Privacy Policy

This Privacy Policy describes the personal information practices of Euna Solutions, Inc. (“Euna Solutions,” “we,” “us,” or “our”) in connection with our business; our websites, including www.eunasolutions.com, and any other websites, blogs, and applications operated under the Euna Solutions brand (collectively, the “Sites”); and our software-as-a-service platform and related products and services (collectively, the “Platform Services”). Where a particular Site or application provides a different privacy policy, that policy will govern. Personal information collected or processed through the Platform Services is subject to the privacy policies of our Customers, as further described in Section I.

For purposes of this Privacy Policy, “Personal Information” means any information that identifies, is related to, describes, or is reasonably capable of being linked or associated with, directly or indirectly, an identifiable individual. Personal Information does not include information that is considered anonymous, de-identified, or aggregated by applicable law.

NOTE: The Sites are business-to-business websites and are not directed at consumers. When a consumer visits our Sites, we may collect information automatically as described in Section IV, below. When our customers (“Customers”) use our Platform Services to collect, use, or disclose Personal Information, we act solely as a service provider processing Personal Information on behalf of and as directed by the Customer. The privacy practices governing those activities are those of the applicable Customer, not Euna Solutions. Individuals with questions about how their Personal Information is handled in connection with a Customer’s use of the Platform Services should refer to the applicable Customer’s privacy policy.

To the extent consent is required under applicable law, your use of our Sites indicates that you consent to our collection, disclosure, and use of Personal Information about you as described in this Privacy Policy. You may withdraw your consent at any time, subject to legal or contractual restrictions, by contacting us as described in the Contact Us section below. Note that withdrawing consent may affect our ability to provide certain services to you.

We do not offer or provide products and services for minors or children. If you are under 18, you may not use our Sites.

We may update this Privacy Policy from time-to-time to reflect changes in our practices. When we post modifications to this Privacy Policy, we will update the “Last Updated” date on the top of this Privacy Policy. The new Privacy Policy will be applicable from that date forward until further changes are made and a new Last Updated date appears. We encourage you to periodically review this page for the latest information on our privacy practices.

This Privacy Policy does not cover our data handling practices for our employee data. This Privacy Policy also does not apply to any third-party websites, applications, or services that you may access through our Sites.

Please see Sections V and XI for more information about specific privacy rights you may have. Please see Section IX for additional disclosures applicable to California residents. For California residents, our Notice at Collection is as follows:

1. A list of the categories of Personal Information we collect is available in Section IX.

2. The purposes for which Personal Information is collected and used are available in Section II.

3. We may disclose data in a manner that may constitute a “sale” or “sharing” (as those terms are defined by California’s CCPA) of personal information about you. The specific categories that are sold or shared are disclosed in Section IX. Our Notice of Right to Opt-Out of Sale/Sharing is also provided in Section XI. We do not sell or share Platform Services Data.

4. Our retention period for personal information is discussed in Section VI.

I. Personal Information We Collect and Their Sources

A. For all individuals other than job applicants, the following describes the types of Personal Information we collect from the indicated source:

Personal Information We Collect Directly from You. We may collect Personal Information that you provide to us when you register for or license our products, call us or send us an email, participate in promotions, sign up for a demo, register to create a new account, register for our newsletter, attend an event or webinar, interact with us at a trade show or similar event, participate in any contests, sweepstakes and/or other promotions, download articles, data sheets, or other content from our Sites, or otherwise choose to provide Personal Information to us. We may collect direct identifiers such as your name, email address, phone number, job title, company name, account username and password, and other similar information, as well as additional information you choose to include in your account profile such as a profile picture. We may also collect commercial information regarding your business, such as the products and services you license or receive from us, your company’s website, your buying group, franchise or national account, your payment information (e.g., cardholder data), tax information, your shipping address, your billing address, and the information you provide in connection with your order. Further, we may collect other Personal Information you provide to us, including information you provide when you seek our assistance licensing products, respond to a survey, report a problem with the Sites, or send us an email. Some forms on the Sites may require that you provide certain Personal Information to submit the form, and you may choose not to provide Personal Information in those cases, but this may prevent you from being able to license our products or use certain features of our Sites or receive certain services that require the Personal Information to perform the service.

