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Last Updated: Apr 15, 2022

By accessing and using the Services, you are agreeing to the practices and
policies described in this Privacy Policy. If you object to any practices or
policies as described in this Privacy Policy, please do not access or use the
Services.




INTRODUCTION

For purposes of this Privacy Policy, “Mural,” “we” or “us” means Tactivos, Inc.,
d/b/a Mural, and “you” or “your” means you, the individual human collaborator
who is using our Services. Your use of the Services is subject to our Terms of
Service. All of our Terms of Service are available at mural.co/terms. Any
capitalized terms that are not defined in this Privacy Policy have the meaning
ascribed to such terms in our otherTerms of Service.  


This Privacy Policy describes how Mural collects, uses, transfers and discloses
the information collected from and about you, and what choices you have with
respect to your information. Please note, however, that this Privacy Policy does
not cover Workspace Content or your Contributions. Your Workspace Owner (our
Customer) controls the Workspace and any Content or Contributions. We are their
data processor, service provider, or subprocessor (as applicable), and our
processing of Workspace Content data is governed by our agreements with your
Workspace Owner. If you have any questions about your Contributions or Workspace
Content, please contact your Workspace Owner.


WHAT INFORMATION WE COLLECT

Directly from you, when you register for and interact with the Services: When
you register as a Mural Member or Guest, we collect your email address, name,
phone number, password, and company name (if applicable). You also have the
option to add a personal photo to your Mural profile to help foster team
building and collaboration. In addition to the information you provide when
registering an account, you can choose to provide additional information when
you use the Services. For example, Visitors to a Mural canvas collaborate
without needing to register an account or sign in; Visitors can choose to
identify themselves by name for the duration of their collaboration session, or
they can choose to remain anonymous. Admins may also be asked to provide billing
and payment related information for their associated Customer accounts. Mural
uses a third-party payment processor to collect billing and payment information;
we do not directly collect, process, store or use any billing or payment
information. We may also collect information that you submit to us in other
contexts, such as when you participate in a Mural event, download a Mural white
paper, request support, interact with our social media accounts, or otherwise
communicate or interact with Mural or our Services. Mural does not require you
to provide any special category or sensitive data to use the Services, and in
fact, the Services are not intended to be used for the transmission of such
data. Please do not transmit any sensitive or special category of data through
the Services.


Indirectly, when you interact with the Services: Mural uses cookies and similar
technologies to collect a variety of information about how you interact with the
Services so that we can deliver a better and more relevant experience for you.
This includes, for example: device-related information such as IP address,
browser language, the state or country from which you accessed the Services
(based on IP address), company names, software and hardware attributes
(including device IDs, operating system, and browser type); referring and exit
URLs; the links clicked on and files downloaded; pages viewed and the order of
those pages; the amount of time spent on particular pages; the terms used in
searches on the Services; the date and time of a visit or when an email is
opened; when you first registered an account; your team, role, and status; the
dates and duration of collaboration activities; the levels of access or
functionality applicable to your role or account; the number of workspaces,
rooms, and murals you have joined or created; the number of invitations you have
sent; and other similar information. For more information on our use of cookies
and similar technologies, please see our Cookie Policy. 


From Third Party Services, with your permission, when you use the Services: If
you choose to use a Third Party Service (including without limitation an
Integration) that is available through the Services, the Third Party Service may
share certain information with Mural in accordance with your privacy settings
with such Third Party Service. For example, if your Workspace Owner enables a
cloud storage Integration to import files from that application to the
Workspace, we may receive additional information that the Integration has
elected to make available to Mural to facilitate the Integration. Or, if you
choose to register your Mural account using a Third Party Service authentication
tool (such as your Google account), the Third Party Service will provide Mural
with information necessary for authentication and account registration, such as
your name and email address. Authorized Users should check the privacy settings
and notices in Third Party Services to understand what data may be disclosed to
Mural. Mural is not responsible for the data protection or privacy practices of
any Third Party Services. 


HOW WE USE YOUR INFORMATION

Mural uses your information only as it relates to our interests in operating our
business and providing the Services. More specifically, we use your information
as follows:

Purpose Description Legal Basis Provide the Services to Customers and their
Authorized Users MURAL uses information to provide the Services to you and your
Workspace Owner, as requested and authorized by your Workspace Owner. For
example:
 * We may use information to prepare reports and other information to Workspace
   Owners about utilization of their Workspace.
 * If you request customer support, we may use information to respond and help
   resolve the support issue.
 * We may use information to provide Collaboration Insights™ and as part of our
   enterprise-grade solutions.
 * We may also use information to provide service notifications.

