Automatic Data Collection.  We may collect certain information automatically when you use the Services.  This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services.  Information we collect may be associated with accounts and other devices. Our Services, such as those related to location data management, may collect precise geolocation information in accordance with applicable law.

In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities.  Unless contrary to applicable law or contractual agreement, we may combine your information with information that other people provide when they use our Services, including, when the option is available, information about you when they tag you.

Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising technologies.  We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services.  Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

Web Analytics Services. We use Google Analytics, a service for the marketing analysis of the site provided by Google, Inc. Google Analytics uses cookies to allow us to see how you use our site, so we can improve your experience. Google’s ability to use and share information collected by Google Analytics about your visits to the site is restricted by the Google Analytics Terms of Use available at http://www.google.com/analytics/terms/us.htmland the Google Privacy Policy available at http://www.google.com/policies/privacy/ . You can prevent Google Analytics from recognizing you on return visits to the site by disabling cookies in your browser. If you prefer to not have data reported by Google Analytics, you can install the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout .

Information from Other Sources. We may obtain information about you from other sources, including, but not limited to, Company affiliates, organizations with a relationship with Company (such as customers, prospects and suppliers), social media sites, organizations providing marketing contacts, publicly available databases, and through other third-party services and organizations to supplement information provided by you.  For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings.  Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, email, profile picture, and your contacts stored in that service.  This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services. The information in this section is further supplemented by the information in Section 7 (Our Use of Automatic Collection Technologies).

With respect to personal data of individuals from the European Economic Area (“EEA”), the United Kingdom (“UK”) or Switzerland, our legal basis for collecting and using the personal data will depend on the personal data concerned and the specific context in which we collect it. Our Company will generally collect personal data from you or a third party only where: (a) we have your consent to do so, (b) where we need the personal data to perform a contract with you (e.g. to deliver the services you have requested), or (c) where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms).

Where required by applicable law, our Company (or the applicable controller) will obtain the consumer’s consent before processing their “special category data” or “sensitive data”. Under GDPR, “special category data” is, unless an exemption applies, personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Under the Virginia Consumer Data Protection Act, “sensitive data” means personal data (a) revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status; (b) genetic or biometric data for the purpose of uniquely identifying a natural person; (c) collected from a known child; or (d) precise geolocation data.

Our Company may use information that we collect about you to:

Fulfill our contract with you and provide you with our Services, such as:

Analyze and improve our Services pursuant to our legitimate interest, such as:

Provide you with additional content and Services, such as:

Contact Information. Your email and phone number may be utilized as described herein or for the purposes for which it was provided, including but not limited to, as a method to contact you, or a username to login to a product.

Use De-identified and Aggregated Information.  We may use personal data and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create. Where required by applicable law, Company publicly commits to maintaining and using de-identified data without attempting to re-identify the data

Share Content with Friends or Colleagues.  Our Services may offer various tools and functionalities.  For example, we may allow you to provide information about your friends or colleagues through our referral services.  Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.

Process Information on Behalf of Our Customers (as processors).   Our customers may choose to use our Services to process certain data of their own, which may contain personal data.  The data that we process through our Services is processed by us on behalf of our customer, and our privacy practices will be governed by the contracts that we have in place with our customers, not this Privacy Policy, other than in respect of data transfer to the United States, as described in International Transfers of your Personal data.

If you have any questions or concerns about how such data is handled or would like to exercise your rights, you should contact the person or entity (i.e., the data controller) who has contracted with us to use the Service to process this data.  Our customers control the personal data in these cases and determine the security settings within the account, its access controls and credentials.  We will, however, provide assistance to our customers to address any concerns you may have, in accordance with the terms of our contract with them.  For a list of our sub-processors, contact us as described below.

We may share your personal data with third parties only in the ways that are described in this Privacy Policy.

Below is a list of categories of personal data (from the California Consumer Privacy Act) we have collected and disclosed about consumers for a business purpose in the past 12 months:

Category A: Identifiers.

Category B: Personal Data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Category D: Commercial information.

Category F: Internet or other electronic network activity.

Category G: Geolocation data.

Category I: Professional or employment-related information.

In addition to any other disclosures described in this Privacy Policy, our disclosures to others may include:

Please note that these third parties may be in other countries where the laws on processing personal data may be less stringent than in your country.

To the extent that a given application supports personal messaging functionality between and among end users, you may receive personal messages from other end users.  You can disable this functionality by using the unsubscribe and other disabling instructions in the given application.

Our Company uses industry-standard technologies when transferring and receiving data exchanged between our Company and other companies to help ensure its security. This site has security measures in place to help protect information under our control from the risk of accidental or unlawful destruction or accidental loss, alteration or unauthorized disclosure or access. However, “perfect security” does not exist on the Internet.  Also, if this website contains links to other sites, our Company is not responsible for the security practices or the content of such sites.