If you choose to refer a third party to us, we may collect that third party’s name, email address, and company name, and by providing this information you represent that you have the third party’s permission to share their Personal Information with us.

Personal Information We Collect Through AI-Assisted Features. We may offer interactive AI-assisted chat or similar features on our Sites (collectively, “AI Features”). When you choose to use an AI Feature, we may collect the Personal Information you submit through the AI Feature interface, including the content of your messages and any other information you choose to provide. We may also automatically collect certain Personal Information in connection with your use of AI Features, such as your IP address, device information, and browser type, as further described herein.

AI Features are operated with the assistance of third parties who perform services on our behalf (“Service Providers”). Such Service Providers process Personal Information in connection with the AI Features solely to generate responses, provide functionality, maintain security, and improve service and AI Feature performance in accordance with our contractual requirements.

Please do not submit Sensitive Personal Information (as that term (or like term) is defined under your jurisdiction’s law) through our AI Features, including passwords, precise geolocation, payment card numbers, financial information, government-issued identification numbers, Social Security numbers, or health information.

Personal Information We Collect Automatically. We may automatically collect Personal Information about you when you access, interact with, or use our Site or promotional emails. To automatically collect Personal Information about you, we use automated means such as cookies, pixels, session replay, beacons, invisible tags, and other similar tracking technologies (collectively “Cookies”). These typically involve pieces of information or code that a website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you. We have included below a description of the information we may automatically collect from you with these Cookies:

• Direct identifiers, such as your IP address, and your registered domain or home server.

• Location data, such as physical location or movements. When we collect your IP address, we may infer location such as city or postcode therefrom.

• Your device and browser information, such as information about your browser type, device used to access our Site, connection speed, screen resolution, operating system and data regarding network-connected hardware (e.g., computer or mobile device). We also may determine the applicable technology available to serve you the most appropriate version of a web page, e-mail, advertising or promotional announcement or similar service.

• Internet or other electronic network activity information, such as your session identification number, search terms, search results, access times, software crash reports, and referring website’s addresses.

• Detailed information about your usage of our Site, such as your date of access, time of access, clickstream to, through, and from our services (including dates and times), products you viewed, searched for, which links you click on, which pages or content you view and for how long, and other similar data and statistics about your interactions, such as length of visits to certain pages, page response times, and download errors. We may also visually record your interactions with our website, including your mouse clicks, mouse-overs, scrolling, keystrokes, and navigation through our Site.

• Interaction with promotional emails, such as whether you clicked on an email from us.

For more information about the Cookies and the methods that may be used on our Sites to automatically collect information please refer to Section IV, below.

Personal Information We Collect from Others. We may obtain Personal Information about you from other sources. For example, we may obtain Personal Information about you from third-party services, from our related companies, lead generation providers, social media platforms, public databases, and from our business and channel partners. We may combine this information with information we collect through other means described above. This helps us to update and improve our records, identify new customers, create more personalized advertising and suggest products that may be of interest to you.

Personal Information We Collect Through Our Platform Services. Our Platform Services are intended for use by our public sector Customers and their employees, customers, constituents, and suppliers (collectively, “End Users”). Personal Information collected through the Platform Services is referred to in this Privacy Policy as “Platform Data.” When Customers and End Users access or use the Platform Services, we may collect general business contact information, including names, employee identification numbers, workplace email addresses, and workplace telephone numbers, to create and manage End User accounts. Our Platform Services may also collect, process, and store additional Personal Information supplied by our Customers as necessary for the proper operation of the contracted services. The specific Personal Information collected through our Platform Services varies by product.

When operating the Platform Services, we act as a service provider to our Customers and not as a data controller with respect to Platform Data. Our Customers are responsible for maintaining their own privacy policies governing the collection, use, and disclosure of Platform Data, and for obtaining any necessary authorization or consent for the processing of Platform Data. Any individual seeking to exercise privacy rights with respect to Platform Data should direct their request to the applicable Customer.

More detailed information about the security and privacy practices applicable to our Platform Services is available to Customers and prospective Customers upon request.

Other Personal Information and Sources. We may also receive Personal Information about you in circumstances where we provide you with a copy of this Privacy Policy or we make this Privacy Policy available to you.