We process such information only in accordance with our Terms of Service and the
instructions of our Customers, the Workspace Owners Account Management

We use information to create and administer Mural accounts. We may send you
service, technical, legal, and other administrative emails, messages, and
notices, such as security and fraud notices. These communications are considered
part of the Services and you may not opt out of them.

If you are the Workspace Owner of a personal Workspace, we also use information
to keep track of billing, payments, account management, and similar
administrative functions.

Legitimate interests Security and Performance We use information to monitor,
investigate, research, and enhance the security and performance of our Services.
This includes using information to prevent or address security or technical
issues, analyze and monitor usage, and other similar activities. Legitimate
interests; Legal obligation Analytics and Product Development We use information
to analyze, develop, and improve the Services. For example, we may use
information to analyze how collaborators use the Services and generate
Collaboration Insights™. We may also use information to develop new features or
functionality for the Services. We may also use information to develop new
products or services. Legitimate interests; Consent Marketing and Sales

In accordance with applicable law, we may send you emails about promotions,
events, publications, or other news about Mural. You can control whether you
receive these marketing messages either through the unsubscribe mechanism
included in the emails or by contacting us directly to unsubscribe.

In addition, in accordance with applicable law, members of our Sales team may
contact you to discuss your needs and help determine which plan or service
offering may be best for you.

Legitimate interests; Consent

‍


HOW WE SHARE YOUR INFORMATION

It is important to remember that, as the controllers of Workspaces and Workspace
Content, our Customers may have their own policies and practices with respect to
the sharing and disclosure of information, and may have certain features or
functionality turned on or off accordingly. Mural does not control Customer
policies or procedures. 


Mural shares information only as it relates to our interests in operating our
business and providing the Services, and in accordance with our agreements with
Customers. More specifically, we share information in the following situations,
subject to appropriate confidentiality protections:


 * With other Authorized Users of your Workspace(s). When you use the Services
   to collaborate with others, your Contributions and certain profile
   information (such as your name and profile picture) will be shared with your
   collaborators.
   

 * With Customers. Customers (the Workspace Owners) are provided with
   information about their Workspace(s) and Authorized Users for their account
   management and other business and administrative purposes, including without
   limitation Collaboration Insights™ and usage reports. 
   

 * With Integrations. If enabled by your Workspace Owner, Mural is authorized to
   connect to and share information with Integrations to deliver the Integration
   features and functionality to you. Integrations are not owned or controlled
   by Mural and have their own policies and practices regarding the collection,
   use, transfer and disclosure of information.
   

 * With marketing partners. Mural provides a variety of webinars, research,
   white papers, and other materials and events on topics related to
   collaborative intelligence and the Services, for the benefit of Customers and
   collaborators. Sometimes these materials or events are co-created or
   co-sponsored by third parties, including without limitation Customers,
   service providers, and Integration partners. If you attend an event or access
   any such materials, we may share your information when we have your consent
   to do so.
   

 * With third party Subprocessors, service providers, or processors. We may
   engage third party companies or individuals as Subprocessors, service
   providers or processors to process information on our behalf to help develop
   or provide the Services, or support our business in other ways, such as for
   example providing virtual computing and cloud storage services. 

 * With our Affiliates. Mural may share information with its corporate
   Affiliates to help deliver the Services and for other business and marketing
   purposes.
   

 * With our auditors, attorneys, and other trusted agents or representatives,
   and for purposes of business transactions. For example, if Mural engages in a
   business transaction such as a merger, acquisition, bankruptcy, dissolution,
   reorganization, sale of some or all of Mural's assets or stock, financing,
   public offering of securities, acquisition of all or a portion of our
   business, a similar transaction or proceeding, or steps in contemplation of
   such activities (e.g. due diligence), some or all information may be shared
   or transferred with the professionals that we retain to assist us in the
   transaction, as well as with the business with which we are engaging in such
   transaction.
   

 * To comply with a valid legal request. We will share information in response
   to a valid and binding compulsory legal request or process, if we reasonably
   believe in good faith that such disclosure is relevant and necessary to the
   legal request or process. In certain situations, we may be required to
   disclose information in response to lawful requests by public authorities,
   including to meet national security or law enforcement requirements.
   

 * To enforce our rights and protect the Services. We may share information to
   the extent necessary to protect and defend our rights and the Services,
   including without limitation to enforce contracts or policies, or in
   connection with investigating and preventing fraud or security issues.
   

