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Text Content

AVOXI, Inc. Websites, Apps, and Services collects some Personal Data from its
Users.

This document contains a section dedicated to California consumers and their
privacy rights.

This document contains a section dedicated to Virginia consumers and their
privacy rights.

This document can be printed for reference by using the print command in the
settings of any browser.

OWNER AND DATA CONTROLLER

AVOXI, Inc.
300 Galleria Parkway, Suite 1040
Atlanta, GA 30339 USA
Policy Effective Date: 25 MAY 2018

Owner contact email: privacy@avoxi.com

TYPES OF DATA COLLECTED

Among the types of Personal Data that AVOXI, Inc. Websites, Apps, and Services
collects, by itself or through third parties, there are: Cookies; Usage Data;
first name; last name; phone number; company name; address; state; email
address; city; various types of Data; geographic position; workplace; financial
information; Data communicated while using the service.

Complete details on each type of Personal Data collected are provided in the
dedicated sections of this privacy policy or by specific explanation texts
displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data,
collected automatically when using AVOXI, Inc. Websites, Apps, and Services.
Unless specified otherwise, all Data requested by AVOXI, Inc. Websites, Apps,
and Services is mandatory and failure to provide this Data may make it
impossible for AVOXI, Inc. Websites, Apps, and Services to provide its services.
In cases where AVOXI, Inc. Websites, Apps, and Services specifically states that
some Data is not mandatory, Users are free not to communicate this Data without
consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to
contact the Owner.
Any use of Cookies – or of other tracking tools – by AVOXI, Inc. Websites, Apps,
and Services or by the owners of third-party services used by AVOXI, Inc.
Websites, Apps, and Services serves the purpose of providing the Service
required by the User, in addition to any other purposes described in the present
document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or
shared through AVOXI, Inc. Websites, Apps, and Services and confirm that they
have the third party's consent to provide the Data to the Owner.

MODE AND PLACE OF PROCESSING THE DATA

METHODS OF PROCESSING

The Owner takes appropriate security measures to prevent unauthorized access,
disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools,
following organizational procedures and modes strictly related to the purposes
indicated. In addition to the Owner, in some cases, the Data may be accessible
to certain types of persons in charge, involved with the operation of AVOXI,
Inc. Websites, Apps, and Services (administration, sales, marketing, legal,
system administration) or external parties (such as third-party technical
service providers, mail carriers, hosting providers, IT companies,
communications agencies) appointed, if necessary, as Data Processors by the
Owner. The updated list of these parties may be requested from the Owner at any
time.

LEGAL BASIS OF PROCESSING

The Owner may process Personal Data relating to Users if one of the following
applies:

* Users have given their consent for one or more specific purposes. Note: Under
some legislations the Owner may be allowed to process Personal Data until the
User objects to such processing (“opt-out”), without having to rely on
consent or any other of the following legal bases. This, however, does not
apply, whenever the processing of Personal Data is subject to European data
protection law;
* provision of Data is necessary for the performance of an agreement with the
User and/or for any pre-contractual obligations thereof;
* processing is necessary for compliance with a legal obligation to which the
Owner is subject;
* processing is related to a task that is carried out in the public interest or
in the exercise of official authority vested in the Owner;
* processing is necessary for the purposes of the legitimate interests pursued
by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that
applies to the processing, and in particular whether the provision of Personal
Data is a statutory or contractual requirement, or a requirement necessary to
enter into a contract.

PLACE

The Data is processed at the Owner's operating offices and in any other places
where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the
User's Data to a country other than their own. To find out more about the place
of processing of such transferred Data, Users can check the section containing
details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a
country outside the European Union or to any international organization governed
by public international law or set up by two or more countries, such as the UN,
and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the
relevant sections of this document or inquire with the Owner using the
information provided in the contact section.

RETENTION TIME

Personal Data shall be processed and stored for as long as required by the
purpose they have been collected for.

Therefore:

* Personal Data collected for purposes related to the performance of a contract
between the Owner and the User shall be retained until such contract has been
fully performed.
* Personal Data collected for the purposes of the Owner’s legitimate interests
shall be retained as long as needed to fulfill such purposes. Users may find
specific information regarding the legitimate interests pursued by the Owner
within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever
the User has given consent to such processing, as long as such consent is not
withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a
longer period whenever required to do so for the performance of a legal
obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore,
the right of access, the right to erasure, the right to rectification and the
right to data portability cannot be enforced after expiration of the retention
period.

THE PURPOSES OF PROCESSING

The Data concerning the User is collected to allow the Owner to provide its
Service, comply with its legal obligations, respond to enforcement requests,
protect its rights and interests (or those of its Users or third parties),
detect any malicious or fraudulent activity, as well as the following:
Remarketing and behavioral targeting, Backup saving and management, Contacting
the User, Displaying content from external platforms, Tag Management, User
database management, Interaction with external social networks and platforms,
Platform services and hosting, Analytics, Handling payments, Data transfer
outside the EU, Location-based interactions, Hosting and backend infrastructure,
Registration and authentication, Marketing, Access to third-party accounts,
Information collection, Managing landing and invitation pages, Content
performance and features testing (A/B testing), Connecting Data, Advertising,
Managing contacts and sending messages, Heat mapping and session recording,
Handling activities related to productivity, Handling finance and accounting,
Collection of privacy-related preferences and Interaction with live chat
platforms.

For specific information about the Personal Data used for each purpose, the User
may refer to the section “Detailed information on the processing of Personal
Data”.

DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA

Personal Data is collected for the following purposes and using the following
services:

* ACCESS TO THIRD-PARTY ACCOUNTS

This type of service allows AVOXI, Inc. Websites, Apps, and Services to
access Data from your account on a third-party service and perform actions
with it.
These services are not activated automatically, but require explicit
authorization by the User.

ZIPWHIP SMS

Revised and Effective: December 9, 2017

Version 2.3

Zipwhip, Inc. (“Company“) appreciates your trust and is committed to
protecting your privacy. We have prepared this Privacy Policy to describe to
you what data we collect, why we do so, and what we do with it. It applies to
the personal information we collect from users of our website located at
https://www.zipwhip.com(the “Site“), our Application Program Interfaces
(collectively the “API“), our downloadable software applications (to include
mobile applications) (each, an “Application“), and online services available
therein (the “Services“).

Questions; Contacting Company; Reporting Violations. If you have any
questions or concerns or complaints about our Privacy Policy or our data
collection or processing practices, or if you want to report any security
violations to us, please contact us at the following address or phone number:
Zipwhip, Inc.

1501 1st Ave South
Suite 500
Seattle, WA 98134

1-855-ZIPWHIP (947-9447)

Types of Data We Collect.
(a) We collect personal information from users or prospective customers
during their use of the website, use of our products, or communication with
our employees. This includes: (1) basic data passed during text message
transmission (including, but not limited to, message content, photos, files,
and message count/volume), (2) information entered in website forms or when
creating or using accounts, (3) mobile device information including mobile
devise identification, service provider, and location, (4) payment
information, and (5) information or feedback provided through e-mail, voice,
letter, or online posting. We also collect data (including phone number,
transmission, and message data) from general text messaging users who send
messages to users of Company Services.

(b) We also collect information using technology. We gather (1) clicking,
browsing, and use data/patterns (including, but not limited to, information
gathered through “cookies” and “pixel tags” as well as information about your
IP address, browser, internet service provider, pages, operating system,
date/time stamps, and clickstream data), (2) information about your mobile
device, use of our app, or app performance and (3) information (via “pixel
tags”) about how emails we have sent have been accessed. Third-party
advertisers or data analytics providers also gather similar information
and/or match this information to that from other sources.

Use of Your Information
(a) General Use. In general, personal information you submit to us is used to
provide the Services, for our direct marketing purposes, to respond to
requests that you make, or to aid us in serving you better. We will also use
the information to contact you via e-mail or phone call for (1) phone number
verification, (2) marketing/promotional purposes, (3) enrollment/activation
activities, (5) response to your request/inquiry, (6) encouraging or enabling
your use of the Services including, but not limited to, specific features,
(7) billing inquiries, (8) to address possible inappropriate use, or at our
Company”s discretion, (9) to provide users material updates related to the
Services.

(b) User Feedback. If you provide us with feedback, we may post it on the
Site or our blog from time to time. (We love to share positive customer
experiences!) If we desire to post your full first and full last name along
with the feedback, we will ensure that we obtain your consent prior to
posting.

(c) Creation of Anonymous Data. We may create anonymous data records from
personal information by excluding information that makes the data personally
identifiable to you or your business. We reserve the right to use anonymous
data for any purpose and disclose anonymous data to third parties in our sole
discretion.

Disclosure of Your Personal Information. We disclose your personal
information as described below and as described elsewhere in this Privacy
Policy.
(a) Third Parties Designated by You. When you use the Services, the personal
information you provide will be shared with the third parties that You
designate to receive it (for example, the person you are texting).

(b) Third Party Service Providers. We may share your personal information
with third party service providers: (1) to provide you with the Services that
we offer you through our Site, (2) to enable message transmission, (3) to
conduct quality assurance testing or audits, (4) for our own marketing
purposes, (5) to facilitate enrollment and creation of accounts, (6) to
provide technical support, (7) to facilitate data storage, (8) for billing,
(9) to manage sales accounts, and/or (10) to provide other services to our
Company. These third-party service providers are required to not use your
personal information other than to provide the services requested by our
Company.

(c) Public Profile. Profile information, such as your profile photo, name,
and telephone number, may be shared between users of Zipwhip Services when
communicating via text-enabled landlines.

(d) Corporate Restructuring. We may share some or all of your personal
information in connection with or during negotiation of any merger or change
in ownership of all or a portion of our business or assets.