B. For job applicants, in addition to the Personal Information collection described above, we collect through our Sites the Personal Information you voluntarily provide to us when submitting a job application, including your name, email address, telephone number and resume.

We may also receive Personal Information about you in circumstances where we provide you with a copy of this Privacy Policy or we make this Privacy Policy available to you.

II. Purposes for our Collection and Use of Personal Information

We collect and use Personal Information for the following purposes:

To provide our products and services and to engage in the ordinary course of business. We collect and use Personal Information, for example, to fulfill or meet the reason you provided the information. We may also collect and use Personal Information about you, such as your contact information, payment card information and order information, to provide you products and services you request, including to process your transactions and payments and fulfill your orders, create and administer your account, communicate with you and provide you customer service in relation to the products and services you request. We may collect and use all categories of Personal Information for these purposes.

To provide and support our Platform Services. We collect and use Personal Information to deliver, maintain, and support our Platform Services to our Customers and their End Users, including to create and manage End User accounts, deliver training and technical support, process payments for Platform subscriptions, and carry out transactions you have requested. We may collect and use all categories of Personal Information for these purposes.

To respond to your requests or questions. We collect and use Personal Information to respond to your feedback, inquiries, and requests, including to provide you with information about products and services you may be interested in. We may collect and use all categories of Personal Information for these purposes.

To improve the operation of our Sites and business. We may collect and use Personal Information to improve your experience on our Sites and the functionality of our Sites, such as by analyzing how our Sites are being accessed and used, including by analyzing user clicks and usage patterns to improve user experience, maximize usage of our services, and diagnose problems. We may also collect and use Personal Information to evaluate interest in our products. We may collect and use all categories of Personal Information for these purposes.

For marketing and sales purposes. We collect and use Personal Information to market and advertise our products and services to you, including by sending you communications about new features and product updates, event announcements, changes to our terms and policies, programs in which you have chosen to participate, promotional offers and surveys, and to schedule demos and manage free trials. We may also use Personal Information to identify and pursue potential customers, generate sales leads, create and manage marketing campaigns, and deliver interest-based advertisements on our Sites and on other websites and content platforms. We may communicate with you directly through email, telephone calls, chat, and video conferencing for these purposes. We may collect and use all categories of Personal Information for these purposes.

To enforce our agreements and prevent fraud. We collect and use Personal Information to enforce our website terms of use and our contracts with Customers and other parties, to prevent fraud and other prohibited or illegal activities, and to protect the security and integrity of our Sites and Platform Services. We may collect and use all categories of Personal Information for these purposes.

To address our safety, security, compliance and legal obligations. We may collect and use all categories of Personal Information for these purposes.

To record calls and meetings. We may record telephone calls, video conferences, and similar communications in which you participate in connection with your business relationship with us. Where required by applicable law, we will notify you that a recording is taking place and provide you with an opportunity to opt out prior to the recording commencing. We may collect and use all categories of Personal Information for these purposes.

To operate automated and AI-assisted processes. We may use automated decision-making technologies, including artificial intelligence, to support certain business processes. Where we use such technologies in a manner that produces legal or similarly significant effects concerning you, you may have the right to request meaningful information about the logic involved and to opt out of such processing where permitted by applicable law. Where required by applicable law, including Quebec’s Act respecting the protection of personal information in the private sector, you may also have the right to be informed when a decision based solely on automated processing of your Personal Information is made about you and to request that a human review that decision. To exercise this right, please contact us as described in the Contact Us section below. We also use Personal Information collected through our AI Features to provide contracted Platform Services, respond to inquiries, provide information about our products and services, deliver customer support, improve the functionality and performance of our AI Features, maintain safety and security, prevent fraud or misuse, and comply with applicable legal obligations. We may collect and use all categories of Personal Information for these purposes.

To conduct corporate transactions. We may collect and use all categories of Personal Information for these purposes.

To consider individuals for employment. We may collect and use all Personal Information referenced above in connection with job applicants for these purposes.

To provide the information to Service Providers and other third parties as further described in Section III, below. We may collect and use all Personal Information referenced above for these purposes.

With your consent. We may collect and use Personal Information about you where you have given us consent to do so for a specific purpose not listed above.

