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THE DATA WE COLLECT, HOW IT'S USED, AND WHO WE SHARE IT WITH

We care about your privacy and want to help you understand how we collect, use,
and share your personal information.

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Our Policies
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1. Introduction
2. Personal information we collect
3. How we use your personal information
4. Data retention
5. How we share your personal information
6. Your choices
7. Other sites and services
8. Security
9. International data transfer
10. Children
11. Changes to this Privacy Policy
12. How to contact us
13. California Privacy Rights Notice
14. European Notice

WE'RE TAKING A DIFFERENT APPROACH TO PRIVACY

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EFFECTIVE DATE:MARCH 22, 2023

If you are a California resident, refer to section 13 for more information about
your specific privacy rights.

If you are a resident of the European Economic Area ( including European Union
Member States, Iceland, Liechtenstein, and Norway), Switzerland, or the UK,
refer to section 14 for more information about your specific privacy rights.

1. INTRODUCTION

Metadata, Inc., including all of our affiliated companies (“us,” “we,” or “our”)
collects and processes information about you as described in this Privacy
Policy. We are committed to protecting your privacy. This Privacy Policy
contains details about how we collect, use, and share Personal Information that
we obtain from and about you when you interact with us on our website, via
email, and through other online and offline interactions. Please read this
Privacy Policy carefully.

This Privacy Policy describes how Metadata handles personal information that we
collect in the following circumstances:

* through our website www.metadata.io and any other digital properties that
link to this Privacy Policy (the “Site”);
* through the Metadata platform (the “Metadata Platform”) where and to the
extent we use your personal information for our own purposes (e.g., account
creation);
* in connection with the development of our data augmentation and intelligence
services (the “Offerings”); and
* through social media, our marketing activities, our live events and other
activities described in this Privacy Policy, (collectively, the
“Service(s)”).

This Privacy Policy does not apply to:

* information that we process on behalf of our business customers while
providing the Metadata Platform to them (e.g., where business customers
provide customer relationship data to us for us to enrich using our
Offerings). We use personal information we receive from our business
customers solely on the instructions of our business customers, as governed
by our agreements with those business customers. If you have concerns
regarding personal information that we process on behalf of a business,
please direct your concerns to that business; and/or
* information we obtain from third-party sources that does not constitute
“personal information,” “personally identifiable information,” and/or
“personal data” for the purposes of applicable law. The majority of data we
receive from third-party sources in order to develop and enhance our
Offerings does not constitute personal information, personally identifiable
information, and/or personal data.

Our Services are designed for businesses and their representatives. We do not
offer products or services for use by individuals for their personal, family, or
household purposes. Accordingly, we treat all personal information we collect as
pertaining to individuals in their capacities as business representatives and
not their individual capacities.

Metadata may provide additional or supplemental privacy policies to individuals
for specific products or services that we offer at the time we collect personal
information.

2. PERSONAL INFORMATION WE COLLECT

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

* Contact data, such as your first and last name, salutation, email address,
billing and mailing addresses, professional title and company name, and phone
number.
* Professional information, such as your work history, city, state, country of
residence, postal code, age and links to your profiles on social networks.
* Account data, such as the username and password that you may set to establish
an online account on the Services, biographical details, preferences, and any
other information that you add to your account profile.
* Communications that we exchange with you, including when you contact us
through the Services, social media, by phone or video platform or otherwise,
and recordings of the same.
* Transactional data, such as information relating to or needed to complete
your orders on or through the Services, including order numbers and
transaction history.
* Marketing data, such as your preferences for receiving our marketing
communications and details about your engagement with them.
* Payment information needed to complete transactions, including payment card
information or bank account number.
* Promotional information, including information you share when you enter a
competition, promotion or complete a survey. Please note that if you
participate in a sweepstakes, contest or giveaway through the Service, we may
ask you for your Contact Data to notify you if you win or not, to verify your
identity and/or to send you prizes. In some situations, we may need
additional information as a part of the entry process, such as a prize
selection choice. These sweepstakes and contests are voluntary. We recommend
that you read the rules and other relevant information for each sweepstakes
and contest that you enter.
* Other data not specifically listed here, which we will use as described in
this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may obtain personal information about you falling within
one or more of the categories identified above from third-party sources and we
may combine that information with other information we have about you. For
example, we may obtain personal information about you from:

