Website Privacy Policy

Effective as of April 17th, 2020

This “Privacy Policy” describes the privacy practices of ActZero, Inc. and our subsidiaries (collectively, “ActZero”, “we”, “us”, or “our”) in connection with the www.actzero.ai website and any other website or mobile application that we own or control and which posts or links to this Privacy Policy (collectively, the “Service”), and the rights and choices available to individuals with respect to their personal information. ActZero may provide additional or supplemental privacy policies, statements or notices to individuals for specific products or services that we offer at the time we collect their personal information. These supplemental privacy policies, statements or notices will govern how we may process the information in the context of the specific product or service.

Table of Contents 1

Privacy Policy Effective for US and Canada 2

Personal Information We Collect 2

How We Use Your Personal Information 4

How We Share your Personal Information 6

Your Consent Is Important to Us 7

Your Choices 7

Other sites, mobile applications and services 8

Security Practices 9

International data transfers 9

Updating Your Personal Information 9

Access to Your Personal Information 9

Children 10

Changes to this Privacy Policy 10

How to Contact Us 11

Privacy Policy Effective for US and Canada

It is our policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and / or an individual’s right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of the federal, state and provincial privacy laws of Canada and the United States, as applicable.

This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact our Privacy Officer for more information.

This Privacy Policy does not create or confer upon any individual any rights, or impose upon ActZero any obligations outside of, or in addition to, any rights or obligations imposed by the federal, state and provincial privacy laws of the United States and Canada, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and such privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

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Personal Information We Collect

Information you provide to us. Personal information you provide to us through the Service or otherwise may include:

Business and personal contact information, such as your first and last name, email and mailing addresses, phone number, professional title and company name.
Content you choose to upload to the Service, such as text, images, audio, and video, along with the metadata associated with the files you upload.
Profile information, such as your username and password that you may set to establish an online account with us, your photograph, interests, and preferences.
Registration information, such as information that may be related to a service, an account or an event for which you register.
Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
Demographic Information, such as your city, state, country of residence, postal code, and age.
Usage information, such as information about how you use the Service and interact with us, including information associated with any content you upload to the websites or otherwise submit to us, and information you provide when you use any interactive features of the Service.
Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from social media platforms.

We may maintain pages for ActZero on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

Information we obtain from other third parties.

We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers for the purposes described in this Privacy Policy.

Cookies and Other Information Collected by Automated Means

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Service, including but not limited, your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and other personal information. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications. We may use this information to monitor our website’s performance, including: (i) customizing certain content that we think you might like based on your usage patterns; (ii) improving our products and services; and (iii) upgrading our website.
On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies, and our emails may also contain web beacons.
A “cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Browser web storage, or LSOs, are used for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. A “web beacon,” also known as a pixel tag or clear GIF, is typically used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of our websites.
Web browsers may offer users of our websites or mobile apps the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly. Please see the “Targeted online advertising” section for information about how to exercise choice regarding the use of browsing behavior for purposes of targeted advertising.

Referrals

Users of the Service may have the opportunity to refer contacts to us. If you are an existing user of our service, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.

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How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To operate the Service.

We may use your personal information to:
provide, operate and improve the Service;
provide information about our products and services;
establish and maintain your user profile on the Service;
enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously accessed the Service;
communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages;
communicate with you about events or contests in which you participate;
understand your needs and interests, and personalize your experience with the Service and our communications;
provide support and maintenance for the Service; and
respond to your requests, questions and feedback.

For research and development.

We may analyze use of the Service to improve the Service and to develop new products and services, including by studying user demographics and use of the Service.

To send you marketing and promotional communications.

We may send you ActZero-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below.

To display advertisements.

We may work with advertising partners to display advertisements on the Service or elsewhere online. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Service or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising.”

To comply with law.

We may use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety.

We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent.

In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data.

We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the information personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

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How We Share your Personal Information

We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:

Affiliates.

We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers.

We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate our business (such as customer support, hosting, analytics, payment processing, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

Partners.

We may share your personal information with partners, specifically resellers, for the purposes of assisting us in the distribution of our service.

Other Users of the Service and the Public.

We may provide functionality that enables you to disclose personal information to other users of the Service or the public. For instance, you may be able to submit content to the Service (such as comments, reviews, surveys, blogs, photos, and videos), and we will display your name, username, and a link to your user profile along with the content you submit. We do not control how other users or third parties use any personal information that you make available to such users or the public.

Professional advisors.

We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety.

We may share your personal information for the compliance, fraud prevention and safety purposes described above.

Business transfers.

We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

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Your Consent Is Important to Us

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.

As above, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

We assume that, unless you advise us otherwise, that you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

Please note that we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

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Your Choices

In this section, we describe the rights and choices available to all users.

Access or Update Your Information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.
Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at privacy@actzero.ai. You may continue to receive service-related and other non-marketing emails.
Cookies and Browser Web Storage. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Service and third party websites. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Sites may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.
Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Service may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.
Users may opt-out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.
If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt-out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.

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Other sites, mobile applications and services

The Service may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

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Security Practices

The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

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International data transfers

We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to Canada and the United States. As such, your personal information may potentially be accessible to law enforcement and national security authorities of that jurisdiction.

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Updating Your Personal Information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

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Access to Your Personal Information

You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact the office of our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

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Children

The Service is not directed to, and we do not knowingly collect personal information from, anyone under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable. We encourage parents with concerns to contact us.

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Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Service.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

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How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to our Privacy Officer at privacy@actzero.ai. You may also write to us via postal mail at:

ActZero, Inc.

Attn: Legal – Privacy Officer

2882 Sand Hill Road, Suite 115

Menlo Park, CA 94025