We may collect and use anonymized, de-identified, or aggregated information for any purpose permitted by law. We may also collect and use Personal Information as otherwise disclosed to you at the point of collection or as required or permitted by applicable law

III. Purposes for our Disclosures of Personal Information.

We disclose Personal Information for the following purposes:

Service Providers. To Service Providers to perform services on our behalf. For example, we disclose Personal Information to Service Providers who send emails for us, operate our Sites, run a promotion, or assist with order fulfillment. We may also disclose Personal Information to Service Providers that operate, support, or maintain our AI Features and related infrastructure on our behalf. Service Providers process Personal Information solely as directed by us and in accordance with our contractual requirements.

Advertisers. To social media, technology and advertising-related companies (“Advertisers”) to advertise for us. For example, we disclose Personal Information (including as described in Section IV) to advertise our products and services to you on social media and other platforms and to conduct analytics on the use and operation of our Sites.

Requested Third Parties. With your consent, where you have directed or requested us to make the disclosure, or where we deem necessary for us to provide our products and services (“Requested Third Parties”). When we process payment transactions, for example, our payment processor, the payment brands (e.g., Mastercard, Visa) and other third parties performing payment transaction services (e.g., your card issuer) will receive Personal Information about you so that your payment can be processed. Their collection, use and disclosure of Personal Information is described in their own privacy policies, notices and statements.

Professionals. To professional consultants such as our accountants, lawyers and financial advisors to enable them to provide the services we request them to provide (“Professionals”).

Euna Solutions Group. Among the entities that comprise the Euna Solutions Group. Euna Solutions shares Personal Information with those entities controlling, controlled by or under common control with Euna Solutions, Inc., including our parent, subsidiary, and affiliate entities and our portfolio of companies (collectively, the “Euna Solutions Group”), as necessary for the purposes identified in this Privacy Policy.

Corporate Transaction. In connection with a corporate transaction or reorganization event (“Corporate Transaction”). We may disclose, transfer or assign Personal Information about you in connection with a sale, merger, consolidation, change in control, transfer of assets, reorganization or liquidation of Euna Solutions, Inc. or any other entity comprising the Euna Solutions Group. This may include a sale of part of our business to another entity or an asset sale.

Government and Other Third Parties. To government entities and other third parties for safety, security, legal compliance, to enforce our rights, conduct an investigation, or for related purposes (“Government and Other Third Parties”). We may be required to provide Personal Information to law enforcement or other governmental authorities, or to other third parties, when we believe in good faith that disclosure is necessary or appropriate to: (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce our website terms of use or our contracts with Customers and other parties, including to investigate potential violations; (iii) detect, prevent, or otherwise address fraud, security, or technical issues, including by exchanging Personal Information with other companies and organizations for fraud protection and spam and malware prevention; (iv) protect or defend our rights or the rights or well-being of our customers, End Users, or other users of our services; or (v) protect the health and safety of our personnel, customers, guests, and the general public. We may also disclose Personal Information to investigative bodies in the case of a breach of an agreement or contravention of law, or as otherwise required by law or court order, or as necessary to exercise our legal rights or defend claims brought against us.

We may also disclose Personal Information as otherwise described to you at the point of collection or as required or permitted by applicable law.

We may disclose anonymized, de-identified, or aggregated information for any purpose permitted by law.

IV. How We Use Cookies and Targeted Advertising

Our Use of Cookies. As explained above, we use Cookies to automatically collect data from you and your devices when you use our Sites. Cookies enable you to be remembered when using a specific computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalized content. Certain Cookies also enhance our ability to serve you targeted advertising on websites and platforms other than our Sites.

The types of Cookies we use can be classified as follows:

• Functional Cookies. The technical storage or access is strictly necessary for the legitimate purpose of enabling the use of a specific service explicitly requested by the subscriber or user, or for the sole purpose of carrying out the transmission of a communication over an electronic communications network. These Cookies are always active and are essential for the Sites to function. They are usually set in response to actions made by you, such as logging in, setting your privacy preferences, or filling in forms. Because these Cookies are strictly necessary to deliver the Sites, you cannot refuse them, though you can set your browser to block them, in which case some parts of the Sites may not work properly.

