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Text Content

Why Bigtincan?  


WHY BIGTINCAN?

How We’re Different
Welcome to a new era of sales enablement.
Our Platform
Take the buying experience to new frontiers.
Meet Our Customers

Integrations

Pricing

Partners

Products  


OUR PRODUCTS

Readiness
Prepare and upskill your customer-facing teams.
Content
Access, personalize, and share content with buyers.
Engagement
Build meaningful engagement with powerful tools.
Our Platform
Custom tailor our platform to fit your organization's needs.

FEATURES

Sales AI

Interactive Experiences

Analytics & Reporting

Conversation Intelligence

Relationship Intelligence

Document Automation

Content Personalization

Coaching

Solutions  


BY DEPARTMENT

Sales Teams
Stay focused on sales activities and win more.
Marketing Teams
Bridge the gap between marketing and sales.
Channel Partners
Boost revenue with your channel partners.
Explore Our Platform
Prepare, engage, measure—then improve.

BY INDUSTRY

Life Sciences

Financial Services

Telecommunications

Manufacturing

Technology

Retail

Government

Energy

Resources  


RESOURCE

Resources Hub
Insights for high-performing sales teams.
Customer Stories
Meet those transforming their buyers’ experiences.
Partners
Learn how we leverage our partner network.
Integrations
Integrate Bigtincan with your current tech stack

FEATURED POST

HOW MICROLEARNING IMPROVES CUSTOMER EXPERIENCE AND CLOSES MORE DEALS

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PRIVACY POLICY

Last updated 23rd January 2023




Overview

The Information We Collect And Store

How We Use Personal Information

Information Sharing and Disclosure

Changing or Deleting Your Information

Data Retention

Bigtincan Community

Security

Our Policy Toward Children

GDPR

Contacting Us

Changes to our Privacy Policy

Privacy Notice for California Residents

Brainshark, Inc. Privacy Policy

VoiceVibes, Inc Privacy Policy

Modus Privacy Policy

imSMART Privacy Policy
OverviewThe Information We Collect And StoreHow We Use Personal
InformationInformation Sharing and DisclosureChanging or Deleting Your
InformationData RetentionBigtincan CommunitySecurityOur Policy Toward
ChildrenGDPRContacting UsChanges to our Privacy PolicyPrivacy Notice for
California ResidentsBrainshark, Inc. Privacy PolicyVoiceVibes, Inc Privacy
PolicyModus Privacy Policy imSMART Privacy Policy



BIGTINCAN PRIVACY POLICY

This Privacy Policy provides our policies and procedures for collecting, using,
and disclosing your information. Users can access the Bigtincan Hub service (the
“Service”) through our website www.Bigtincan.com, applications on Devices,
through APIs, and through third-parties. A “Device” is any computer used to
access the Bigtincan Service, including without limitation a desktop, laptop,
mobile phone, tablet, or other consumer electronic device. This Privacy Policy
governs your access of all products and services provided by Bigtincan,
regardless of how you access them, and by using our Services you consent to the
collection, transfer, processing, storage, disclosure and other uses described
in this Privacy Policy. All of the different forms of data, content, and
information described below are collectively referred to as “information.” As
indicated by the attached documentation, additional policies apply to
Bigtincan’s VoiceVibes and Brainshark products.




1. THE INFORMATION WE COLLECT AND STORE

We may collect and store the following information when running the Bigtincan
Service:

Information You Provide. When you register an account, we collect some personal
information, such as your name, phone number, credit card or other billing
information, email address and home and business postal addresses. You may also
ask us to import your contacts by giving us access to your third-party services
(for example, your email account) or to use your social networking information
if you give us access to your account on social network connection services. You
may also provide us with your contacts’ email addresses when sharing folders or
files with them. We may also receive Personal Information (for example, your
email address) through other users, for example, if they have tried to share
something with you.

Files.  We collect and store the files you upload, download, or access with the
Bigtincan Service (“Files”). If you add a file to your Bigtincan Hub that has
been previously uploaded by you or another user, we may associate all or a
portion of the previous file with your account rather than storing a duplicate.

Log Data. When you use the Service, we automatically record information from
your Device, its software, and your activity using the Services. This may
include the Device’s Internet Protocol (“IP”) address, browser type, the web
page visited before you came to our website, information you search for on our
website, locale preferences, identification numbers associated with your
Devices, your mobile carrier, date and time stamps associated with transactions,
system configuration information, metadata concerning your Files, and other
interactions with the Service.




2. HOW WE USE PERSONAL INFORMATION

Personal Information.  In the course of using the Service, we may collect
personal information that can be used to contact or identify you (“Personal
Information”). Personal Information is or may be used: (i) to provide and
improve our Service, (ii) to administer your use of the Service, (iii) to better
understand your needs and interests, (iv) to personalize and improve your
experience, and (v) to provide or offer software updates and product
announcements. If you no longer wish to receive communications from us, please
follow the “unsubscribe” instructions provided in any of those communications,
or update your account settings information.