(e) Marketing. Personal information will not be used for third party
marketing purposes with the following exceptions: (1) Third party analytics
companies or advertisers on our website may collect and use information via
their own technical tools such as cookies. This policy does not apply to, and
we are not responsible for, cookies used by analytics companies or in third
party ads. We encourage you to check the privacy policies of advertisers
and/or ad services to learn about their use of cookies and other
technologies. If you would like more information about this practice and to
know your choices about not having this information used by these companies,
click here: http://www.networkadvertising.org. And, (2) third parties may
track and record user clicking/browsing data as related to retargeting
display adds.

(f) Other Disclosures. Regardless of any choices you make regarding your
personal information (as described below), our Company may disclose your
personal information if it believes in good faith that such disclosure is
necessary (i) in connection with any legal investigation; (ii) to comply with
relevant laws or to respond to subpoenas or warrants served on Company; (iii)
to protect or defend the rights or property of Company or users of the
Application or Services; and/or (iv) to investigate or assist in preventing
any violation or potential violation of the law, this Privacy Policy, or our
Terms of Use.

Your Choices Regarding Your Information. You have several choices regarding
use of information on our Services:
(a) Email Communications. You may indicate a preference to stop receiving
further marketing e-mail from us and may “opt-out” by following the
unsubscribe instructions provided in the e-mail you receive or by contacting
us directly (please see contact information below). Despite your indicated
e-mail preferences, we may send you service related communications.

(b) Changing Your Personal Information. You may change certain elements of
personal information in your Account by logging into the Site. You may
requested deletion of your personal information by us, and at our discretion,
we may use commercially reasonable efforts to honor your request; but, please
note that we may be required to keep such information and not delete it (or
to keep this information for a certain time, in which case we will comply
with your deletion request only after we have fulfilled such requirements).
When we delete any information, it will be deleted from the active database,
but may remain in our archives. We may also retain your information for fraud
prevention or similar purposes.

Security of Your Personal information. Your security matters to us. We use a
variety of security technologies and procedures designed to help protect your
personal information from unauthorized access, use, or disclosure.
Information from Children. From time to time as part of a special Zipwhip
promotion, such as “texting to Santa,” we may request information from
children under 13 years of age. We will take all necessary steps to protect
the privacy and safety of any child participating in these activities in
accordance with the Children’s Online Privacy Protection Act (COPPA).
Obtaining Verifiable Parental Consent. We will use reasonable effort to
obtain verifiable parental consent prior to the collection and use of
personally identifiable information from children under 13. The method of
parental consent verification may vary according to the event in which the
child wishes to participate. Means of obtaining such consent may include, but
are not limited to, offline consent such as printing and submitting a
permission form by mail or fax or online consent that contains information
that enables Zipwhip to verify the identity of the parent.
Parental Review. Zipwhip will allow parents to review any personal
information collected from their children, based on verifying the identity of
the consenting parent. Parents may revoke their consent and delete
information collected from their children at their discretion. In such event,
Zipwhip will then stop collecting, using, or disclosing information from that
child, and will end that child’s participation in that event.
When Parental Consent is not Required. We do not require parental consent in
order to collect and use information texted to Zipwhip to:
Respond more than once directly to a specific request from a child and not
used to re-contact the child beyond the scope of the child’s request (e.g. a
response to a child’s text to Santa);
Request the name or online contact information of a parent for the sole
purpose of obtaining a verifiable parental consent or providing parental
notification; or
Respond directly to a child’s request on a one-time basis to a specific
request where the information is not used for purposes other than the event
(e.g. Santa’s response to a child’s text request).
Texts received from children under the age of 13 will not be used for any
purpose unrelated to a particular event; each will only be stored long enough
to complete the event and will be promptly deleted thereafter from Zipwhip
databases.

Changes to This Privacy Policy. This Privacy Policy is subject to occasional
revision. When changes are made, the Company will make a new copy of the
Privacy Policy available at the Site. Any changes to this Privacy Policy will
be effective upon thirty (30) calendar days following our posting of the
changes on our Site. These changes will be effective immediately for new
users of our Service. If you do not wish to permit changes in our use of your
personal information, you must notify us prior to the effective date of the
changes that you wish to deactivate your Account with us. Continued use of
our Site, Application or Service, following notice of such changes shall
indicate your acknowledgement of such changes and agreement to be bound by
the terms and conditions of such changes.

This processing constitutes:

* a sale according to the CCPA and the VCDPA
* a sharing according to the CCPA
* targeted advertising according to the VCDPA

* ADVERTISING

This type of service allows User Data to be utilized for advertising
communication purposes. These communications are displayed in the form of
banners and other advertisements on AVOXI, Inc. Websites, Apps, and Services,
possibly based on User interests.
This does not mean that all Personal Data are used for this purpose.
Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they
may use the behavioral retargeting technique, i.e. displaying ads tailored to
the User’s interests and behavior, including those detected outside AVOXI,
Inc. Websites, Apps, and Services. For more information, please check the
privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such
tracking. In addition to any opt-out feature offered by any of the services
below, Users may learn more on how to generally opt out of interest-based
advertising within the dedicated section "How to opt-out of interest-based
advertising" in this document.

LINKEDIN ADS (LINKEDIN CORPORATION)

LinkedIn Ads is an advertising service provided by LinkedIn Corporation.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy – Opt out.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA
* a sharing according to the CCPA
* targeted advertising according to the VCDPA

MICROSOFT ADVERTISING (MICROSOFT CORPORATION)

Microsoft Advertising is an advertising service provided by Microsoft
Corporation.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA
* a sharing according to the CCPA
* targeted advertising according to the VCDPA

* ANALYTICS

The services contained in this section enable the Owner to monitor and
analyze web traffic and can be used to keep track of User behavior.

ANALYTICS COLLECTED DIRECTLY (AVOXI, INC. WEBSITES, APPS, AND SERVICES)

AVOXI, Inc. Websites, Apps, and Services uses an internal analytics system
that does not involve third parties.

Personal Data processed: Cookies; Usage Data.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the VCDPA

GOOGLE ADS CONVERSION TRACKING (GOOGLE INC.)

Google Ads conversion tracking is an analytics service provided by Google
Inc. that connects data from the Google Ads advertising network with actions
performed on AVOXI, Inc. Websites, Apps, and Services.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

GOOGLE ANALYTICS (GOOGLE INC.)

Google Analytics is a web analysis service provided by Google Inc.
(“Google”). Google utilizes the Data collected to track and examine the use
of AVOXI, Inc. Websites, Apps, and Services, to prepare reports on its
activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of
its own advertising network.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

WORDPRESS STATS (AUTOMATTIC INC.)

Wordpress Stats is an analytics service provided by Automattic Inc.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

FULLSTORY

Anonymous Data – Analytics
Google Analytics: Company uses Google Analytics as a web analytics tool to
track user behavior on its marketing Site. Google Analytics collects
anonymized information in accordance with its Privacy Policy. However, if you
do not want Google Analytics to track your behavior on the Platform, you may
opt-out by installing Google Analytics Opt-out Browser Add-on.

FullStory: Company utilizes FullStory for tracking user-driven events in the
web application. FullStory collects information in accordance with its
FullStory Privacy Policy. You can opt-out of FullStory automatic retention of
data collected by clicking here: FullStory Opt Out. If you get a new
computer, install a new browser, erase or otherwise alter your browser's
cookie file (including upgrading certain browsers) you may also clear the
FullStory opt-out cookie.

https://www.fullstory.com/optout/

This processing constitutes:

* a sale according to the CCPA and the VCDPA
* a sharing according to the CCPA
* targeted advertising according to the VCDPA

FULLSTORY (FULLSTORY, INC.)

FullStory is an analytics and heat mapping service provided by FullStory,
Inc.
FullStory maps how frequently Users interact with the different areas of
AVOXI, Inc. Websites, Apps, and Services, allowing the Owner to draw
conclusions about their interests and preferences. FullStory further allows
for the recording of mapping sessions making them available for later visual
playback.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy – Opt out.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

FACEBOOK ADS CONVERSION TRACKING (FACEBOOK PIXEL) (META PLATFORMS, INC.)

Facebook Ads conversion tracking (Facebook pixel) is an analytics service
provided by Meta Platforms, Inc. that connects data from the Meta advertising
network with actions performed on AVOXI, Inc. Websites, Apps, and Services.
The Facebook pixel tracks conversions that can be attributed to ads on
Facebook, Instagram and Audience Network.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

TWITTER ADS CONVERSION TRACKING (TWITTER, INC.)

Twitter Ads conversion tracking is an analytics service provided by Twitter,
Inc. that connects data from the Twitter advertising network with actions
performed on AVOXI, Inc. Websites, Apps, and Services.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

* BACKUP SAVING AND MANAGEMENT

This type of service allows the Owner to save and manage backups of AVOXI,
Inc. Websites, Apps, and Services on external servers managed by the service
provider itself. The backups may include the source code and content as well
as the data that the User provides to AVOXI, Inc. Websites, Apps, and
Services.

BACKUP ON GOOGLE DRIVE (GOOGLE INC.)

Google Drive is a service to save and manage backups provided by Google Inc.

Personal Data processed: various types of Data as specified in the privacy
policy of the service.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

* COLLECTION OF PRIVACY-RELATED PREFERENCES

This type of service allows AVOXI, Inc. Websites, Apps, and Services to
collect and store Users’ preferences related to the collection, use, and
processing of their personal information, as requested by the applicable
privacy legislation.

IUBENDA COOKIE SOLUTION (IUBENDA SRL)

The iubenda Cookie Solution allows the Owner to collect and store Users’
preferences related to the processing of personal information, and in
particular to the use of Cookies and other Trackers on AVOXI, Inc. Websites,
Apps, and Services.

Personal Data processed: Tracker.