* Public sources, such as government agencies, public records, social media
platforms, and other publicly available sources.
* Private sources, such as our business customers, data providers/data
licensors, information services, social media platforms and other third-party
platforms/services that may be used to log into, or may otherwise be
integrated with or connected to, the Services, and other similar private
sources.
* Marketing partners, such as joint marketing partners and event co-sponsors.

Automatic data collection. We, our service providers, and our business partners
may automatically log information about you, your computer or mobile device, and
your interaction over time with the Services, our communications and other
online services, such as:

* Device data, such as your computer’s or mobile device’s operating system type
and version, manufacturer and model, browser type, screen resolution, RAM and
disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique
identifiers (including identifiers used for advertising purposes), language
settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE,
3G), and general location information such as city, state or geographic area.
* Online activity data, such as pages or screens you viewed, how long you spent
on a page or screen, the website you visited before browsing to the Site,
navigation paths between pages or screens, information about your activity on
a page or screen, access times and duration of access, and whether you have
opened our emails or clicked links within them.
* Location data, such as city, state, and country.

For more information concerning our automatic collection of data, please see our
Cookies Policy.

3. HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information for the following purposes or as otherwise
described at the time of collection:

Service delivery. We may use your personal information to:

* provide, operate, and improve the Services and our business, including
enhancing our Offerings to enable our business customers to target
advertising to their own users and prospects;
* establish and maintain business customer profiles on the Services;
* enable security features of the Services, such as by remembering devices from
which you have previously logged in;
* communicate with you about the Services, including by sending announcements,
updates, security alerts, and support and administrative messages;
* understand your needs and interests, and personalize your experience with the
Services and our communications; and
* provide support for the Services, and respond to your requests, questions and
feedback.

Research and development. We may use your personal information for research and
development purposes, such as to analyze and improve the Services and our
business, including through the use of analytics. For example, we may use
analytics in connection with the Services to understand user activity on the
Services, such as which pages are most and least visited and how visitors move
around the Services, as well as user interactions with our emails.

Marketing and advertising. We, our service providers, and our third-party
advertising partners may collect and use your personal information for marketing
and advertising purposes:

* Direct marketing. We may send our business customers and prospects direct
marketing communications. You may opt-out of our marketing communications as
described in section 6 below.
* Interest-based advertising. We and our third-party advertising partners may
use cookies and similar technologies to collect information about your
interaction (including the data described in the automatic data collection
section above) with the Service, our communications and other online services
over time, and use that information to serve online ads that we think will
interest you. This is called interest-based advertising. We may also share
information about our users with these companies to facilitate interest-based
advertising to those or similar users on other online platforms. You can
learn more about your choices for limiting interest-based advertising in our
Cookies Policy.

Compliance and protection. We may use your personal information to:

* comply with applicable laws, lawful requests, and legal process, such as to
respond to subpoenas or requests from government authorities;
* protect our, your or others’ rights, privacy, safety or property (including
by making and defending legal claims);
* audit our internal processes for compliance with legal and contractual
requirements or our internal policies;
* enforce the terms and conditions that govern the Service; and
* prevent, identify, investigate and deter fraudulent, harmful, unauthorized,
unethical or illegal activity, including cyberattacks and identity theft.

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 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, develop new
services, and promote our business.

4. DATA RETENTION

Retention. We generally retain personal information to fulfill the purposes for
which we collected it, including for the purposes of satisfying any legal,
accounting, or reporting requirements, to establish or defend legal claims, or
for fraud prevention purposes. To determine the appropriate retention period for
personal information, we may consider factors such as the amount, nature, and
sensitivity of the personal information, the potential risk of harm from
unauthorized use or disclosure of your personal information, the purposes for
which we process your personal information and whether we can achieve those
purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you,
we may either delete it, anonymize it, or isolate it from further processing.

5. HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information with the following parties and as
otherwise described in this Privacy Policy or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes
consistent with this Privacy Policy.

Service providers. Third parties that provide services on our behalf or help us
operate the Services or our business (such as hosting, information technology,
customer support, email delivery, marketing, consumer research, and website
analytics).

Payment processors. Any payment card information you use to make a purchase on
the Services is collected and processed directly by our payment processors.

Our business customers. We may enhance or supplement data we receive about you
from a business customer with data we receive from other sources and provide the
enhanced data back to such business customer. Our business customers may combine
the personal information we share with other data they have and may process your
personal information for their own purposes, including their own marketing and
advertising purposes. This Privacy Policy does not apply to, and we are not
responsible for, our business customers’ (or any other third party’s) processing
of personal information. If you have questions concerning the processing of your
information by one of our business customers, please contact the relevant
business customer.

Advertising partners.

* We may provide information regarding our business customers and prospects to
third-party advertising companies for the internet based advertising purposes
described above.
* We may also work with third-party advertising companies in connection with
the provision of the Services to our business customers to enable our
business customers to target advertising. As noted, this Privacy Policy does
not apply to, and we are not responsible for, our business customers’ or any
third party’s processing of personal information.

Business and marketing partners. Third parties with whom we co-sponsor events or
promotions, with whom we jointly offer products or services, or whose products
or services may be of interest to you.

Linked third-party services. If you log into the Services with, or otherwise
link or connect your account to, a social media, customer relationship
management, or other third-party service, we may share your personal information
with that third-party service. The third party’s use of the shared information
will be governed by its privacy policy and the settings associated with your
account with the third-party service.

Professional advisors. Professional advisors, such as lawyers, auditors,
bankers and insurers, where necessary in the course of the professional services
that they render to us.

Authorities and others. Law enforcement, government authorities, and private
parties, as we believe in good faith to be necessary or appropriate for the
compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business
transactions (or negotiations of or due diligence for such transactions)
involving a corporate divestiture, merger, consolidation, acquisition,
reorganization, sale or other disposition of all or any portion of the business
or assets of, or equity interests in, Metadata or our affiliates (including, in
connection with a bankruptcy or similar proceedings).

With your consent. We may share your personal information with any third parties
where you have consented to such sharing.

6. YOUR CHOICES

Access or update your information. If you have registered for an account with us
through the Service, you may review and update certain account information by
logging into the account.

Opt-out of marketing communications. You may opt-out of marketing-related emails
from us by following the opt-out or unsubscribe instructions at the bottom of
the email or by contacting us, see section 12. Please note that if you choose to
opt-out of marketing-related emails, you may continue to receive service-related
and other non-marketing emails. You may have the right to opt-out of receiving
marketing or advertising calls, in which case you may do so during any such call
or by contacting us, see section 12.

Cookies. For information about cookies and other tracking technologies employed
by the Services and how to control them, including your choices with respect to
interest-based advertising, see our Cookies Policy.

Declining to provide information. We need to collect personal information to
provide certain Services. If you do not provide the information we identify as
required or mandatory, we may not be able to provide those Services.

Linked third-party platforms. If you choose to connect to the Services through,
or link or otherwise connect the Services with, your social media account,
customer relationship management platform or other third-party platform, you may
be able to use your settings in your account with that platform to limit the
information we receive from it. If you revoke our ability to access information
from a third-party platform, that choice will not apply to information that we
have already received from that third party.

Delete your content or close your account. You can choose to delete certain
content through your account. If you wish to request to close your account,
please contact us, see Section 12.

Residents of Nevada and Vermont. Certain data sharing we engage in may be
classified under Nevada and Vermont law as a “sale” of your Personal
Information. If you are a resident of Nevada or Vermont, you can request to
opt-out out of the sale of covered personal information here.

