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INCENTIFY PRIVACY POLICY

We at Incentify ("Company," "Incentify", "we," "us," "our") know that our users ("you," "your") care about how your personal information and company data is used and shared, and we take your privacy very seriously. By visiting or using our Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways. Any capitalized terms used herein without definition shall have the meaning given to them in the Incentify Terms of Use (which is located in the footer section of our System).

1 - WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy ("Privacy Policy") applies to our sites, products and services (collectively, "Services") and covers our treatment of both personally identifiable information ("Personal Information") and the services content and client data ("Client Data") that we gather through use of our Services. You can access the Services in many ways, including from a computer or mobile phone, and this Privacy Policy will apply regardless of the means of access. This Privacy Policy does not apply to the privacy policies or practices of third-party sites or of companies we do not own or control. You should always check the privacy policies of third-party sites and your privacy settings.

2 - WHAT INFORMATION IS COLLECTED?

2.1 - Personal Information

We only collect four data points of Personal Information in connection to using our Services: (1) your name, (2) your email address, (3) your location, and (4) potentially your phone number. This Personal Information is used only for authentication and logging into our Services. You can choose not to provide us with certain information, but then you may not be able to register with us or to take advantage of some of our features.

2.2 - Client Data

We receive and store any information you knowingly provide to us. All Client Data is encrypted end-to-end (at rest and in transit) and follows both domestic and EU security best practices.

a. Web Browser Cookies:

Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser including your IP address, "cookie" information, and the page you requested. "Cookies" are identifiers we transfer to your computer or mobile device that allow us to recognize your browser or mobile device and tell us how and when pages in our Services are visited and by how many people. You may be able to change the preferences on your browser or mobile device to prevent or limit your computer or device's acceptance of cookies, but this may prevent you from taking advantage of some of our system features.

Additionally, if you click on a link to a third-party website, such third party may also transmit cookies to you. This Privacy Policy does not cover the use of cookies by any third parties.

b. Statistics Collected:

When we collect usage information (such as the numbers and frequency of visitors to Services), we only use this data in aggregate form, and not in a manner that would identify you personally. For example, this aggregate data tells us how often users visit parts of the System, so that we can make services appealing to as many users as possible. We may also provide this aggregate information to our partners; our partners may use such information to understand how often and in what ways people use our System. We never disclose aggregate information to a partner in a manner that would identify you personally.

c. Age Requirements:

We do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register for the Services (as that term is defined in our Terms of Use). If you are under 18, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 18 may provide any personal information to us or on the Services. In the event that we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us at 213-315-1034.

3 - HOW IS PERSONAL INFORMATION PROCESSED?

Personal Information is only used for authentication purposes and is immediately encrypted and Pseudonymized. Personal Information is collected only for the relevant and specific purpose of authenticating the user. Personal Information will only be kept as it necessary for authentication and only stored for the period of time needed to authenticate the user. We make best efforts to keep Personal Information up-to-date and will delete any known inaccurate information. It should go without saying, Personal Information is never processed in a manner that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or any personal data including, but not limited to, personal health, relationships, sex life, sexual orientations, genetics or biometric data. Finally, no automated decision-making or logic is involved in the processing of your Personal Information.

4 - IS MY INFORMATION SECURE?

Technical, physical and organizational measures are taken to prevent unauthorized access, unlawful processing and unauthorized or accidental loss, destruction or damage to Personal Information and Client Data. Personal Information is never accessed, printed or forwarded. In case of any such violation with respect to Client Data Personal Information, we will take appropriate steps to end the violation and determine liabilities in accordance with applicable law and will cooperate with the competent authorities. If any collection, storage or processing of Client Data or Personal Information is now, or in the future, considered to result in a high-risk to the rights and freedoms of users, we will, prior to any new process, carry out an assessment of the impact and ensure protections are in place.

Your Services profile is protected by a password for your privacy and security. You must prevent unauthorized access to your profile and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your profile. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

5 - WHAT IS YOUR DELETION POLICY?

We always and completely delete any of your Client Data or Personal Information upon request. If a client requests to have their data removed (for example, upon termination their contract), Incentify deletes all active data from its system/database. Our Chief Technology Officer then does a manual check to verify that all Client Data and Personal Information has been removed. Requests for data deletion are completed within 30 calendar days of the request. Client accounts that have been closed after a Trial Period or License expiration may remain for additional 30 days if the Sales Team has not confirmed an intent to terminate.

6 - DO YOU SHARE INFORMATION?

We never rent or sell your Client Data, or Personal Information in personally identifiable form, to anyone. We share your Client Data and Personal Information in personally identifiable form with third parties only as described below.

6.1 - User Profiles and Submissions

Certain user profile information, including without limitation a user's name, location, and any video or image content that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for Company's services. Your account privacy settings allow you to limit the other users who can see the Personal Information in your user profile and/or what information in your user profile is visible to others. Any content you upload to your public user profile, along with any Personal Information or content that you voluntarily disclose online in a manner that other users can view (on discussion boards, in messages and chat areas, etc.), becomes publicly available, and can be collected and used by others. Your user name may also be displayed to other users if and when you send messages or comments or upload images or videos through the Services.

6.2 - Business Transfers

If we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be transferred to or acquired by a third party.

6.3 - Protection of Company and Others

We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

7 - DO YOU ASK MY CONSENT?

Yes, we acquire consent to use your Personal Information when you create a profile with our Services. You can revoke consent at any time by emailing support@incentify.com.

Except as set forth above, you will be notified if your Personal Information ever needs to be shared with third parties in a personally identifiable form and will be able to prevent the sharing of this information.

8 - WHAT CHOICES DO I HAVE?

You can always opt not to disclose Personal Information, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

9 - WHAT NOTIFICATIONS WILL I RECEIVE?

We will notify you anytime this Privacy Policy is updated. Use of Personal Information and Client Data we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use Personal Information, we will notify you by posting an announcement on our Services or sending you an email. You are bound by any changes to the Privacy Policy when you use the Services after such changes have been first posted.

We may also contact you, by email or other means, to communicate with you about the use of our Services. We may send you promotional offers on behalf of other businesses we work with in relation to our Services. If you do not want to receive email or other mail from us, please indicate your preference by emailing us at support@incentify.com. Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the Services, and you are responsible for reviewing such legal notices for changes.

10 - HOW DO I ASK QUESTIONS OR REPORT PROBLEMS?

If you have a critical concern about your Personal Information or a Data Breach, email emergency@incentify.com or call 310-974-3435.

If you have any questions about viewing or updating information we have on file about you, please email support@incentify.com or contact us at 310-974-3435. Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties (if any) for marketing purposes and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit an email request to support@incentify.com.

Complaints regarding data protections and/or Personal Information for U.S. users can be reported to the attorney general at http://oag.ca.gov (for California), or the Office of Civil Rights (OCR) at 1-866-627-7748. International users under Article 77 of GDPR are encouraged to lodge a complaint with their national Data Protection Authority at http://www.dsb.gv.at/.

Last Updated: April 2020