• Preferences Cookies. The technical storage or access is necessary for the legitimate purpose of storing preferences that are not requested by the subscriber or user. These Cookies enable the Sites to remember information that changes the way the Sites behave or look, such as your preferred language, region, or other customized settings. If you do not allow these Cookies, some or all of these personalization features may not function properly.

• Statistics Cookies. The technical storage or access that is used exclusively for statistical purposes. These Cookies allow us or third parties on our behalf to count visits and traffic sources so we can measure and improve the performance of our Sites. They help us to know which pages are the most and least popular and see how visitors move around the Sites. The information collected by these Cookies is typically aggregated and anonymous, although some collected information may constitute Personal Information under applicable law. If you do not allow these Cookies, we will not know when you have visited our Sites and will not be able to monitor the performance of our Sites.

• Marketing Cookies. The technical storage or access is required to create user profiles to send advertising, or to track the user on a website or across several websites for similar marketing purposes. These Cookies may be set through our Sites by our advertising partners and may be used by those companies to build a profile of your interests and show you relevant advertisements on other websites, apps, and social media platforms. They store information that may constitute Personal Information under applicable law, such as unique identifiers associated with your profile, device, or browser. If you do not allow these Cookies, you will experience less targeted advertising.

Unless you opt out of our Cookies or change your Cookie preferences (as described below), by clicking “Accept,” authorizing cookies under “View preferences,” or by using our Sites without selecting your preference, you consent to the use of Cookies, including to automatically collect data from and about you. If you opt out of our Cookies, the only Cookies we will place on your session are those that are Functional Cookies or Cookies that you have individually consented to receive.

Several Cookies we use last only for the duration of your session and expire when you close your browser. Others are used to remember you when you return to our Sites and will last longer.

Cookie Preferences. You may change your Cookie preferences at any time to prevent the further collection of Personal Information through the Preferences, Statistics, and Marketing Cookies on the Site.

• Cookie settings on the Sites. Use the “Manage Cookies” link at the bottom of our Sites to turn on or off the different categories of Cookies. Note that depending on your prior selections, after selecting “Manage Cookies,” you may need to first select “View preferences” before selecting your cookie options. Your selection will be remembered on the specific device or browser you are using until you clear Cookies. Note that each Site has its own settings, and you must configure your Cookie preferences on each individual Site.

• Browser settings. Most web browsers automatically accept Cookies, but if you prefer, you can change your browser settings to prevent Cookies. How you can do this will depend on the browser you use (see your browser help screen for details).

You may not be able to take full advantage of our Sites if you disable certain Cookies. The effect of disabling Cookies depends on which Cookies you disable but in general, the Sites may not operate properly if all Cookies are switched off. Depending on your jurisdiction, we may separately prompt you regarding our use of Cookies on the Sites.

Our use of Targeted Advertising. We use online advertising to keep you aware of our brand and help you to find and see our products. We partner with platforms such as Google, Microsoft (Bing, LinkedIn), and similar digital advertising partners. Marketing Cookies help us and the advertising partners we work with to gather information about the content you visit on our Sites and other websites. This may result in you seeing our banners and ads when you are on other websites, apps and social media platforms. We may also target ads using Personal Information we have collected when you create an account on the Sites.

Social Media and Internet Platforms. We may disclose certain portions of Personal Information about you and your use of our Sites to social media and internet platforms. If you have an account on one of these platforms, you may be shown our marketing messages while you are using the social media or internet platform. Additionally, certain functionalities on our Sites may permit interactions that you initiate between the Sites and these social media and internet platforms (“Social Features”). Examples of these Social Features include features enabling you to like or share our content and features. If you use Social Features, and potentially other third-party services, information you post or provide access to may be publicly displayed by the third-party service you use.

Targeted Advertising Preferences. You may opt-out of us using Personal Information about you for targeted advertising by changing your Cookie preferences. Use the “Manage Cookies” link at the bottom of our Sites and then toggle the “Marketing Cookies” button to the left so that it is turned off. Note that depending on your prior selections, after selecting “Manage Cookies,” you may need to first select “View preferences” before selecting your cookie options.