Cross-Device Tracking. Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person. Notice Regarding Third-Party Websites, Social Media Platforms and Software Development Kits. Our Company websites and mobile apps may use third parties, including social media platforms, to present or serve the advertisements that you may see at their platforms and web pages and to conduct research about the advertisements and web usage, and we share personal data about you to enable them to show advertisements on their platforms and web-pages. This Privacy Policy does not cover any use of information that such third parties may have collected from you (unless collected through our Services) or the methods used by the third parties to collect that information. Except where expressly required by applicable law, we do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Our Services may include publicly accessible blogs, forums, social media pages, and private messaging features. By using such Services, you assume the risk that the personal data provided by you may be viewed and used by third parties for any number of purposes. In addition, social media buttons such as Twitter and LinkedIn (that might include widgets such as the “share this” button or other interactive mini-programs) may be on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our site. Your interactions with these features apart from your visit to our site are governed by the privacy policy of the company providing it.

We may use third-party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your personal data for various purposes including to provide analytics services and content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.

S Website Usage Monitoring Consent. Your usage of this website is subject to monitoring by us and our service providers. In addition to traditional analytics collection, we may monitor your usage in other ways. We and/or our service provider(s) may track precise mouse movements or insert code to allow us to use or view session replays. We and/or our service provider(s) may make or receive transcripts of chat communications and service tickets. We and/or our service provider(s) may utilize Facebook pixels or other technology, or pixels, of other advertising, marketing or social media companies, in order to facilitate or engage in advertising or marketing, and provide certain services.

Session data may be shared with third parties by us, and our third-party service providers may be able to collect data on aspects of your session or communications without express notification, or collecting opt-in consent, on the web page where it happens. In the United States, when you agree to the website terms of use, or acknowledge this Privacy Policy, you consent to the collection, usage and disclosure of this information in accordance with our Privacy Policy, and/or where applicable, our service provider’s privacy policy. If you wish to retract your consent and have this information deleted, please contact us via the email provided below.

Whenever applicable, our Company identifies the purposes for which the information is being collected before or at the time of collection. The collection of your personal data will be limited to that which is needed for the purposes identified by our Company. Unless you consent, or we are required by law, we will only use the personal data for the purposes for which it was collected. If our Company will be processing your personal data for another purpose later on, our Company will seek your further legal permission or consent; except where the other purpose is compatible with the original purpose.

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory and tax, accounting or other requirements.

In some circumstances you can ask us to delete your personal data (see Your Privacy Rights below).

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

We are a global company. Information about you may be stored and processed in the European Economic Area, the United States or any other country in which our Company or agents or contractors maintain facilities. Such countries may have laws which are different, and potentially not as protective as the laws of your own country.

Whenever we share personal data originating in the EEA, the UK or Switzerland, or another country with restricted transfers, we will rely on lawful measures to transfer that data, such as the EU standard contractual clauses.

EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF and Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”).

Parea Hub, LLC (“Parea”) complies with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF as set forth by the U.S. Department of Commerce. Parea has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. DPF Principles with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Parea has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. DPF Principles with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.

Parea relies on these certifications as its primary transfer mechanisms for transfers of personal data from the UK, EU and Switzerland to the US for onward transfers of personal data to third parties, and remains liable for damages caused by third parties under the Data Privacy Framework (“DPF”) unless Parea did not cause the event giving rise to damage. The U.S. Federal Trade Commission has jurisdiction over Parea’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov/ .

Pursuant to the Data Privacy Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the Data Privacy Frameworks, should direct their query to hello@parea.click . If requested to remove data, we will respond within a reasonable timeframe. We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to hello@parea.click .

In certain situations, Parea may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Parea’s accountability for personal data that it receives in the United States under the Data Privacy Frameworks and subsequently transfers to a third party is described in the Data Privacy Framework Principles. In particular, Parea remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Parea proves that it is not responsible for the event giving rise to the damage.

In compliance with the Data Privacy Framework Principles, Parea commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Data Privacy Frameworks. European Union, United Kingdom, and Swiss individuals with DPF inquiries or complaints should first contact Parea by email at hello@parea.click .

Parea has further committed to refer unresolved privacy complaints under the Data Privacy Framework Principles to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

Further, Parea commits to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information

Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on  the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the

Swiss-U.S. DPF in the context of employment relationship.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See  https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf .

We do our best to ensure that the personal data we hold and use is accurate. We rely on the customers we do business with to disclose to us all relevant information and to inform us of any changes.