7. OTHER SITES AND SERVICES

The Services may contain links to websites, mobile applications, and other
online services operated by third parties. In addition, our content may be
integrated into web pages or other online services that are not associated with
us. These links and integrations are not an endorsement of, or representation
that we are affiliated with, any third party. We do not control websites, mobile
applications, or online services operated by third parties and we are not
responsible for their actions. We encourage you to read the privacy policies of
the other websites, mobile applications, and online services you use.

8. SECURITY

We employ a number of technical, organizational 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.

9. INTERNATIONAL DATA TRANSFER

We are headquartered in the United States and may use service providers that
operate in other countries. Your personal information may be transferred to the
United States or other locations where privacy laws may not be as protective as
those in your state, province, or country.

For more information on how we transfer personal information from the European
Economic Area, United Kingdom, and Switzerland, please see the European Notice
in section 14.

10. CHILDREN

The Services are not intended for use by anyone under 18 years of age. If you
are a parent or guardian of a child from whom you believe we have collected
personal information in a manner prohibited by law, please contact us, see
section 12. If we learn that we have collected personal information through the
Services from a child without the consent of the child’s parent or guardian as
required by law, we will comply with applicable legal requirements to delete the
information.

11. 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 or other appropriate means.
Any modifications to this Privacy Policy will be effective upon our posting the
modified version (or as otherwise indicated at the time of posting). In all
cases, your use of the Service after the effective date of any modified Privacy
Policy indicates your acceptance of the modified Privacy Policy.

12. HOW TO CONTACT US

* Email: privacy@metadata.io
* Mail: Metadata, Inc., 1754 Technology Drive, STE 212, San Jose, California,
95110, United States
* Phone: 415-231-2211

13. CALIFORNIA PRIVACY RIGHTS NOTICE

This section describes how we collect, use, and share Personal Information of
California residents in our capacity as a “business” under the California
Consumer Privacy Act, as amended by the California Privacy Rights Act, (“CPRA”)
and their rights with respect to that Personal Information. For purposes of this
section, the term “Personal Information” has the meaning given in the CPRA but
does not include information exempted from the scope of the CPRA. In some cases,
we may provide a different privacy notice to certain categories of California
residents, such as job applicants, in which case that notice will apply instead
of this section.

Your California privacy rights. California residents have the rights listed
below under the CPRA with respect to their Personal Information. However, these
rights are not absolute, and in certain cases we may decline your request as
permitted by law.

* Information. You can request the following information about how we have
collected and used your Personal Information during the past 12 months:
* The categories of Personal Information that we have collected.
* The categories of sources from which we collected Personal Information.
* The business or commercial purpose for collecting and/or selling Personal
Information.
* The categories of third parties with which we share Personal Information.
* The categories of Personal Information that we sold or disclosed for a
business purpose.
* The categories of third parties to whom the Personal Information was sold
or disclosed for a business purpose.
* Access. You can request a copy of the Personal Information that we have
collected about you.
* Correction. You can ask us to correct inaccurate Personal Information that we
have collected about you.
* Deletion. You can ask us to delete the Personal Information that we have
collected from you.
* Opt-out.
* Opt-out of certain processing of Personal Information for targeted
advertising purposes. You can opt-out of certain processing of personal
information for targeted advertising purposes.
* Opt-out of other sales of personal data. You can opt-out of other sales of
your Personal Information.
* Opt-in. As the Services are intended for users 18 years of age or older, we
do not intentionally collect or sell Personal Information regarding
individuals between the ages of 13 and 15.
* Nondiscrimination. You are entitled to exercise the rights described above
free from discrimination as prohibited by the CPRA.

Exercising your right to information/know, access, correction and deletion. You
may submit requests to exercise your right to information/know, access,
correction or deletion at https://metadata.io/data-request-form/, calling us at
415.231.2211, or via email to privacy@metadata.io.