Place of processing: Italy – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

IUBENDA CONSENT SOLUTION (IUBENDA SRL)

The iubenda Consent Solution allows to store and retrieve records of Users’
consent to the processing of Personal Data, and information and preferences
expressed in relation to the provided consent.
In order to do so, it makes use of a Tracker that temporarily stores pending
information on the User’s device until it is processed by the API. The
Tracker (a browser feature called localStorage) is at that point deleted.

Personal Data processed: Data communicated while using the service; Tracker.

Place of processing: Italy – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

“DO NOT SELL MY PERSONAL INFORMATION” LINK

As a requirement under the consumer’s right to opt-out, below we provide an
easily accessible, clear, and conspicuous “Do Not Sell My Personal
Information” link.

Do Not Sell My Personal Information

When clicked, this link will display a dialog where you can confirm you're
intending to opt-out of the sale of their personal information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA
* a sharing according to the CCPA
* targeted advertising according to the VCDPA

* CONNECTING DATA

This type of service allows the Owner to connect Data with third-party
services disclosed within this privacy policy.
This results in Data flowing through these services, potentially causing the
retention of this Data.

ZAPIER (ZAPIER, INC.)

Zapier is a workflow automation service provided by Zapier, Inc. that
automates the movement of Data between (third-party) services.

Personal Data processed: company name.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: commercial
information.

This processing constitutes:

* a sale according to the CCPA

* CONTACTING THE USER

CONTACT FORM (AVOXI, INC. WEBSITES, APPS, AND SERVICES)

By filling in the contact form with their Data, the User authorizes AVOXI,
Inc. Websites, Apps, and Services to use these details to reply to requests
for information, quotes or any other kind of request as indicated by the
form’s header.

Personal Data processed: address; city; company name; email address; first
name; last name; phone number; state.

Category of personal information collected according to the CCPA:
identifiers; commercial information.

This processing constitutes:

* a sale according to the VCDPA

PHONE CONTACT (AVOXI, INC. WEBSITES, APPS, AND SERVICES)

Users that provided their phone number might be contacted for commercial or
promotional purposes related to AVOXI, Inc. Websites, Apps, and Services, as
well as for fulfilling support requests.

Personal Data processed: phone number.

Category of personal information collected according to the CCPA:
identifiers.

This processing constitutes:

* a sale according to the VCDPA

FORMSITE

Formsite does not access, view, sell, share, rent, or trade any information
collected by customer forms for any purposes aside from naturally occurring
exposure as a result of customer support, fraud prevention, or other
maintenance activities, or as may be required by law.

Privacy Statement | Formsite
https://www.formsite.com/privacy/#:~:text=required%20by%20law.-,Form%20visitors,may%20be%20required%20by%20law.

This processing constitutes:

* a sale according to the VCDPA
* a sharing according to the CCPA
* targeted advertising according to the VCDPA

* CONTENT PERFORMANCE AND FEATURES TESTING (A/B TESTING)

The services contained in this section allow the Owner to track and analyze
the User response concerning web traffic or behavior regarding changes to the
structure, text or any other component of AVOXI, Inc. Websites, Apps, and
Services.

GOOGLE OPTIMIZE (GOOGLE LLC)

Google Optimize is an A/B testing service provided by Google LLC ("Google").

Google may use Personal Data to contextualize and personalize the ads of its
own advertising network.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

* DATA TRANSFER OUTSIDE THE EU

The Owner is allowed to transfer Personal Data collected within the EU to
third countries (i.e. any country not part of the EU) only pursuant to a
specific legal basis. Any such Data transfer is based on one of the legal
bases described below.
Users can inquire with the Owner to learn which legal basis applies to which
specific service.

DATA TRANSFER ABROAD BASED ON STANDARD CONTRACTUAL CLAUSES (AVOXI, INC.
WEBSITES, APPS, AND SERVICES)

If this is the legal basis, the transfer of Personal Data from the EU to
third countries is carried out by the Owner according to “standard
contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in
compliance with the data protection standards set forth by EU data protection
legislation. For further information, Users are requested to contact the
Owner through the contact details provided in the present document.

Personal Data processed: various types of Data.

Category of personal information collected according to the CCPA: internet
information.

DATA TRANSFER FROM THE EU AND/OR SWITZERLAND TO THE U.S BASED ON PRIVACY
SHIELD (AVOXI, INC. WEBSITES, APPS, AND SERVICES)

If this is the legal basis, the transfer of Personal Data from the EU or
Switzerland to the US is carried out according to the EU - U.S. and Swiss -
U.S. Privacy Shield.
In particular, Personal Data is transferred to services that self-certify
under the Privacy Shield framework and therefore guarantee an adequate level
of protection of such transferred Data. All services are listed within the
relevant section of this document and those that adhere to Privacy Shield can
be singled out by checking their privacy policy and possibly also by
specifically checking for Privacy Shield adherence in the official Privacy
Shield List. Privacy Shield also specifically guarantees rights to Users
which can be found in its most current form on the website run by the US
Department of Commerce.
Personal Data may be transferred from within the EU or Switzerland to the
U.S. to services that are not, or not anymore, part of Privacy Shield, only
based on other valid legal grounds. Users can ask the Owner to learn about
such legal grounds.

Personal Data processed: various types of Data.

Category of personal information collected according to the CCPA: internet
information.

* DISPLAYING CONTENT FROM EXTERNAL PLATFORMS

This type of service allows you to view content hosted on external platforms
directly from the pages of AVOXI, Inc. Websites, Apps, and Services and
interact with them.
This type of service might still collect web traffic data for the pages where
the service is installed, even when Users do not use it.

GOOGLE PROGRAMMABLE SEARCH ENGINE (GOOGLE INC.)

Google Programmable Search Engine is a search engine embedding service
provided by Google LLC or by Google Ireland Limited, depending on how the
Owner manages the Data processing, that allows AVOXI, Inc. Websites, Apps,
and Services to incorporate content of this kind on its pages.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

GOOGLE MAPS WIDGET (GOOGLE INC.)

Google Maps is a maps visualization service provided by Google Inc. that
allows AVOXI, Inc. Websites, Apps, and Services to incorporate content of
this kind on its pages.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

GOOGLE FONTS (GOOGLE INC.)

Google Fonts is a typeface visualization service provided by Google Inc. that
allows AVOXI, Inc. Websites, Apps, and Services to incorporate content of
this kind on its pages.

Personal Data processed: Usage Data; various types of Data as specified in
the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

INSTAGRAM WIDGET (INSTAGRAM, INC.)

Instagram is an image visualization service provided by Instagram, Inc. that
allows AVOXI, Inc. Websites, Apps, and Services to incorporate content of
this kind on its pages.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

YOUTUBE VIDEO WIDGET (GOOGLE INC.)

YouTube is a video content visualization service provided by Google Inc. that
allows AVOXI, Inc. Websites, Apps, and Services to incorporate content of
this kind on its pages.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

WISTIA WIDGET (WISTIA, INC.)

Wistia is a video content visualization service provided by Wistia, Inc. that
allows AVOXI, Inc. Websites, Apps, and Services to incorporate content of
this kind on its pages.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

* HANDLING ACTIVITIES RELATED TO PRODUCTIVITY

This type of service helps the Owner to manage tasks, collaboration and, in
general, activities related to productivity. In using this type of service,
Data of Users will be processed and may be retained, depending on the purpose
of the activity in question.
These services may be integrated with a wide range of third-party services
disclosed within this privacy policy to enable the Owner to import or export
Data needed for the relative activity.

ASANA (ASANA, INC.)

Asana is a project management service provided by Asana, Inc.

Personal Data processed: workplace.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: employment
related information.

This processing constitutes:

* a sale according to the CCPA

* HANDLING FINANCE AND ACCOUNTING

PORTAONE, INC.

Personal Data collected
At least one employee's business contact information of each customer and
possible various types of data as specified in the privacy policy of the
service

Privacy Policy
PortaOne's service is a business support system (BSS) with convergent billing
and an online charging system (OCS) for communication service providers
(CSP).

This processing constitutes a sale based on the definition under the CCPA. In
addition to the information in this clause, the User can find information
regarding how to opt-out of the sale in the section detailing the rights of
California consumers.

This processing constitutes:

* a sale according to the VCDPA
* a sharing according to the CCPA
* targeted advertising according to the VCDPA

* HANDLING PAYMENTS

Payment processing services enable AVOXI, Inc. Websites, Apps, and Services
to process payments by credit card, bank transfer or other means. To ensure
greater security, AVOXI, Inc. Websites, Apps, and Services shares only the
information necessary to execute the transaction with the financial
intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the
User, such as emails containing invoices or notifications concerning the
payment.

AUTHORIZE.NET (AUTHORIZE.NET)

Authorize.Net is a payment service provided by Authorize.Net.

Personal Data processed: various types of Data as specified in the privacy
policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

PAYPAL (PAYPAL INC.)

PayPal is a payment service provided by PayPal Inc., which allows Users to
make online payments.

Personal Data processed: various types of Data as specified in the privacy
policy of the service.

Place of processing: See the PayPal privacy policy – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

* HEAT MAPPING AND SESSION RECORDING

Heat mapping services are used to display the areas of AVOXI, Inc. Websites,
Apps, and Services that Users interact with most frequently. This shows where
the points of interest are. These services make it possible to monitor and
analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later
visual playback.

CRAZY EGG (CRAZYEGG)

Crazy Egg is a heat mapping service provided by Crazy Egg, Inc.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

* HOSTING AND BACKEND INFRASTRUCTURE

This type of service has the purpose of hosting Data and files that enable
AVOXI, Inc. Websites, Apps, and Services to run and be distributed as well as
to provide a ready-made infrastructure to run specific features or parts of
AVOXI, Inc. Websites, Apps, and Services. Some of these services work through
geographically distributed servers, making it difficult to determine the
actual location where the Personal Data are stored.