In addition to the situations outlined above, Mural may share information when
we have your consent to do so. Finally, we may disclose or use aggregated or
de-identified data that can no longer be reasonably linked to you for any
purpose, including without limitation for business, marketing, or research
purposes.


FOR INTERNATIONAL COLLABORATORS

The Mural Services are designed and delivered primarily in the United States
(“U.S.”) and Argentina. As such, Mural may need to transfer your information to
countries other than the one in which you live.  Wherever your information is
transferred, stored, or processed by us, we take reasonable steps to protect
your information in accordance with this Privacy Policy and applicable laws.
These measures may include implementing Standard Contractual Clauses to govern
the transfer of your information, or other means recognized by applicable laws.
By providing us with your information, you acknowledge any such transfer,
storage, or processing.  


If you have any concerns or complaints about our data processing activities, we
urge you to first try to resolve such issues directly with us or your Workspace
Owner. However, if applicable, you may make a complaint to the data protection
supervisory authority in the country where you are based, or seek a remedy
through local courts if you believe your rights have been breached.


Mural has certified to the U.S. Department of Commerce that it adheres to the
Privacy Shield principles of Notice, Choice, Accountability for Onward Transfer,
Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement
and Liability, and the Supplemental Principles (the "Privacy Shield Principles")
with respect to data transfers from the EEA, UK, and Switzerland. As a result,
Mural is subject to the investigatory and enforcement powers of the U.S. Federal
Trade Commission. If there is a conflict between this Privacy Policy and the
Privacy Shield Principles, the Privacy Shield Principles shall govern. We are
committed to applying the Privacy Shield Principles to all personal data
received from the EEA, UK, and Switzerland in reliance upon the Privacy Shield.
To learn more about the Privacy Shield program, and to view our certification
page, please visit: https://www.privacyshield.gov/.


YOUR RIGHTS WITH RESPECT TO YOUR INFORMATION

Some data privacy laws provide data subjects with certain rights with respect to
their information, such as the right to be informed of processing activities,
the right to correct inaccurate information, the right to erasure, the right to
restrict processing, and the right to receive from Mural a structured, common
and machine-readable copy of the information we process about you.  You may also
have other rights depending on the applicable law in your jurisdiction. Please
note that your data subject rights do not apply to your Contributions or any
Content that we process on behalf of your Workspace Owner, our Customer. Your
Workspace Owner is the controller of the Workspace, so if you have concerns
about your Contributions or Content, please contact your Workspace Owner.


If you wish to exercise your data subject rights, please contact us at:
compliance@mural.co. If you are an Authorized User of a Workspace, we may
redirect your request in whole or in part to your Workspace Owner for handling,
in accordance with applicable laws and our agreements with Customers. Otherwise,
please note that, pursuant to applicable law, we must be able to verify your
identity to process your data subject rights request. We cannot respond to your
request or provide you with the information you seek if we cannot verify your
identity or authority to make the request and confirm the request relates to you
and your information.


If you have any questions about Mural’s policies or procedures related to data
subject rights, please contact us at: privacy@mural.co. 


CALIFORNIA PRIVACY NOTICE

If you are a California resident, California law may provide you with additional
rights regarding our use of your “personal information” (as defined under
California law). This section describes your CCPA (California Consumer Privacy
Act) rights and explains how to exercise those rights.

Throughout this Policy, we discuss in detail the specific pieces of personal
information we collect from and about Authorized Users.  Please see the “What
Information We Collect” section above for the categories of personal information
we collect. We source, use, and share the categories of personal information we
collect from and about you consistent with the various business purposes we
discuss throughout this Policy.  See the “How We Use Your Information” and “How
We Share Your Information” sections above for more information.


Please note that the CCPA sets forth certain obligations for businesses that
“sell” personal information to third parties.  We do not engage in the “sale” of
personal information as defined under the CCPA, and have not engaged in such
activity in the past twelve months from the effective date of this Privacy
Policy.


NEVADA PRIVACY NOTICE

Under Nevada law, Nevada residents who have purchased goods or services from us
may opt out of the “sale” of “covered information” (as such terms are defined
under Nevada law) for monetary consideration. Mural does not engage in this
activity at this time, but if you are a Nevada resident and you would like to
opt out of potential future sales of your information under Nevada law, please
email us at privacy@mural.co.  Please note we may take reasonable steps to
verify your identity and the authenticity of the request.


