Platform, such as Users’ browser type, search preferences, data relating to advertisements that have been displayed to Users or that Users have clicked on, and the date and time of Users’ use of the Platform. With the exception of identifier Cookies that are associated with registered User accounts to prevent fraud on the Platform, Cookies link to certain unique information (such as information on Users’ profiles), but this is not linked to specific User names.  

  1. How CollabScale Works with Third-Party Ad Partners.

When CollabScale works with its Ad Partners to present Users with personalized advertising experiences, CollabScale does not share information with Ad Partners that can be used to identify Users or associate with Users on an individual basis, unless the User has instructed CollabScale to do so (such as when Users provide information requested by an Ad Partner). If a CollabScale Ad Partner has information about Users saved in one of the Ad Partner’s own Cookies, then the Ad Partner can use that information to help CollabScale send Users relevant ads, but the Ad Partners do not share information with CollabScale that would lead to identifying individual Users.

  1. Consenting to Cookies and Opting Out of Cookies

CollabScale uses Cookies that are necessary for CollabScale to provide services to Users and Users cannot opt out of these Cookies on the Platform. Users are able to opt out of Cookies (other than the strictly necessary cookies) at any time. Users may also disable placement of some (but not all) Cookies by setting their browser to decline cookies, although this diminishes their User experience. Additionally, Users are able to control, manage and/or delete Cookies via their browser settings.

If Users enable location data for any mobile version of the Platform, CollabScale may use their location data to provide geo-targeted ads from Ad Partners that are local to the User. CollabScale does not share a User’s location with Ad Partners. Geo-targeted ads occur because CollabScale may provide Ad Partners with the ability to push ads to Users that are located in certain geographic areas. Users can disable their location services at any time in their device privacy settings.

  1. Ad Partner Cookies.

When Users visit CollabScale from regions in which applicable law requires User consent for using non-strictly necessary Cookies, CollabScale will surface a Cookie consent banner and request the User’s consent.

If ads or other features on the Platform are provided by third-parties, these third-parties set and use their own Cookies, and these Cookies are subject to the third parties’ privacy notices and policies. CollabScale has no access or control over these Cookies and CollabScale takes no liability or responsibility for these Cookies in any way. Further, if Users respond to ads posted by third-parties or submit information to third-parties via the Platform, such information is submitted to and governed by the third-parties and such third-parties’ respective privacy policies and notices, and CollabScale shall have no responsibility or liability therefor.

  1. Do Not Track Signals

CollabScale does not currently respond to ‘do not track’ signals and similar settings or mechanisms. When Users use and interact with the Platform, CollabScale aims to provide Users with a customized experience.

  1. Users’ Privacy Rights

Users may submit a data rights request to access, correct, delete, export, rectify, update, or ask questions about their Personal Information. If they do so, the User’s name and email address will be requested. CollabScale will then take measures to verify the User’s identity. Users can object to processing their Personal Information or ask CollabScale to restrict processing their Personal Information. Users have the right to opt-out of marketing communications from CollabScale at any time.  

Similarly, if CollabScale has collected and processed Users’ personal information with their consent, the User is able withdraw such consent. Withdrawing consent does not affect the lawfulness of any Personal Information processing that CollabScale has conducted prior to the User’s withdrawing consent, and it will not affect processing the User’s personal information which may be lawful based on grounds other than User consent. CollabScale does not process User information to make automated decisions about Users which may have a legal or other significant effect. CollabScale does not discriminate against Users that exercise the privacy rights set forth in this Policy or otherwise available pursuant to applicable law. Further, CollabScale will respond in a reasonable time to requests from Users wishing to exercise their data protection rights provided by applicable laws and/or as set forth in this Policy. Notwithstanding the foregoing, CollabScale reserves the absolute right to keep any information in its archives that CollabScale, in its sole but reasonable discretion, deems necessary to comply with CollabScale’s legal obligations, resolve disputes and enforce its agreements.

  1. How Long CollabScale Keeps User’s Personal Information

CollabScale keeps Users’ personal information as long as needed to operate the Platform and for the purposes set forth in this Policy. Retention periods can vary significantly based on the type of information and how the information is used. CollabScale retention periods are based on criteria such as legally mandated retention periods, pending or potential litigation, CollabScale’s intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When CollabScale no longer needs Users’ personal information and/or no longer needs to retain this information to comply with legal or regulatory obligations, resolve disputes and enforce CollabScale’s agreements, CollabScale will either remove it from its systems or depersonalize it so that the information does not identify specific Users.

  1. Security Safeguards

  1. Security. 

CollabScale employs physical, electronic, and managerial measures to safeguard the information it collects online. However, it is impossible to fully eliminate security risks, so CollabScale does not make any guarantees of any kind about the Platform or its related products or services. Users are responsible for keeping their username and password private. Once Users have registered with CollabScale, Users will not be asked by CollabScale for their password. CollabScale advises Users to create unique passwords for their User Profiles and to not use this password for any other web services or applications and to not share this password with others.        

  1. Privacy of Minors. 

To access or use the Platform, Users must be at least 16 years of age to use the Platform. If any User becomes aware that someone under the age of 16 has provided CollabScale with personal information without parental consent, please contact CollabScale. If CollabScale becomes aware that someone under the age of 16 has provided CollabScale with personal information without parental consent, CollabScale will remove such information and terminate any accounts associated with such person.        

  1. Data Controller. 

 The information about Users that CollabScale collects, processes and/or uses through the Platform is hosted, controlled, and services are provided by CollabScale and/or its affiliates as set forth in this Policy and CollabScale’s Terms of Use.

  1. Updates to CollabScale’s Privacy Policy.

CollabScale may revise this Policy from time to time by publishing an updated version of this Policy on the Platform. The revised Policy will be effective as of the revision date for all Users. However, Users may object to the new Policy within thirty (30) days after the revision date. If CollabScale makes a change to the Policy that will have a material impact on the Users’ rights or increase their responsibilities, CollabScale will notify Users by email (sent to the email address specified in Users’ account) or by posting a notice on the Platform prior to the change becoming effective. CollabScale encourages Users to periodically review this Policy for the latest information on CollabScale’s privacy practices. Users continued use of the Platform is subject to the most current version of this Policy. If a User objects to the Policy after it becomes effective, the User may no longer use the Platform. Any capitalized terms used in this Policy but not otherwise defined shall have the meaning set forth in CollabScale’s Terms of Use, which is available for all Users on the Platform.