GOOGLE CLOUD STORAGE (GOOGLE LLC)

Google Cloud Storage is a hosting service provided by Google LLC.

Personal Data processed: various types of Data as specified in the privacy
policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

GOOGLE APP ENGINE (GOOGLE LLC)

Google App Engine is a hosting service provided by Google LLC.

Personal Data processed: various types of Data as specified in the privacy
policy of the service.

Place of processing: Germany – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA

QUICKBOOKS (INTUIT LIMITED.)

Quickbooks is an invoicing and accounting management service provided by
Intuit Limited. that enables and facilitates the management of quotes,
invoices and other types of accounting documents. Personal Data are shared
with Quickbooks for the purpose of creating electronic invoices upon the
fulfillment of a payment by the User. Quickbooks may also be used as an
inventory management service.

Personal Data processed: financial information.

Place of processing: United Kingdom – Privacy Policy.

Category of personal information collected according to the CCPA: california
Consumer Records Statute information.

This processing constitutes:

* a sale according to the CCPA

* INFORMATION COLLECTION

PRIVACY SHIELD

In compliance with the Privacy Shield Principles, Avoxi, Inc. commits to
resolve complaints about our collection or use of your personal information.
EU and Swiss individuals with inquiries or complaints regarding our Privacy
Shield policy should first contact Avoxi, Inc. at:

Privacy@avoxi.com and/or Weston.Edmunds@avoxi.com or call +1.678.348.5042

Avoxi, Inc. has further committed to refer unresolved Privacy Shield
complaints to JAMS, an alternative dispute resolution provider located in the
United States. If you do not receive timely acknowledgment of your complaint
from us, or if we have not addressed your complaint to your satisfaction,
please visit https://www.jamsadr.com/eu-us-privacy-shield for more
information or to file a complaint. The services of JAMS are provided at no
cost to you.

This processing constitutes:

* a sale according to the CCPA and the VCDPA
* a sharing according to the CCPA
* targeted advertising according to the VCDPA

* INTERACTION WITH EXTERNAL SOCIAL NETWORKS AND PLATFORMS

This type of service allows interaction with social networks or other
external platforms directly from the pages of AVOXI, Inc. Websites, Apps, and
Services.
The interaction and information obtained through AVOXI, Inc. Websites, Apps,
and Services are always subject to the User’s privacy settings for each
social network.
This type of service might still collect traffic data for the pages where the
service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make
sure that the processed data on AVOXI, Inc. Websites, Apps, and Services
isn’t being connected back to the User’s profile.

TWITTER TWEET BUTTON AND SOCIAL WIDGETS (TWITTER, INC.)

The Twitter Tweet button and social widgets are services allowing interaction
with the Twitter social network provided by Twitter, Inc.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

FACEBOOK LIKE BUTTON AND SOCIAL WIDGETS (FACEBOOK, INC.)

The Facebook Like button and social widgets are services allowing interaction
with the Facebook social network provided by Facebook, Inc.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

GOOGLE+ +1 BUTTON AND SOCIAL WIDGETS (GOOGLE INC.)

The Google+ +1 button and social widgets are services allowing interaction
with the Google+ social network provided by Google Inc.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

LINKEDIN BUTTON AND SOCIAL WIDGETS (LINKEDIN CORPORATION)

The LinkedIn button and social widgets are services allowing interaction with
the LinkedIn social network provided by LinkedIn Corporation.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

YOUTUBE BUTTON AND SOCIAL WIDGETS (GOOGLE INC.)

The YouTube button and social widgets are services allowing interaction with
the YouTube social network provided by Google Inc.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

* INTERACTION WITH LIVE CHAT PLATFORMS

This type of service allows Users to interact with third-party live chat
platforms directly from the pages of AVOXI, Inc. Websites, Apps, and
Services, in order to contact and be contacted by AVOXI, Inc. Websites, Apps,
and Services‘s support service.
If one of these services is installed, it may collect browsing and Usage Data
in the pages where it is installed, even if the Users do not actively use the
service. Moreover, live chat conversations may be logged.

SNAPENGAGE WIDGET (TEAMSUPPORT, LLC.)

The Snapengage Widget is a service for interacting with the Snapengage live
chat platform provided by TeamSupport, LLC.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy.

Category of personal information collected according to CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA
* a sharing according to the CCPA
* targeted advertising according to the VCDPA

* LOCATION-BASED INTERACTIONS

GEOLOCATION (AVOXI, INC. WEBSITES, APPS, AND SERVICES)

AVOXI, Inc. Websites, Apps, and Services may collect, use, and share User
location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by
default. If explicit authorization has been provided, the User’s location
data may be tracked by AVOXI, Inc. Websites, Apps, and Services.

Personal Data processed: geographic position.

Category of personal information collected according to the CCPA: geolocation
data.

This processing constitutes:

* a sale according to the VCDPA
* a sharing according to the CCPA
* targeted advertising according to the VCDPA

* MANAGING CONTACTS AND SENDING MESSAGES

This type of service makes it possible to manage a database of email
contacts, phone contacts or any other contact information to communicate with
the User.
These services may also collect data concerning the date and time when the
message was viewed by the User, as well as when the User interacted with it,
such as by clicking on links included in the message.

MAILGUN (MAILGUN TECHNOLOGIES, INC.)

Mailgun is an email address management and message sending service provided
by Mailgun Technologies, Inc.

Personal Data processed: email address.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA:
identifiers.

This processing constitutes:

* a sale according to the CCPA and the VCDPA
* a sharing according to the CCPA
* targeted advertising according to the VCDPA

APPCUES (APPCUES, INC.)

Appcues is a message sending service provided by Appcues, Inc. Appcues may
also be used to manage the creation, deployment, administration, distribution
and analysis of online forms and surveys.

Personal Data processed: physical address.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA:
identifiers.

This processing constitutes:

* a sale according to the CCPA and the VCDPA
* a sharing according to the CCPA
* targeted advertising according to the VCDPA

* MANAGING LANDING AND INVITATION PAGES

This type of service helps with building and managing landing and invitation
pages, i.e., pages for presenting a product or service, where you may add
your contact information such as an email address.
Managing these pages means that these services will handle the Personal Data
collected through the pages, including Usage Data.

UNBOUNCE (UNBOUNCE MARKETING SOLUTIONS INC.)

Unbounce is a landing page management service provided by Unbounce Marketing
Solutions Inc., that allows AVOXI, Inc. Websites, Apps, and Services to
collect the email addresses of Users interested in its service.
Unbounce allows the Owner to track and analyze the User response concerning
web traffic or behavior regarding changes to the structure, text or any other
component of the created landing pages.

Personal Data processed: Cookies; email address; Usage Data.

Place of processing: Canada – Privacy Policy.

Category of personal information collected according to the CCPA:
identifiers; internet information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

* MARKETING

CONSENT TO RECEIVE EMAIL MESSAGES

You consent to receive e-mail messages that are of promotional nature from
AVOXI to market, promote, and drive engagement of our products and services.
We use data about you to send promotional communications that may be of
specific interest to you. Based on the information we collect about you, we
may decide whether and how to promote certain of our products or services to
you over others. These communications are to drive your engagement and
maximize the value of our services to you. To perform the above functions and
others described in this Privacy Policy, we may match information collected
from you, including personal data and usage information, and use such
information in communications. You can opt out of promotional communications
at any time by clicking the unsubscribe button.

This processing constitutes:

* a sale according to the CCPA and the VCDPA
* a sharing according to the CCPA
* targeted advertising according to the VCDPA

CLEARBIT

Clearbit is a B2B marketing data engine that helps businesses sell to other
businesses. They enable them to better understand the businesses they sell
to, identify future prospects, and personalize their marketing and sales
interactions. Our proprietary indexing systems ("Clearbit Indexers") collect
information from a variety of sources in order to compile "Attribute Data"
about corporations, non-profits, and similar entities ("Companies") and the
professionals that work for them ("Professionals"). A complete list of
Attribute Data we make available to users of the Site and Services (defined
below) can be found at www.clearbit.com/attributes. Learn more here
https://clearbit.com/privacy

This processing constitutes:

* a sale according to the CCPA and the VCDPA
* a sharing according to the CCPA
* targeted advertising according to the VCDPA

* PLATFORM SERVICES AND HOSTING

These services have the purpose of hosting and running key components of
AVOXI, Inc. Websites, Apps, and Services, therefore allowing the provision of
AVOXI, Inc. Websites, Apps, and Services from within a unified platform. Such
platforms provide a wide range of tools to the Owner – e.g. analytics, user
registration, commenting, database management, e-commerce, payment processing
– that imply the collection and handling of Personal Data. Some of these
services work through geographically distributed servers, making it difficult
to determine the actual location where the Personal Data are stored.

WORDPRESS.COM (AUTOMATTIC INC.)

WordPress.com is a platform provided by Automattic Inc. that allows the Owner
to build, run and host AVOXI, Inc. Websites, Apps, and Services.

Personal Data processed: various types of Data as specified in the privacy
policy of the service.

Place of processing: USA – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA

APPLE APP STORE (APPLE INC.)

AVOXI, Inc. Websites, Apps, and Services is distributed on Apple's App Store,
a platform for the distribution of mobile apps, provided by Apple Inc.

By virtue of being distributed via this app store, Apple collects basic
analytics and provides reporting features that enables the Owner to view
usage analytics data and measure the performance of AVOXI, Inc. Websites,
Apps, and Services. Much of this information is processed on an opt-in basis.