COMPLAINTS AND DISPUTE RESOLUTION

Mural is committed to resolve complaints about your privacy and our collection,
use, transfer or disclosure of your information. Any inquiries or complaints
regarding this Privacy Policy should be directed to: privacy@mural.co.


For residents of the EU, EEA or Switzerland: Mural has further committed to
refer unresolved privacy complaints as follows:


 * Mural has committed to refer unresolved privacy complaints under the Privacy
   Shield Principles to an independent dispute resolution mechanism, the BBB EU
   PRIVACY SHIELD, operated by BBB National Programs. If you do not receive
   timely acknowledgment of your complaint, or if your complaint is not
   satisfactorily addressed, please visit
   https://bbbprograms.org/privacy-shield-complaints/ for more information and
   to file a complaint. This service is provided free of charge to you. 
   

 * If your Privacy Shield complaint cannot be resolved through the above
   channels, under certain conditions, you may invoke binding arbitration for
   some residual claims not resolved by other redress mechanisms. For more
   information, please review Privacy Shield Annex 1, available 
   at https://www.privacyshield.gov/article?id=ANNEX-I-introduction. 
   

 * Finally, you have the right to lodge a complaint with the data protection
   authority in your jurisdiction. Pursuant to Article 27 of the General Data
   Protection Regulation (GDPR), Mural has appointed the European Data
   Protection Office (EDPO) as its representative in the EU. You can contact
   EDPO regarding matters pertaining to EU data protection law by using EDPO’s
   online request form (available at https://edpo.com/gdpr-data-request/) or by
   writing to EDPO at: 

European Data Protection Office (EDPO)
Regus Block 1
Blanchardstown Corporate Park
Ballycoolen Road, Blanchardstown
Dublin D15 AKK1
Ireland


For residents of the UK:  you have the right to lodge a complaint with the data
protection authority in your jurisdiction. Pursuant to Article 27 of the UK
General Data Protection Regulation (UK GDPR), Mural has appointed EDPO UK Ltd.
as its UK GDPR representative in the UK. You can contact EDPO UK regarding
matters pertaining to the UK GDPR by using EDPO UK’s online request form
(available at https://edpo.com/uk-gdpr-data-request/) or by writing to EDPO UK
at: 

EDPO UK Ltd.
8 Northumberland Avenue
London WC2N 5BY
United Kingdom


SECURITY

Mural places great importance on the security of the Services. We have adopted a
variety of administrative, technical, physical, and organizational measures to
protect the Services against accidental or unlawful destruction, loss,
alteration, disclosure or access (a “Security Incident”) (collectively our
“Security Measures”). To learn more about Security Measures at Mural, please
visit https://www.mural.co/security. While we take reasonable steps to protect
the Services, no security system is impenetrable. We cannot and do not guarantee
that the Services will be 100% secure, that a Security Incident will not occur,
or that your communications with us will not be intercepted while being
transmitted to us. Any suspected Security Incident should be immediately brought
to our attention by contacting us at security@mural.co.


INTEGRATIONS AND THIRD PARTY SERVICES

If any part of the Services contains links to other websites or services,
whether our Affiliates or third parties, those sites or services may not operate
under this Privacy Policy. You are advised to check the privacy notices on those
other sites or in connection with those services to understand their policies
and practices on the collection, usage, transfer, and disclosure of your
information.


CHILDREN’S PRIVACY

The Services are not directed to children, and are not intended for and may not
be used by anyone under sixteen (16) years of age. We do not intentionally
collect information from children, and any use of the Services by someone who is
not at least 16 years of age is a violation of our Terms of Service. If you have
any concerns about your child’s privacy, please contact us at: privacy@mural.co.


CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be modified from time to time in our sole discretion.
Laws, regulations and industry standards evolve, which may make those changes
necessary, or we may make changes to our Services that necessitate such changes.
If that happens, we will promptly post the revised Privacy Policy to the
Services and update the “last updated” date at the top of the Privacy Policy. 
If we make changes that materially alter your privacy rights, Mural will provide
additional notice in accordance with applicable legal requirements, such as via
email or through the Services. By continuing to access and use the Services
after the effective date, you agree to be bound by the revised Privacy Policy.
If you disagree with the revised Privacy Policy, do not use the Services.


CONTACT US

Mural is committed to transparency about our collection, use, transfer and
disclosure of your information. Please direct any inquiries, comments or
questions regarding this Privacy Policy or our processing of your information
to: privacy@mural.co.

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