Notice of right to opt-out of the “sale” or “sharing” of your Personal
Information. Certain data sharing we engage in may be classified under
California law as a “sale” or “sharing” of your Personal Information. You can
request to opt-out out of this “sale” or “sharing” of your personal information
here: https://metadata.io/data-request-form/ or via email at:
privacy@metadata.io.

Verification of identity; authorized agents. We cannot process your request if
you do not provide us with sufficient detail to allow us to understand and
respond to it.

We will need to verify your identity to process your information/know, access,
correction and deletion requests and reserve the right to confirm your
California residency. To verify your identity, we may require government
identification, a declaration under penalty of perjury or other information.

Your authorized agent may make a request on your behalf upon our verification of
the agent’s identity and our receipt of a copy of a valid power of attorney
given to your authorized agent pursuant to California Probate Code Sections
4000-4465. If you have not provided your agent with such a power of attorney,
you must provide your agent with written and signed permission to exercise your
CPRA rights on your behalf, provide the information we request to verify your
identity, and provide us with confirmation that you have given the authorized
agent permission to submit the request.

Financial Incentives. We may offer financial incentives as permitted by the
CPRA. These incentives may result in different prices, rates, levels, or quality
of services. The terms and conditions of any such financial incentive shall be
provided separately to you at the time of the offering.

Personal information that we collect, use and disclose. The chart below
summarizes the Personal Information we collect by reference to the categories of
Personal Information specified in the CPRA (Cal. Civ. Code §1798.140) and
describes our practices currently and during the 12 months preceding the
effective date of this Privacy Policy. The terms in the chart refer to the
categories of information, sources, purposes and third parties described above
in this Privacy Policy in more detail. Information you voluntarily provide to
us, such as in free-form webforms, may contain other categories of personal
information not described below. In addition to the disclosures described in the
chart below, we disclose Personal Information as described in section 5, above.

Statutory category / Personal information we collect in this category

Source of PI

Business/
commercial purpose for collection

Categories of third parties to whom we “disclose” PI for a business purpose

Categories of third parties to whom we “sell”or “share” PI

Identifiers

* Contact data
* Professional information
* Device data

* Third-party sources
* Automatic data collection

* Service delivery
* Research and development
* Compliance and protection
* With your consent
* To create anonymous, aggregated or de-identified data

* Affiliates
* Service providers
* Customers
* Advertising partners
* Business and marketing partners
* Linked third-party services
* Professional advisors
* Authorities and others
* Business transferees
* With your consent

* Customers

Inferences

May be derived from:

* Contact data
* Professional information
* Communications
* Transactional data
* Marketing data
* Promotional information
* Device data
* Online activity data

N/A

* Service delivery
* Research and development
* Marketing and advertising
* Compliance and protection
* With your consent
* To create anonymous, aggregated or de-identified data

* Affiliates
* Service providers
* Customers
* Advertising partners
* Business and marketing partners
* Authorities and others
* Business transferees
* With your consent

* Customers

Internet or other electronic network activity information

* Marketing data
* Device data
* Online activity data
* Location data

* Automatic data collection
* Third-party sources

* Service delivery
* Research and development
* Compliance and protection

* Affiliates
* Service providers
* Customers
* Authorities and others

* Customers

Geolocation data

* Location data

* Automatic data collection
* Third-party sources

* Service delivery
* Research and development
* Marketing and advertising
* Compliance and protection
* With your consent
* To create anonymous, aggregated or de-identified data

* Affiliates
* Service providers
* Customers
* Advertising partners
* Business and marketing partners
* Linked third-party services
* Authorities and others
* Business transferees
* With your consent

* Customers

Professional or Employment Information

* Professional information

* Third-party sources

* Service delivery
* Research and development
* Compliance and protection
* With your consent
* To create anonymous, aggregated or de-identified data

* Affiliates
* Service providers
* Customers
* Linked third-party services
* Authorities and others
* Business transferees
* With your consent