If you are using a web browser with Global Privacy Control enabled, we will recognize that signal as a request to opt-out of Preferences, Statistics, and Marketing Cookies, just as if you had turned off those Cookies in the Manage Cookies or View preferences link.

V. Your Choices

This Section describes certain choices you may have about the Personal Information we collect from you. You may have additional rights as provided in Section XI, below.

You can opt out of receiving our marketing emails. To stop receiving our promotional emails, email our privacy team at [email protected] or follow the instructions in any promotional message you receive from us. Even if you opt out of receiving marketing email messages, we may still send you transactional and other direct messages. These include, for example, responses to your questions and inquiries. If you opt-out of receiving marketing email communications from our business partners with whom we have disclosed your information, you will still receive marketing communications from us and any other business partners with whom your information was disclosed.

You can request that we stop sharing information with third parties for their marketing purposes. To opt out of having us share your information with third parties for their promotional purposes, email us at [email protected].

You can control cookies and tracking tools on our Sites. To learn how to manage how we use Cookies on our Sites, please refer to Section IV.

You may withdraw your consent to our use of your Personal Information. Where we rely on your consent as the basis for collecting, using, or disclosing your Personal Information, you may withdraw that consent at any time by contacting us as described in the Contact Us section below. Please note that withdrawing your consent does not affect the lawfulness of any collection, use, or disclosure carried out before your withdrawal, and may affect our ability to provide certain products or services to you.

VI. Data Retention

We retain Personal Information as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide our products and services, comply with our legal obligations, prevent fraud, resolve disputes, troubleshoot problems, and enforce our agreements. In determining the criteria by which to retain or dispose of Personal Information, we consider the type, sensitivity, context, and purpose of collecting Personal Information. The specific retention period for each category of Personal Information is available upon request by contacting us as described in the Contact Us section below.

Personal Information collected through our AI Features may be retained for a limited period to provide customer support, maintain security, comply with legal obligations, and improve and train our AI systems. Where such data is used for AI training or improvement purposes, de-identified or aggregated versions may be retained for longer periods, including on an ongoing basis.

Personal Information that is no longer necessary to provide our services may be de-identified or aggregated. De-identified or aggregated information is not Personal Information and may be retained and used by us for any purpose permitted by applicable law.

VII. Security and Data Transfer

We have implemented reasonable safeguards designed to protect Personal Information from unauthorized loss, misuse, alteration, or destruction. We also take reasonable steps designed to ensure that third parties who work with us agree to protect Personal Information we disclose to them or that they process on our behalf.

No security measure, however, can guarantee absolute security. Accordingly, we cannot guarantee that Personal Information related to you will be secure. We encourage you to take precautions when providing Personal Information to us or others. If you believe Personal Information related to you has been compromised in connection with your business dealings with us, please contact us immediately as detailed in the “Contact Us” Section below.

Personal Information we collect may be transmitted, stored and processed in the United States or Canada. By using our Sites or providing Personal Information to us, you acknowledge that your Personal Information may be stored and processed in these countries, where privacy laws may differ from those in your jurisdiction.

When Personal Information is transferred to third-party Service Providers or other recipients located in jurisdictions outside of Canada or the United States, we use contractual or other means to provide a comparable level of protection for that Personal Information while it is being processed in those jurisdictions.

In the event of a confidentiality incident involving Personal Information that presents a risk of serious harm to affected individuals, we will notify the affected individuals and applicable regulatory authorities, including the Commission d’accès à l’information in Quebec and the Office of the Privacy Commissioner of Canada, as required by applicable law. We maintain a register of confidentiality incidents as required by applicable law.

VIII. Information Relating to Minors

Our Sites are not intended for minors under the age of 18 and we do not knowingly collect Personal Information directly from minors under the age of 18 through our Sites without prior parental consent as required by applicable law. If you believe a minor has provided Personal Information to us directly through our Sites, please contact us using the information in the Contact Us section below and we will take reasonable measures to delete such Personal Information as soon as possible, except where retention is necessary to protect the safety of the minor or others as required or permitted by law.

Our Platform Services may receive Personal Information about minors from our Customers in connection with the services we provide. As a service provider, we process such information solely as directed by the applicable Customer. Individuals with questions or concerns about Personal Information relating to a minor that has been submitted through the Platform Services should contact the applicable Customer directly.