Users may opt-out of this analytics feature directly through their device
settings. More information on how to manage analysis settings can be found on
this page.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

* REGISTRATION AND AUTHENTICATION

By registering or authenticating, Users allow AVOXI, Inc. Websites, Apps, and
Services to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration
and authentication services. In this case, AVOXI, Inc. Websites, Apps, and
Services will be able to access some Data, stored by these third-party
services, for registration or identification purposes.

GOOGLE OAUTH (GOOGLE INC.)

Google OAuth is a registration and authentication service provided by Google
Inc. and is connected to the Google network.

Personal Data processed: various types of Data as specified in the privacy
policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

* REMARKETING AND BEHAVIORAL TARGETING

This type of service allows AVOXI, Inc. Websites, Apps, and Services and its
partners to inform, optimize and serve advertising based on past use of
AVOXI, Inc. Websites, Apps, and Services by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to
collect information which is then transferred to the partners that manage the
remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below,
Users may opt out by visiting the Network Advertising Initiative opt-out
page.

Users may also opt-out of certain advertising features through applicable
device settings, such as the device advertising settings for mobile phones or
ads settings in general.

GOOGLE ADS REMARKETING (GOOGLE INC.)

Google Ads Remarketing is a remarketing and behavioral targeting service
provided by Google LLC or by Google Ireland Limited, depending on how the
Owner manages the Data processing, that connects the activity of AVOXI, Inc.
Websites, Apps, and Services with the Google Ads advertising network and the
DoubleClick Cookie.

Users can opt out of Google's use of cookies for ads personalization by
visiting Google's Ads Settings.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA
* a sharing according to the CCPA
* targeted advertising according to the VCDPA

GOOGLE AD MANAGER AUDIENCE EXTENSION (GOOGLE LLC)

Google Ad Manager Audience Extension is a remarketing and behavioral
targeting service provided by Google LLC that tracks the visitors of AVOXI,
Inc. Websites, Apps, and Services and allows selected advertising partners to
display targeted ads across the web to them.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA
* a sharing according to the CCPA
* targeted advertising according to the VCDPA

* TAG MANAGEMENT

This type of service helps the Owner to manage the tags or scripts needed on
AVOXI, Inc. Websites, Apps, and Services in a centralized fashion.
This results in the Users' Data flowing through these services, potentially
resulting in the retention of this Data.

GOOGLE TAG MANAGER (GOOGLE LLC)

Google Tag Manager is a tag management service provided by Google LLC or by
Google Ireland Limited, depending on how the Owner manages the Data
processing.

Personal Data processed: Usage Data.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA

* USER DATABASE MANAGEMENT

This type of service allows the Owner to build user profiles by starting from
an email address, a personal name, or other information that the User
provides to AVOXI, Inc. Websites, Apps, and Services, as well as to track
User activities through analytics features. This Personal Data may also be
matched with publicly available information about the User (such as social
networks' profiles) and used to build private profiles that the Owner can
display and use for improving AVOXI, Inc. Websites, Apps, and Services.
Some of these services may also enable the sending of timed messages to the
User, such as emails based on specific actions performed on AVOXI, Inc.
Websites, Apps, and Services.

SALESFORCE SALES CLOUD (SALESFORCE.COM, INC.)

Salesforce Sales Cloud is a User database management service provided by
salesforce.com, inc.

Personal Data processed: various types of Data as specified in the privacy
policy of the service.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

PARDOT (SALESFORCE.COM, INC.)

Pardot is a User database management service provided by Salesforce.com, inc.

Personal Data processed: various types of Data as specified in the privacy
policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet
information.

This processing constitutes:

* a sale according to the CCPA and the VCDPA

INFORMATION ON OPTING OUT OF INTEREST-BASED ADVERTISING

In addition to any opt-out feature provided by any of the services listed in
this document, Users may learn more on how to generally opt out of
interest-based advertising within the dedicated section of the Cookie Policy.

FURTHER INFORMATION ABOUT THE PROCESSING OF PERSONAL DATA

* DOCUSIGN

Provider
DocuSign, Inc.

Purpose
Handles documents (contracts) for review and signature

Personal Data collected
Various types of data as specified in the privacy policy of the service

Privacy Policy
DocuSign is service used to process and store document information on behalf
of its clients to allow its clients' customer (or the customer’s Authorized
Users) to review and sign such documents (contracts).

This processing constitutes a sale based on the definition under the CCPA. In
addition to the information in this clause, the User can find information
regarding how to opt out of the sale in the section detailing the rights of
Californian consumers.

* CALL RECORDING AND MONITORING

Purpose

Call recording and monitoring allow service improvement which AVOXI provides
to ensure call quality, to manage services and user experience, and to
confirm compliance to policies and procedures.

Personal Data collected

Various types of data may be collected such as IP address, name, location,
account details, and phone number.

AVOXI has a legitimate reason to process the personal data collected to
enable our ability to provide services, administer customer accounts, and
operate its business.

* PROTECTION OF PERSONAL INFORMATION ACT 4 OF 2013 (“POPIA”)

This Notice explains how we obtain, use and disclose your personal
information, in accordance with the requirements of the Protection of
Personal Information Act 4 of 2013 (“POPIA”).
At AVOXI (and including this website, POPIAct-Compliance) we are committed to
protecting your privacy and ensuring that your personal information is
collected and used properly, lawfully, and transparently.

The information we collect
Among the types of Personal Data that AVOXI Websites, Apps, and Services
collects, by itself or through third parties, there are Cookies; Usage Data;
first name; last name; phone number; company name; address; state; email
address; city; various types of Data; geographic position.

Complete details on each type of Personal Data collected are provided in the
dedicated sections of this privacy policy or by specific explanation texts
displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data,
collected automatically when using AVOXI Websites, Apps, and Services.

Unless specified otherwise, all Data requested by AVOXI. Websites, Apps, and
Services are mandatory and failure to provide this Data may make it
impossible for AVOXI Websites, Apps, and Services to provide its services. In
cases where AVOXI Websites, Apps, and Services specifically state that some
Data is not mandatory, Users are free not to communicate this Data without
consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to
contact the Owner.

Any use of Cookies – or of other tracking tools – by AVOXI Websites, Apps,
and Services or by the owners of third-party services used by AVOXI Websites,
Apps, and Services serves the purpose of providing the Service required by
the User, in addition to any other purposes described in the present document
and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published
or shared through AVOXI Websites, Apps, and Services and confirm that they
have the third party's consent to provide the Data to the Owner.

How we use your information
We will use your personal information only for the purposes for which it was
collected and agreed with you in compliance with the provisions of POPIA. In
addition, Personal Data shall be processed and stored for as long as required
by the purpose they have been collected for. AVOXI does not, except where
otherwise permitted by law, collect, use or disclose your Personal
Information without your consent.

Therefore:
Personal Data collected for purposes related to the performance of a contract
between the Owner and the User shall be retained until such contract has been
fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests
shall be retained as long as needed to fulfill such purposes. Users may find
specific information regarding the legitimate interests pursued by the Owner
within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever
the User has given consent to such processing, as long as such consent is not
withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for
a longer period whenever required to do so for the performance of a legal
obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore,
the right of access, the right to erasure, the right to rectification, and
the right to data portability cannot be enforced after the expiration of the
retention period.

Disclosure of information
We may disclose your personal information to our service providers who are
involved in the delivery of products or services to you. We have agreements
in place to ensure that they comply with the privacy requirements as required
by the Protection of Personal Information Act.

We may also disclose your information:
Where we have a duty or a right to disclose in terms of law or industry
codes;
Where we believe it is necessary to protect our rights.

In the event that AVOXI sends Personal Information outside of South Africa
(including if such information is hosted offshore), AVOXI will ensure that it
takes all reasonable steps to ensure that it complies with all applicable
laws in this regard, including POPIA.

Information Security
We are legally obliged to provide adequate protection for the personal
information we hold and to stop unauthorized access and use of personal
information. We will, on an ongoing basis, continue to review our security
controls and related processes to ensure that your personal information
remains secure.

When we contract with third parties, we impose appropriate security, privacy,
and confidentiality obligations on them to ensure that personal information
that we remain responsible for, is kept secure.

We will ensure that anyone to whom we pass your personal information agrees
to treat your information with the same level of protection as we are obliged
to.

Definition of personal information
According to the Act ‘‘personal information’’ means information relating to
an identifiable, living, natural person, and where it is applicable, an
identifiable, existing juristic person. Further to the POPI Act, AVOXI may
ask you to provide Us with information:

Email address
First and last name
Phone number
Business physical or postal
Company Name
Company Registration Number
Vat Number

Tracking Technologies and Cookies
AVOXI Websites, Apps, and Services use Trackers managed directly by the Owner
(so-called “first-party” Trackers) and Trackers that enable services provided
by a third-party (so-called “third-party” Trackers). Unless otherwise
specified within this document, third-party providers may access the Trackers
managed by them.
The validity and expiration periods of Cookies and other similar Trackers may
vary depending on the lifetime set by the Owner or the relevant provider.
Some of them expire upon termination of the User’s browsing session.
In addition to what’s specified in the descriptions within each of the
categories below, Users may find more precise and updated information
regarding lifetime specification as well as any other relevant information –
such as the presence of other Trackers - in the linked privacy policies of
the respective third-party providers or by contacting the Owner.
To find more information about our cookies and other similar trackers please
view our Websites, Apps, and Services Cookie Policy. Also refer to our
Privacy Policy for further information on third-party Analytics, Email
Marketing, and Remarketing.

Updating of Privacy Policy

AVOXI, in its sole discretion, reserves the right to update, modify or amend
this Policy from time to time with or without notice. You therefore agree and
undertake to review the Policy whenever you visit the Website. Save as
expressly provided to the contrary in this Policy, any amended version of the
Policy shall supersede and replace all previous versions thereof.