* Customers

Statutory category / Personal information we collect in this category

Identifiers

* Contact data
* Professional information
* Device data

Source of PI

* Third-party sources
* Automatic data collection

Business/
commercial purpose for collection

* Service delivery
* Research and development
* Compliance and protection
* With your consent
* To create anonymous, aggregated or de-identified data

Categories of third parties to whom we “disclose” PI for a business purpose

Categories of third parties to whom we “sell”or “share” PI

* Customers

Statutory category / Personal information we collect in this category

Inferences

May be derived from:

* Contact data
* Professional information
* Communications
* Transactional data
* Marketing data
* Promotional information
* Device data
* Online activity data

Source of PI

N/A

Business/
commercial purpose for collection

* Service delivery
* Research and development
* Marketing and advertising
* Compliance and protection
* With your consent
* To create anonymous, aggregated or de-identified data

Categories of third parties to whom we “disclose” PI for a business purpose

* Affiliates
* Service providers
* Customers
* Advertising partners
* Business and marketing partners
* Authorities and others
* Business transferees
* With your consent

Categories of third parties to whom we “sell”or “share” PI

* Customers

Statutory category / Personal information we collect in this category

Internet or other electronic network activity information

* Marketing data
* Device data
* Online activity data
* Location data

Source of PI

* Automatic data collection
* Third-party sources

Business/
commercial purpose for collection

* Service delivery
* Research and development
* Compliance and protection

Categories of third parties to whom we “disclose” PI for a business purpose

* Affiliates
* Service providers
* Customers
* Authorities and others

Categories of third parties to whom we “sell”or “share” PI

* Customers

Statutory category / Personal information we collect in this category

Geolocation data

* Location data

Source of PI

* Automatic data collection
* Third-party sources

Business/
commercial purpose for collection

* Service delivery
* Research and development
* Marketing and advertising
* Compliance and protection
* With your consent
* To create anonymous, aggregated or de-identified data

Categories of third parties to whom we “disclose” PI for a business purpose

* Affiliates
* Service providers
* Customers
* Advertising partners
* Business and marketing partners
* Linked third-party services
* Authorities and others
* Business transferees
* With your consent

Categories of third parties to whom we “sell”or “share” PI

* Customers

Statutory category / Personal information we collect in this category

Professional or Employment Information

* Professional information

Source of PI

* Third-party sources

Business/
commercial purpose for collection

* Service delivery
* Research and development
* Compliance and protection
* With your consent
* To create anonymous, aggregated or de-identified data

Categories of third parties to whom we “disclose” PI for a business purpose

* Affiliates
* Service providers
* Customers
* Linked third-party services
* Authorities and others
* Business transferees
* With your consent

Categories of third parties to whom we “sell”or “share” PI

* Customers

Annual Consumer Requests Reporting

Below are statistics related to the number of data requests we received under
the CPRA in the year prior to the effective date of this Privacy Policy.

Requests to know

Requests to delete

Requests to opt-out of sale/sharing

Requests to correct

Number of requests received

Number of requests complied with in full

Number of requests complied with in part

Number of requests denied

Mean number of days to substantively respond to requests

Number of requests received

Requests to know

Requests to delete

Requests to opt-out of sale/sharing

Requests to correct

Number of requests complied with in full

Requests to know

Requests to delete

Requests to opt-out of sale/sharing

Requests to correct

Number of requests complied with in part

Requests to know

Requests to delete

Requests to opt-out of sale/sharing

Requests to correct

Number of requests denied

Requests to know

Requests to delete

Requests to opt-out of sale/sharing

Requests to correct

Mean number of days to substantively respond to requests

Requests to know

Requests to delete

Requests to opt-out of sale/sharing

Requests to correct

*Updated March 22, 2023

14. EUROPEAN NOTICE

The information provided in this European Notice section applies only to
individuals in the United Kingdom (“UK”), Switzerland, and the European Economic
Area (“EEA”) (hereafter collectively referred to as “Europe”).