IX. Additional Disclosures for California Residents

This Section IX applies to individuals residing in California and is made in accordance with the California Consumer Privacy Act (“CCPA”) (California Civil Code Section 1798.100 et seq.) and the “Shine the Light” Law (California Civil Code Section 1798.83). The additional disclosures in this Section IX supplement the disclosures above.

A. Compliance with Section 7027(m)

For California residents, we do not use or disclose Sensitive Personal Information (as this term is defined in the CCPA) for purposes other than those specified in Section 7027(m) of the California Consumer Privacy Act Regulations.

B. California’s “Shine the Light” Law

California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of certain categories of Personal Information to third parties for those third parties’ direct marketing purposes. To make such a request, please contact us as provided in Section XI, below. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted other than as provided in Section XI.

C. Disclosures of Personal Information – Individuals other than Job Applicants

For individuals other than job applicants, during the preceding 12-month period we may have disclosed the following categories of Personal Information for a business purpose to the following categories of third parties:

D. Disclosures of Personal Information – Job Applicants

For job applicants, during the preceding 12-month period we may have disclosed the following categories of Personal Information for a business purpose to the following categories of third parties:

X. Selling, Sharing, and Targeted Advertising

Certain states, such as California, require that we disclose whether we “sell” or “share” Personal Information. This Section X solely applies to residents of California and those other States that, like California’s CCPA, have laws that require us to make this disclosure (“Covered State Laws”). We may “share” or “sell” Personal Information to third-parties (as such terms are defined under applicable Covered State Laws) certain (i) Identifiers, (ii) Commercial Information, (iii) Internet and other electronic network activity information, and/or (iv) Geolocation Data, primarily to engage in online advertising activities and provide tailored content and ads that may be of interest to you. You have the right to opt out of this disclosure of your information, as provided in Sections IV and XI.

We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years old.

We do not sell or share Platform Services Data.

XI. Additional Rights and Disclosures for Select States

Residents in California and certain other States may have rights under their State’s privacy laws that require us to provide them with the rights described in this Section. If you reside in such a State, you have some or all of the rights provided below to the extent required by your State’s privacy law.

A. Right to Know About Personal Information Collected, Disclosed, or Sold

You may have the right to request that we provide certain Personal Information to you about our collection and use of Personal Information that relates to you.  Specifically, you may have the right to request disclosure of:

• Whether we process Personal Information related to you;

• The specific pieces of Personal Information we collected about you;

• The categories of Personal Information we collected about you;

• The categories of sources from which Personal Information was collected;

• Our business or commercial purpose for collecting or disclosing Personal Information; and

• The categories of third parties with whom we shared Personal Information.

B. Right to Request Deletion of Personal Information

You may also have the right to request that we delete Personal Information related to you that we collected or maintain, subject to certain exceptions.

C. Right to Correct Inaccurate Personal Information

You may also have the right to request that we correct inaccurate Personal Information we maintain about you.

D. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not unlawfully discriminate against you for exercising any of your applicable privacy rights. If you exercise these rights, however, you may be unable to use or access certain features of our services.

E. Notice of Right to Opt-Out of Sale/Sharing

You may have the right to opt-out of our further sale or sharing (as those terms are defined by California’s CCPA or equivalent terms provided in other State’s privacy laws) of Personal Information related to you. In some States, the term “Targeted Advertising” is used instead of “Sharing.” Where your State’s privacy law requires us to provide this right, you may to the extent provided by your State’s privacy law exercise this right (i) by making a request as provided in Subsection F, below, or (ii) by using a web browser with Global Privacy Control (“GPC”) enabled.

The GPC is designed to allow Internet users to notify website operators of certain privacy preferences when they visit a website. When enabled, it can signal to the website operator that the individual does not want Personal Information about them to be sold or shared. To learn more about the GPC and how you can use it to opt out of the sale or sharing of personal information about you, you can visit the GPC website here.

We process GPC opt-out preference signals in a frictionless manner.

F. Exercising Your Privacy Rights

To request to exercise your privacy rights described above, where applicable, please submit a verifiable consumer request to us by using the information in the “Contact Us” section below. Only you or your “authorized agent,” as defined and provided by applicable law, may make a verifiable consumer request related to Personal Information related to you. We reserve the right not to respond to requests submitted other than to the “Contact Us” information below..