Contact Information

Questions, concerns, or complaints related to this Policy or AVOXI’s
treatment of Personal Information should be directed to privacy@avoxi.com.

* ANONYMIZATION OF CUSTOMER DATA

If Personal Data is used for product enhancement or development, then that
specific Personal Data will be anonymized.

* THE SERVICE IS NOT DIRECTED TO CHILDREN UNDER THE AGE OF 13

Users declare themselves to be adult according to their applicable
legislation. Minors may use AVOXI, Inc. Websites, Apps, and Services only
with the assistance of a parent or guardian. Under no circumstance persons
under the age of 13 may use AVOXI, Inc. Websites, Apps, and Services.

* PRIVACY SHIELD PARTICIPATION: DATA TRANSFERS FROM THE EU AND SWITZERLAND TO
THE UNITED STATES

The Owner participates in and complies with the EU-U.S. Privacy Shield
Framework and the Swiss-U.S Privacy Shield Framework as set forth by the U.S.
Department of Commerce regarding the collection, use, and retention of
Personal Data transferred from the European Union and Switzerland to the
United States. The policies and rights outlined below are therefore equally
and explicitly applicable to Users from Switzerland, except if stated
otherwise. The Owner has certified to the Department of Commerce that it
adheres to the Privacy Shield Principles.

If there is any conflict between the terms in this privacy policy and the
Privacy Shield Principles, the Privacy Shield Principles shall govern. To
learn more about the Privacy Shield program, and to view the Owner’s
certification, please visit https://www.privacyshield.gov/ (or find the
direct link to the certification list of Privacy Shield participants
maintained by the Department of Commerce https://www.privacyshield.gov/list).

What does this mean for the European User?

The Owner is responsible for all processing of Personal Data it receives
under the Privacy Shield Framework from European Union individuals and
commits to subject the processed Personal Data to the Privacy Shield
Principles.

This, most importantly, includes the right of individuals to access their
personal data processed by the Owner.

The Owner also complies with the Privacy Shield Principles for all onward
transfers of Personal Data from the EU, which means that it remains liable in
cases of onward transfers to third parties.

With respect to Personal Data received or transferred pursuant to the Privacy
Shield Framework, the Owner is subject to the investigatory and regulatory
enforcement powers of the FTC, if not stated otherwise in this privacy
policy.

The Owner is further required to disclose Personal Data in response to lawful
requests by public authorities, including to meet national security or law
enforcement requirements.

Dispute resolution under the Privacy Shield

In compliance with the Privacy Shield Principles, the Owner commits to
resolve complaints about its collection or use of the User’s Personal Data.
European Union individuals with inquiries or complaints regarding this
Privacy Shield policy should first contact the Owner at the contact details
supplied at the beginning of this document referring to “Privacy Shield” and
expect the complaint to be dealt with within 45 days.

In case of failure by the Owner to provide a satisfactory or timely response,
the User has the option of involving an independent dispute resolution body,
free of charge.

In this regard, the Owner has agreed to cooperate with the panel established
by the EU data protection authorities (DPAs) and comply with the advice given
by the panel with regard to data transferred from the EU. The User may
therefore contact the Owner at the email address provided at the beginning of
this document in order to be directed to the relevant DPA contacts.

Under certain conditions – available for the User in full on the Privacy
Shield website
(https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint) – the
User may invoke binding arbitration when other dispute resolution procedures
have been exhausted.

THE RIGHTS OF USERS

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

* Withdraw their consent at any time. Users have the right to withdraw consent
where they have previously given their consent to the processing of their
Personal Data.
* Object to processing of their Data. Users have the right to object to the
processing of their Data if the processing is carried out on a legal basis
other than consent. Further details are provided in the dedicated section
below.
* Access their Data. Users have the right to learn if Data is being processed
by the Owner, obtain disclosure regarding certain aspects of the processing
and obtain a copy of the Data undergoing processing.
* Verify and seek rectification. Users have the right to verify the accuracy of
their Data and ask for it to be updated or corrected.
* Restrict the processing of their Data. Users have the right, under certain
circumstances, to restrict the processing of their Data. In this case, the
Owner will not process their Data for any purpose other than storing it.
* Have their Personal Data deleted or otherwise removed. Users have the right,
under certain circumstances, to obtain the erasure of their Data from the
Owner.
* Receive their Data and have it transferred to another controller. Users have
the right to receive their Data in a structured, commonly used and machine
readable format and, if technically feasible, to have it transmitted to
another controller without any hindrance. This provision is applicable
provided that the Data is processed by automated means and that the
processing is based on the User's consent, on a contract which the User is
part of or on pre-contractual obligations thereof.
* Lodge a complaint. Users have the right to bring a claim before their
competent data protection authority.

DETAILS ABOUT THE RIGHT TO OBJECT TO PROCESSING

Where Personal Data is processed for a public interest, in the exercise of an
official authority vested in the Owner or for the purposes of the legitimate
interests pursued by the Owner, Users may object to such processing by providing
a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for
direct marketing purposes, they can object to that processing at any time
without providing any justification. To learn, whether the Owner is processing
Personal Data for direct marketing purposes, Users may refer to the relevant
sections of this document.

HOW TO EXERCISE THESE RIGHTS

Any requests to exercise User rights can be directed to the Owner through the
contact details provided in this document. These requests can be exercised free
of charge and will be addressed by the Owner as early as possible and always
within one month.

COOKIE POLICY

AVOXI, Inc. Websites, Apps, and Services uses Trackers. To learn more, the User
may consult the Cookie Policy.

ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING

LEGAL ACTION

The User's Personal Data may be used for legal purposes by the Owner in Court or
in the stages leading to possible legal action arising from improper use of
AVOXI, Inc. Websites, Apps, and Services or the related Services.
The User declares to be aware that the Owner may be required to reveal personal
data upon request of public authorities.

ADDITIONAL INFORMATION ABOUT USER'S PERSONAL DATA

In addition to the information contained in this privacy policy, AVOXI, Inc.
Websites, Apps, and Services may provide the User with additional and contextual
information concerning particular Services or the collection and processing of
Personal Data upon request.

SYSTEM LOGS AND MAINTENANCE

For operation and maintenance purposes, AVOXI, Inc. Websites, Apps, and Services
and any third-party services may collect files that record interaction with
AVOXI, Inc. Websites, Apps, and Services (System logs) or use other Personal
Data (such as the IP Address) for this purpose.

INFORMATION NOT CONTAINED IN THIS POLICY

More details concerning the collection or processing of Personal Data may be
requested from the Owner at any time. Please see the contact information at the
beginning of this document.

HOW “DO NOT TRACK” REQUESTS ARE HANDLED

AVOXI, Inc. Websites, Apps, and Services does not support “Do Not Track”
requests.
To determine whether any of the third-party services it uses honor the “Do Not
Track” requests, please read their privacy policies.

CHANGES TO THIS PRIVACY POLICY

The Owner reserves the right to make changes to this privacy policy at any time
by notifying its Users on this page and possibly within AVOXI, Inc. Websites,
Apps, and Services and/or - as far as technically and legally feasible - sending
a notice to Users via any contact information available to the Owner. It is
strongly recommended to check this page often, referring to the date of the last
modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the
User’s consent, the Owner shall collect new consent from the User, where
required.

INFORMATION FOR CALIFORNIAN CONSUMERS

This part of the document integrates with and supplements the information
contained in the rest of the privacy policy and is provided by the business
running AVOXI, Inc. Websites, Apps, and Services and, if the case may be, its
parent, subsidiaries and affiliates (for the purposes of this section referred
to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users (Users are referred
to below, simply as “you”, “your”, “yours”), who are consumers residing in the
state of California, United States of America, according to the "California
Consumer Privacy Act of 2018" (the "CCPA"), as updated by the "California
Privacy Rights Act" (the "CPRA") and subsequent regulations. For such consumers,
these provisions supersede any other possibly divergent or conflicting
provisions contained in the privacy policy.

This part of the document uses the terms “personal information” (and “sensitive
personal information”) as defined in the California Consumer Privacy Act (CCPA).

NOTICE AT COLLECTION

CATEGORIES OF PERSONAL INFORMATION COLLECTED, USED, SOLD, OR SHARED

In this section we summarize the categories of personal information that we've
collected, used, sold, or shared and the purposes thereof. You can read about
these activities in detail in the section titled “Detailed information on the
processing of Personal Data” within this document.

INFORMATION WE COLLECT: THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT

We have collected the following categories of personal information about you:
identifiers, california Consumer Records Statute information, commercial
information, internet information, geolocation data and employment related
information.

We have collected the following categories of sensitive personal information:
financial information

We will not collect additional categories of personal information without
notifying you.

YOUR RIGHT TO LIMIT THE USE OR DISCLOSURE OF YOUR SENSITIVE PERSONAL INFORMATION
AND HOW YOU CAN EXERCISE IT

You have the right to request that we limit the use or disclosure of your
sensitive personal information to only that which is necessary to perform the
services or provide the goods, as is reasonably expected by an average consumer.

We can also use your sensitive personal information to perform specific purposes
set forth by the law (such as, including but not limited to, helping to ensure
security and integrity; undertaking activities to verify or maintain the quality
or safety of our service) and as authorized by the relevant regulations.

Outside of the aforementioned specific purposes, you have the right to freely
request, at any time, that we do not use or disclose your sensitive personal
information. This means that whenever you ask us to stop using your sensitive
personal information, we will abide by your request and we will instruct our
service providers and contractors to do the same.

To fully exercise your right to limit the use or disclosure of your sensitive
personal information you can contact us at any time, using the contact details
provided in this document.

For a simplified opt-out method you can also use the privacy choices link
provided on AVOXI, Inc. Websites, Apps, and Services.