Personal information. References to “personal information” in this Privacy
Policy are equivalent to “personal data” governed by European data protection
legislation, including the “GDPR” (i.e., the General Data Protection Regulation
2016/679 (“EU GDPR”) and the EU GDPR as it forms part of UK law (“UK GDPR”)).
Under the GDPR, personal data is information about an individual, from which
that individual is either directly identified or can be identified. It does not
include ‘anonymous data’ (i.e., information where the identity of the relevant
individual has been permanently removed and that individual is no longer
identified or identifiable).

Controller. Metadata, Inc. is the controller of your personal information
covered by this Privacy Policy for purposes of European data protection
legislation.

Our GDPR Representatives. For users in the EEA or UK, our representatives
appointed under the EU GDPR and UK GDPR respectively are:

EU representative: VeraSafe Ireland Ltd.

Inquiries:
https://verasafe.com/public-resources/contact-data-protection-representative or
via telephone at: +420 228 881 031

UK representative: VeraSafe UK Ltd.

Inquiries:
https://verasafe.com/public-resources/contact-data-protection-representative or
via telephone at: +420 228 881 031

Legal bases for processing. We use your personal information for the purposes
listed below. In respect of each of the purposes for which we use your personal
information, European data protection legislation requires us to ensure that we
have a “legal basis” for that use. Our legal bases for processing your personal
information described in this Privacy Policy are listed below.

* Where we need to perform a contract, we are about to enter into or have
entered into with you (“Contractual Necessity”).
* Where it is necessary for our legitimate interests and your interests and
fundamental rights do not override those interests (“Legitimate Interests”).
More detail about the specific legitimate interests pursued in respect of
each purpose we use your personal information for is set out in the table
below.
* Where we need to comply with a legal or regulatory obligation (“Compliance
with Law”).
* Where we have your specific consent to carry out the processing for the
purpose in question (“Consent”).

We have set out below the legal bases we rely on in respect of the relevant
purposes for which we use your personal information.

Processing purpose

Categories of personal information involved

Legal basis

Service delivery

Contact data

Professional information

Account data

Communications

Transactional data

Payment information

Device data

Online activity data

Contractual Necessity

Legitimate Interests

Consent

* Research and development
* Marketing and advertising purposes
* Compliance and protection purposes
* Sharing your personal information as described in this Privacy Policy

Contact data

Professional information

Account data

Communications

Transactional data

Payment information

Marketing data

Promotional information

Device data

Online activity data

Contractual Necessity

Legitimate Interests

Consent

To comply with applicable law

Any data relevant to comply with applicable law

Compliance with Law

With your consent

Any data for which we are required to obtain consent by applicable law

Consent

Processing purpose

Service delivery

Categories of personal information involved

Contact data

Professional information

Account data

Communications

Transactional data

Payment information

Device data

Online activity data

Legal basis

Contractual Necessity

Legitimate Interests

Consent

Processing purpose

* Research and development
* Marketing and advertising purposes
* Compliance and protection purposes
* Sharing your personal information as described in this Privacy Policy

Categories of personal information involved

Contact data

Professional information

Account data

Communications

Transactional data

Payment information

Marketing data

Promotional information

Device data

Online activity data

Legal basis

Contractual Necessity

Legitimate Interests

Consent

Processing purpose

To comply with applicable law

Categories of personal information involved

Any data relevant to comply with applicable law

Legal basis

Compliance with Law

Processing purpose

With your consent

Categories of personal information involved

Any data for which we are required to obtain consent by applicable law

Legal basis

Consent

Use for new purposes. We may use your personal information for reasons not
described in this Privacy Policy where permitted by law and the reason is
compatible with the purpose for which we collected it. If we need to use your
personal information for an unrelated purpose, we will notify you and explain
the applicable legal basis.

Retention. We retain personal information for as long as necessary to fulfil the
purposes for which we collected it, including for the purposes of satisfying any
legal, accounting, or reporting requirements, to establish or defend legal
claims, or for Compliance and protection purposes.