Your verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.  We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.  We will use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.  Where necessary, we may request additional information about you so that we can verify your identity. Making a verifiable consumer request does not require you to create an account with us. If we cannot verify your identity based on the information provided, we will let you know that we are unable to fulfil your request.

You may use an authorized agent to submit a privacy rights request. Authorized agents may exercise rights on your behalf by submitting a request via email to [email protected] and indicating that they are submitting the request as an agent. When we verify your agent’s request, we may verify both you and your agent’s identity and request a signed declaration from you that authorizes your agent to make the request on your behalf. To protect Personal Information about you, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.

We will attempt to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  Within 10 days of receiving the request, we will confirm receipt and provide information about its verification and processing of the request.  We will, including as required by applicable law, maintain records of consumer requests made pursuant to the CCPA and other applicable law as well as our response to said requests for a period of at least 24 months.

If we decline to take action on your verifiable consumer request you may appeal our decision, except where we declined because we were unable to verify your identity. To make your appeal, please submit a verifiable consumer request to us by using the same process for making your original request. For the appeal, please indicate that you are making an appeal and provide any case identifier or similar information we previously provided to you in connection with the request.

XII. Additional Disclosures for Canadian Residents

This Section XII applies to individuals residing in Canada and supplements the disclosures above. It is made in accordance with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and, where applicable, Quebec’s Act respecting the protection of personal information in the private sector (“Quebec Privacy Act”) and other applicable provincial privacy laws.

A. Accountability. Euna Solutions has designated a privacy officer responsible for our compliance with PIPEDA and other applicable Canadian privacy laws. You may contact our privacy officer using the information provided in the Contact Us section below.

B. Consent. We collect, use, and disclose Personal Information about you with your consent, except where applicable law permits or requires otherwise. By providing Personal Information to us or using our Sites, you consent to our collection, use, and disclosure of your Personal Information as described in this Privacy Policy. You may withdraw your consent at any time as described in Section V above, subject to legal or contractual restrictions.

C. Individual Rights. Subject to applicable law, Canadian residents have the right to: (i) request access to the Personal Information we hold about you and receive an account of how it has been used and disclosed; (ii) challenge the accuracy and completeness of your Personal Information and request that it be corrected or amended; (iii) withdraw consent to our collection, use, or disclosure of your Personal Information, subject to legal or contractual restrictions; and (iv) make a complaint to the applicable privacy authority regarding our handling of your Personal Information.

D. Filing a Complaint. If you are a Canadian resident and have concerns about our privacy practices that we have not resolved to your satisfaction, you have the right to file a complaint with the applicable privacy authority: (i) the Office of the Privacy Commissioner of Canada (www.priv.gc.ca) for matters governed by PIPEDA; or (ii) the Commission d’accès à l’information (www.cai.gouv.qc.ca) for matters governed by the Quebec Privacy Act.

E. Privacy Governance. Euna Solutions maintains internal privacy governance policies and procedures governing how Personal Information is managed within our organization, including policies addressing the collection, use, disclosure, retention, and disposal of Personal Information. These policies are available to individuals upon request by contacting us as described in the Contact Us section below.

XIII. Links to Third Party Websites

If you click on a third-party link within our Sites, you will be taken to another website or platform we do not control. This Privacy Policy does not apply to the privacy practices of that website or platform. Read the third party’s privacy policies carefully. We are not responsible for these third parties.

XIV. Contact Us

You may make these requests by submitting a request via email to [email protected]. We will verify your request by confirming at least two pieces of Personal Information, including contact information you provided in submitting your form. To designate an authorized agent to exercise these rights on your behalf, send an email with your request [email protected].

If you have any questions about this Policy, please email us at [email protected]. For Canadian privacy inquiries, including requests to access or correct Personal Information, withdraw consent, or contact our designated privacy officer, please use the contact information below.

You can also write to us at: 

US OFFICE
1155 Perimeter Center West, Suite 500
Sandy Springs, GA 30338

CANADA OFFICE
603 Michigan Drive, Unit 1
Oakville, ON L6L 0G2

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