We use any personal information collected from you in connection with the
submission of your request solely for the purposes of complying with the
request.

Once you have exercised this right, we are required to wait at least 12 months
before asking whether you have changed your mind.

WHAT ARE THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION?

We may use your personal information to allow the operational functioning of
AVOXI, Inc. Websites, Apps, and Services and features thereof (“business
purposes”). In such cases, your personal information will be processed in a
fashion necessary and proportionate to the business purpose for which it was
collected, and strictly within the limits of compatible operational purposes.

We may also use your personal information for other reasons such as for
commercial purposes (as indicated within the section “Detailed information on
the processing of Personal Data” within this document), as well as for complying
with the law and defending our rights before the competent authorities where our
rights and interests are threatened or we suffer an actual damage.

We won’t process your information for unexpected purposes, or for purposes
incompatible with the purposes originally disclosed, without your consent.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

Unless stated otherwise inside the “Detailed information on the processing of
Personal Data” section, we will not retain your personal information for longer
than is reasonably necessary for the purpose(s) they have been collected for.

HOW WE COLLECT INFORMATION: WHAT ARE THE SOURCES OF THE PERSONAL INFORMATION WE
COLLECT?

We collect the above-mentioned categories of personal information, either
directly or indirectly, from you when you use AVOXI, Inc. Websites, Apps, and
Services.

For example, you directly provide your personal information when you submit
requests via any forms on AVOXI, Inc. Websites, Apps, and Services. You also
provide personal information indirectly when you navigate AVOXI, Inc. Websites,
Apps, and Services, as personal information about you is automatically observed
and collected.

Finally, we may collect your personal information from third parties that work
with us in connection with the Service or with the functioning of this
Application and features thereof.

HOW WE USE THE INFORMATION WE COLLECT: DISCLOSING OF YOUR PERSONAL INFORMATION
WITH THIRD PARTIES FOR A BUSINESS PURPOSE

For our purposes, the word “third party” means a person who is not any of the
following: a service provider or a contractor, as defined by the CCPA.

We disclose your personal information with the third parties listed in detail in
the section titled “Detailed information on the processing of Personal Data”
within this document. These third parties are grouped and categorized in
accordance with the different purposes of processing.

SALE OR SHARING OF YOUR PERSONAL INFORMATION

For our purposes, the word “sale” means any “selling, renting, releasing,
disclosing, disseminating, making available, transferring or otherwise
communicating orally, in writing, or by electronic means, a consumer's personal
information by the business to a third party, for monetary or other valuable
consideration”, as defined by the CCPA.

This means that, for example, a sale can happen whenever an application runs
ads, or makes statistical analyses on the traffic or views, or simply because it
uses tools such as social network plugins and the like.

For our purposes, the word “sharing” means any “sharing, renting, releasing,
disclosing, disseminating, making available, transferring, or otherwise
communicating orally, in writing, or by electronic or other means, a consumer's
personal information by the business to a third party for cross-context
behavioral advertising, whether or not for monetary or other valuable
consideration, including transactions between a business and a third party for
cross-context behavioral advertising for the benefit of a business in which no
money is exchanged”, as defined by the CCPA.
Please note that the exchange of personal information with a service provider
pursuant to a written contract that meets the requirements set by the CCPA, does
not constitute a sale or sharing of your personal information.

YOUR RIGHT TO OPT OUT OF THE SALE OR SHARING OF YOUR PERSONAL INFORMATION AND
HOW YOU CAN EXERCISE IT

We sell or share your personal information with the third parties listed in
detail in the section titled “Detailed information on the processing of Personal
Data” within this document. These third parties are grouped and categorized in
accordance with the different purposes of processing.

You have the right to opt out of the sale or sharing of your personal
information. This means that whenever you request us to stop selling or sharing
your personal information, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable
request.
To fully exercise your right to opt out, you can contact us at any time using
the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link
provided on AVOXI, Inc. Websites, Apps, and Services.

If you want to submit requests to opt out of the sale or sharing of personal
information via a user-enabled global privacy control, like the Global Privacy
Control (“GPC”), you are free to do so and we will abide by such request. The
GPC consists of a setting or extension in the browser or mobile device and acts
as a mechanism that websites can use to indicate they support the GPC signal. If
you want to use GPC, you can download and enable it via a participating browser
or browser extension. More information about downloading GPC is available here.

We use any personal information collected from you in connection with the
submission of your opt-out request solely for the purposes of complying with the
opt-out request.

Once you have opted out, we are required to wait at least 12 months before
asking whether you have changed your mind.

YOUR PRIVACY RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT AND HOW TO
EXERCISE THEM

THE RIGHT TO ACCESS PERSONAL INFORMATION: THE RIGHT TO KNOW AND TO PORTABILITY

You have the right to request that we disclose to you:

* the categories of personal information that we collect about you;
* the sources from which the personal information is collected;
* the purposes for which we use your information;
* to whom we disclose such information;
* the specific pieces of personal information we have collected about you.

You also have the right to know what personal information is sold or shared and
to whom. In particular, you have the right to request two separate lists from us
where we disclose:

* the categories of personal information that we sold or shared about you and
the categories of third parties to whom the personal information was sold or
shared;
* the categories of personal information that we disclosed about you for a
business purpose and the categories of persons to whom it was disclosed for a
business purpose.

The disclosure described above will be limited to the personal information
collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be
"portable", i.e. delivered in an easily usable format to enable you to transmit
the information to another entity without hindrance – provided that this is
technically feasible.

THE RIGHT TO REQUEST THE DELETION OF YOUR PERSONAL INFORMATION

You have the right to request that we delete any of your personal information,
subject to exceptions set forth by the law (such as, including but not limited
to, where the information is used to identify and repair errors on AVOXI, Inc.
Websites, Apps, and Services, to detect security incidents and protect against
fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will
delete your personal information and notify any of our service providers and all
third parties to whom we have sold or shared the personal information to do so –
provided that this is technically feasible and doesn’t involve disproportionate
effort.

THE RIGHT TO CORRECT INACCURATE PERSONAL INFORMATION

You have the right to request that we correct any inaccurate personal
information we maintain about you, taking into account the nature of the
personal information and the purposes of the processing of the personal
information.

THE RIGHT TO OPT OUT OF SALE OR SHARING OF PERSONAL INFORMATION AND TO LIMIT THE
USE OF YOUR SENSITIVE PERSONAL INFORMATION

You have the right to opt out of the sale or sharing of your personal
information. You also have the right to request that we limit our use or
disclosure of your sensitive personal information.

THE RIGHT OF NO RETALIATION FOLLOWING OPT-OUT OR EXERCISE OF OTHER RIGHTS (THE
RIGHT TO NON-DISCRIMINATION)

We will not discriminate against you for exercising your rights under the CCPA.
This means that we will not discriminate against you, including, but not limited
to, by denying goods or services, charging you a different price, or providing a
different level or quality of goods or services just because you exercised your
consumer privacy rights.

However, if you refuse to provide your personal information to us or ask us to
delete or stop selling your personal information, and that personal information
or sale is necessary for us to provide you with goods or services, we may not be
able to complete that transaction.

To the extent permitted by the law, we may offer you promotions, discounts, and
other deals in exchange for collecting, keeping, or selling your personal
information, provided that the financial incentive offered is reasonably related
to the value of your personal information.

HOW TO EXERCISE YOUR RIGHTS

To exercise the rights described above, you need to submit your verifiable
request to us by contacting us via the details provided in this document.

For us to respond to your request, it’s necessary that we know who you are.
Therefore, you can only exercise the above rights by making a verifiable request
which must:

* provide sufficient information that allows us to reasonably verify you are
the person about whom we collected personal information or an authorized
representative;
* describe your request with sufficient detail that allows us to properly
understand, evaluate, and respond to it.

We will not respond to any request if we are unable to verify your identity and
therefore confirm the personal information in our possession actually relates to
you.

Making a verifiable consumer request does not require you to create an account
with us. We will use any personal information collected from you in connection
with the verification of your request solely for the purposes of verification
and shall not further disclose the personal information, retain it longer than
necessary for purposes of verification, or use it for unrelated purposes.

If you cannot personally submit a verifiable request, you can authorize a person
registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a minor
under your parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.

HOW AND WHEN WE ARE EXPECTED TO HANDLE YOUR REQUEST

We will confirm receipt of your verifiable request within 10 days and provide
information about how we will process your request.

We will respond to your request within 45 days of its receipt. Should we need
more time, we will explain to you the reasons why, and how much more time we
need. In this regard, please note that we may take up to 90 days to fulfill your
request.

Our disclosure(s) will cover the preceding 12-month period. Only with regard to
personal information collected on or after January 1, 2022, you have the right
to request that we disclose information beyond the 12-month period, and we will
provide them to you unless doing so proves impossible or would involve a
disproportionate effort.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless
such request is manifestly unfounded or excessive. In such cases, we may charge
a reasonable fee, or refuse to act on the request. In either case, we will
communicate our choices and explain the reasons behind it.

ADDITIONAL INFORMATION ABOUT CALIFORNIA PRIVACY

CCPA: COLLECTION OF PERSONAL INFORMATION ABOUT CONSUMERS AGED 13 TO 16

We collect personal information of consumers between the age of 13 and 16 and
won't sell their data unless those consumers have opted-in.

CCPA: COLLECTION OF PERSONAL INFORMATION ABOUT MINORS

We do not knowingly collect personal information of consumers who are below the
age of 16.

CCPA: COLLECTION OF PERSONAL INFORMATION ABOUT CONSUMERS BELOW THE AGE OF 13

We collect personal information of consumers below the age of 13 and won't sell
their data unless their parents or guardians have opted-in on behalf of those
minors.