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

When we no longer require the personal information we have collected about you,
we will either delete or anonymize it or, if this is not possible (for example,
because your personal information has been stored in backup archives), then we
will securely store your personal information and isolate it from any further
processing until deletion is possible. If we anonymize your personal information
(so that it can no longer be associated with you), we may use this information
indefinitely without further notice to you.

Sensitive personal information. We ask that you not provide us with any
sensitive personal information (e.g., social security numbers, information
related to racial or ethnic origin, political opinions, religion or other
beliefs, health, biometrics or genetic characteristics, criminal background, or
trade union membership) on or through the Services, or otherwise to us.

If you provide us with any sensitive personal information to us when you use the
Services, you must consent to our processing and use of such sensitive personal
information in accordance with this Privacy Policy. If you do not consent to our
processing and use of such sensitive personal information, you must not submit
such sensitive personal information through our Services.

Your rights. European data protection laws give you certain rights regarding
your personal information. If you are located in Europe, you may ask us to take
the following actions in relation to your personal information that we hold:

* Access. Provide you with information about our processing of your personal
information and give you access to your personal information.
* Correct. Update or correct inaccuracies in your personal information.
* Delete. Delete your personal information.
* Transfer. Transfer a machine-readable copy of your personal information to
you or a third party of your choice.
* Restrict. Restrict the processing of your personal information.
* Object. Object to our reliance on our legitimate interests as the basis of
our processing of your personal information that impacts your rights.
* Opt-out. Stop sending you direct marketing communications. You may continue
to receive service-related and other non-marketing emails.
* Consent withdrawal. Where we rely on your consent and/or explicit consent to
process your personal information you may withdraw that consent at any time.

You may submit these requests by email to privacy@metadata.io or our postal
address provided in section 12. We may request specific information from you to
help us confirm your identity and process your request. Applicable law may
require or permit us to decline your request. If we decline your request, we
will tell you why, subject to legal restrictions. If you would like to submit a
complaint about our use of your personal information or our response to your
requests regarding your personal information, you may contact us or submit a
complaint to the data protection regulator in your jurisdiction. You can find
your data protection regulator at:
https://edpb.europa.eu/about-edpb/about-edpb/members_en.

Cross-border data transfer. We may share your personal information with third
parties who are based outside Europe. In such circumstances, those parties’
processing of your personal information will involve a transfer your personal
information outside of Europe.

We endeavour to ensure that people to whom we provide your personal information
hold it subject to the standards required by European data protection
legislation. So, whenever we transfer your personal information out of Europe,
we try to ensure a similar degree of protection is afforded to it by making sure
at least one of the following mechanisms is implemented:

* Transfers to territories with an adequacy decision. We may transfer your
personal information to countries or territories whose laws have been deemed
to provide an adequate level of protection for personal data by the European
Commission or UK Government (as and where applicable) from time to time.
* Transfers to territories without an adequacy decision.
* We may transfer your personal information to countries or territories whose
laws have not been deemed to provide an adequate level of protection for
Personal Data by the European Commission or UK Government (as and where
applicable).
* What this means is that the relevant authority(ies) have not adopted an
‘adequacy decision’ to confirm that the relevant laws and practices in that
country or territory are sufficient to ensure an adequate level of
protection for personal data to the standards required by the GDPR – for
example, there is currently no such decision in respect of the United
States.
* However, in these cases:
* we may use specific appropriate safeguards approved by the European
Commission, the UK Information Commissioner’s Office or UK Government (as
and where applicable), which are designed to give personal information
the same protection it has in Europe – for example, requiring the
recipient of personal information to enter into the relevant form of the
so-called ‘Standard Contractual Clauses’ issued or approved from time to
time; or
* in limited circumstances, we may rely on an exception, or ‘derogation’,
which permits us to transfer your information to such country despite the
absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for
example, reliance on your explicit consent to that transfer.

You may contact us using the details under section 12 if you want further
information on the specific mechanism used by us when transferring your personal
information out of Europe.

Our Approach to Privacy
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