INFORMATION FOR VIRGINIA CONSUMERS

This part of the document integrates with and supplements the information
contained in the rest of the privacy policy and is provided by the controller
running this Application and, if the case may be, its parent, subsidiaries and
affiliates (for the purposes of this section referred to collectively as “we”,
“us”, “our”).

The provisions contained in this section apply to all Users (Users are referred
to below, simply as “you”, “your”, “yours”), who are consumers residing in the
Commonwealth of Virginia, according to the “Virginia Consumer Data Protection
Act" (the "VCDPA"), and, for such consumers, these provisions supersede any
other possibly divergent or conflicting provisions contained in the privacy
policy.

This part of the document uses the term “personal data” as defined in the VCDPA.

CATEGORIES OF PERSONAL DATA PROCESSED

In this section, we summarize the categories of personal data that we've
processed and the purposes thereof. You can read about these activities in
detail in the section titled “Detailed information on the processing of Persona
Data” within this document.

CATEGORIES OF PERSONAL DATA WE COLLECT

We have collected the following categories of personal data: identifiers,
commercial information, internet information, geolocation data and employment
related information

We do not collect sensitive data.

We will not collect additional categories of personal data without notifying
you.

WHY WE PROCESS YOUR PERSONAL DATA

To find out why we process your personal data, you can read the sections titled
“Detailed information on the processing of Personal Data” and “The purposes of
processing” within this document.

We won’t process your information for unexpected purposes, or for purposes
incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the
contact details provided in this document.

HOW WE USE THE DATA WE COLLECT: SHARING OF YOUR PERSONAL DATA WITH THIRD PARTIES

We share your personal data with the third parties listed in detail in the
section titled “Detailed information on the processing of Personal Data” within
this document. These third parties are grouped and categorized in accordance
with the different purposes of processing.
For our purposes, the word "third party" means "a natural or legal person,
public authority, agency, or body other than the consumer, controller,
processor, or an affiliate of the processor or the controller" as defined by the
VCDPA.

SALE OF YOUR PERSONAL DATA

For our purposes, the word “sale” means any “exchange of personal data for
monetary consideration by us to a third party“ as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a
processor that processes personal data on behalf of a controller does not
constitute a sale.
As specified in the “Detailed information on the processing of Personal Data”
section of this document, our use of your personal information may be considered
a sale under VCDPA.

YOUR RIGHT TO OPT OUT OF THE SALE OF YOUR PERSONAL DATA AND HOW YOU CAN EXERCISE
IT

You have the right to opt out of the sale of your personal data. This means that
whenever you request us to stop selling your data, we will abide by your
request. To fully exercise your right to opt out you can contact us at any time
using the contact details provided in this document.

We use any personal data collected from you in connection with the submission of
your opt-out request solely for the purpose of complying with the request.

PROCESSING OF YOUR PERSONAL DATA FOR TARGETED ADVERTISING

For our purposes, the word "targeted advertising" means "displaying
advertisements to you where the advertisement is selected based on personal data
obtained from your activities over time and across nonaffiliated websites or
online applications to predict your preferences or interests" as defined by the
VCDPA.

To find out more details on the processing of your personal data for targeted
advertising purposes, you can read the section titled “Detailed information on
the processing of Personal Data” within this document.

YOUR RIGHT TO OPT OUT OF THE PROCESSING OF YOUR PERSONAL DATA FOR TARGETED
ADVERTISING AND HOW YOU CAN EXERCISE IT

You have the right to opt out of the processing of your personal data for
targeted advertising. This means that whenever you ask us to stop processing
your data for targeted advertising, we will abide by your request. To fully
exercise your right to opt out you can contact us at any time, using the contact
details provided in this document.

We use any personal data collected from you in connection with the submission of
your opt-out request solely for the purposes of complying with the opt-out
request.

YOUR PRIVACY RIGHTS UNDER THE VIRGINIA CONSUMER DATA PROTECTION ACT AND HOW TO
EXERCISE THEM

You may exercise certain rights regarding your data processed by us. In
particular, you have the right to do the following:

* access personal data: the right to know. You have the right to request that
we confirm whether or not we are processing your personal data. You also have
the right to access such personal data.
* correct inaccurate personal data. You have the right to request that we
correct any inaccurate personal data we maintain about you, taking into
account the nature of the personal data and the purposes of the processing of
the personal data.
* request the deletion of your personal data. You have the right to request
that we delete any of your personal data.
* obtain a copy of your personal data. We will provide your personal data in a
portable and usable format that allows you to transfer data easily to another
entity – provided that this is technically feasible.
* opt out of the processing of your personal data for the purposes of targeted
advertising, the sale of personal data, or profiling in furtherance of
decisions that produce legal or similarly significant effects concerning you.
* non-discrimination. We will not discriminate against you for exercising your
rights under the VCDPA. This means that we will not, among other things, deny
goods or services, charge you a different price, or provide a different level
or quality of goods or services just because you exercised your consumer
privacy rights. However, if you refuse to provide your personal data to us or
ask us to delete or stop selling your personal data, and that personal data
or sale is necessary for us to provide you with goods or services, we may not
be able to complete that transaction. To the extent permitted by the law, we
may offer a different price, rate, level, quality, or selection of goods or
services to you, including offering goods or services for no fee, if you have
exercised your right to opt out, or our offer is related to your voluntary
participation in a bona fide loyalty, rewards, premium features, discounts,
or club card program.

HOW TO EXERCISE YOUR RIGHTS

To exercise the rights described above, you need to submit your request to us by
contacting us via the contact details provided in this document.

For us to respond to your request, we need to know who you are.

We will not respond to any request if we are unable to verify your identity
using commercially reasonable efforts and therefore confirm that the personal
data in our possession actually relates to you. In such cases, we may request
that you provide additional information which is reasonably necessary to
authenticate you and your request.

Making a consumer request does not require you to create an account with us.
However, we may require you to use your existing account. We will use any
personal data collected from you in connection with your request solely for the
purposes of authentication, without further disclosing the personal data,
retaining it longer than necessary for purposes of authentication, or using it
for unrelated purposes.

If you are an adult, you can make a request on behalf of a minor under your
parental authority.

HOW AND WHEN WE ARE EXPECTED TO HANDLE YOUR REQUEST

We will respond to your request without undue delay, but in all cases and at the
latest within 45 days of its receipt. Should we need more time, we will explain
to you the reasons why, and how much more time we need. In this regard, please
note that we may take up to 90 days to fulfill your request.

Should we deny your request, we will explain to you the reasons behind our
denial without undue delay, but in all cases and at the latest within 45 days of
receipt of the request. It is your right to appeal such decision by submitting a
request to us via the details provided in this document. Within 60 days of
receipt of the appeal, we will inform you in writing of any action taken or not
taken in response to the appeal, including a written explanation of the reasons
for the decisions. If the appeal is denied you may contact the Attorney General
to submit a complaint.

We do not charge a fee to respond to your request, for up to two requests per
year. If your request is manifestly unfounded, excessive or repetitive, we may
charge a reasonable fee or refuse to act on the request. In either case, we will
communicate our choices and explain the reasons behind them.

DEFINITIONS AND LEGAL REFERENCES

PERSONAL DATA (OR DATA)

Any information that directly, indirectly, or in connection with other
information — including a personal identification number — allows for the
identification or identifiability of a natural person.

USAGE DATA

Information collected automatically through AVOXI, Inc. Websites, Apps, and
Services (or third-party services employed in AVOXI, Inc. Websites, Apps, and
Services), which can include: the IP addresses or domain names of the computers
utilized by the Users who use AVOXI, Inc. Websites, Apps, and Services, the URI
addresses (Uniform Resource Identifier), the time of the request, the method
utilized to submit the request to the server, the size of the file received in
response, the numerical code indicating the status of the server's answer
(successful outcome, error, etc.), the country of origin, the features of the
browser and the operating system utilized by the User, the various time details
per visit (e.g., the time spent on each page within the Application) and the
details about the path followed within the Application with special reference to
the sequence of pages visited, and other parameters about the device operating
system and/or the User's IT environment.

USER

The individual using AVOXI, Inc. Websites, Apps, and Services who, unless
otherwise specified, coincides with the Data Subject.

DATA SUBJECT

The natural person to whom the Personal Data refers.

DATA PROCESSOR (OR DATA SUPERVISOR)

The natural or legal person, public authority, agency or other body which
processes Personal Data on behalf of the Controller, as described in this
privacy policy.

DATA CONTROLLER (OR OWNER)

The natural or legal person, public authority, agency or other body which, alone
or jointly with others, determines the purposes and means of the processing of
Personal Data, including the security measures concerning the operation and use
of AVOXI, Inc. Websites, Apps, and Services. The Data Controller, unless
otherwise specified, is the Owner of AVOXI, Inc. Websites, Apps, and Services.

AVOXI, INC. WEBSITES, APPS, AND SERVICES (OR THIS APPLICATION)

The means by which the Personal Data of the User is collected and processed.

SERVICE

The service provided by AVOXI, Inc. Websites, Apps, and Services as described in
the relative terms (if available) and on this site/application.

EUROPEAN UNION (OR EU)

Unless otherwise specified, all references made within this document to the
European Union include all current member states to the European Union and the
European Economic Area.

Cookies are Trackers consisting of small sets of data stored in the User's
browser.

TRACKER

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons,
embedded scripts, e-tags and fingerprinting - that enables the tracking of
Users, for example by accessing or storing information on the User’s device.

--------------------------------------------------------------------------------

LEGAL INFORMATION

This privacy statement has been prepared based on provisions of multiple
legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data
Protection Regulation).

This privacy policy relates solely to AVOXI, Inc. Websites, Apps, and Services,
if not stated otherwise within this document.

Latest update: February 14, 2023

iubenda hosts this content and only collects the Personal Data strictly
necessary for it to be provided.

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