Geo-Location Information. Some Devices allow applications to access real-time
location-based information (for example, GPS). Our mobile apps do not collect
such information from your mobile device at any time while you download or use
our mobile apps as of the date this policy went into effect but may do so in the
future with your consent to improve our Services. Some photos and videos you
place in Bigtincan Hub may contain recorded location information. We may use
this information to optimize your experience. If you do not wish to share files
embedded with your geo-location information with us, please do not upload them.
If you don’t want to store location data in your photos or videos, please
consult the documentation for your camera to turn off that feature. Also, some
of the information we collect from a Device, for example IP address, can
sometimes be used to approximate a Device’s location.

Analytics. We also collect some information (ourselves or using third party
services) using logging, such as IP address, which can sometimes be correlated
with Personal Information. We use this information for the above purposes and to
monitor and analyze use of the Service, for the Service’s technical
administration, to increase our Service’s functionality and user-friendliness,
and to verify users have the authorization needed for the Service to process
their requests.




3. INFORMATION SHARING AND DISCLOSURE

Your Use.  Any information you choose to provide should reflect how much you
want others to know about you. Please consider carefully what information you
disclose and your desired level of anonymity. We do not sell your personal
information to third parties. We may also share or disclose your information
with your consent, for example, if you use a third-party application to access
your account (see below). Through certain features of the Service, you may also
have the ability to make some of your information public. Public information may
be broadly and quickly disseminated.

Service Providers, Business Partners and Others.  We may use certain trusted
third-party companies and individuals to help us provide, analyze, and improve
the Service (including but not limited to data storage, maintenance services,
database management, web analytics, payment processing, and improvement of the
Service’s features). These third parties may have access to your information
only for purposes of performing these tasks on our behalf and under obligations
similar to those in this Privacy Policy.

Third-Party Applications.  We may share your information with a third party
application with your consent, for example when you choose to access our
Services through such an application. We are not responsible for what those
parties do with your information, so you should make sure you trust the
application and that it has a privacy policy acceptable to you.

Compliance with Laws and Law Enforcement Requests; Protection of Bigtincan’s
Rights. We may disclose to parties outside Bigtincan Hub files stored in your
Bigtincan Hub and information about you that we collect when we have a good
faith belief that disclosure is reasonably necessary to (a) comply with a law,
regulation or compulsory legal request; (b) protect the safety of any person
from death or serious bodily injury; (c) prevent fraud or abuse of Bigtincan Hub
or its users; or (d) to protect Bigtincan’s property rights. If we provide your
Bigtincan Hub files to a law enforcement agency as set forth above, we will
remove Bigtincan’s encryption from the files before providing them to law
enforcement. However, Bigtincan will not be able to decrypt any files that you
encrypted prior to storing them on Bigtincan Hub.

Business Transfers. If we are involved in a merger, acquisition, or sale of all
or a portion of our assets, your information may be transferred as part of that
transaction, but we will notify you (for example, via email and/or a prominent
notice on our website) of any change in control or use of your Personal
Information or Files, or if either become subject to a different Privacy Policy.
We will also notify you of choices you may have regarding the information.

Non-private or Non-Personal Information.  We may disclose your non-private,
aggregated, or otherwise non-personal information, such as usage statistics of
our Service.

Bigtincan’s use and transfer of information received from Google APIs to any
other app will adhere to Google API Services User Data Policy, including the
Limited Use requirements.




4. CHANGING OR DELETING YOUR INFORMATION

If you are a registered user, you may review, update, correct or delete the
Personal Information provided in your registration or account profile by
changing your “account settings.” If your personally identifiable information
changes, or if you no longer desire our service, you may update or delete it by
making the change on your account settings. In some cases we may retain copies
of your information if required by law. For questions about your Personal
Information on our Service, please contact info@Bigtincan.com. We will respond
to your inquiry within 30 days.




5. DATA RETENTION

We will retain your information for as long as your account is active or as
needed to provide you services. If you wish to cancel your account or request
that we no longer use your information to provide you services, you may delete
your account by contacting us at info@Bigtincan.com. We may retain and use your
information as necessary to comply with our legal obligations, resolve disputes,
and enforce our agreements. Consistent with these requirements, we will try to
delete your information quickly upon request. Please note, however, that there
might be latency in deleting information from our servers and backed-up versions
might exist after deletion. In addition, we do not delete from our servers files
that you have in common with other users.




6. BIGTINCAN COMMUNITY

Our Service offers publicly accessible community services such as blogs, forums,
and wikis. You should be aware that any information you provide in these areas
may be read, collected, and used by others who access them. Your posts may
remain even after you cancel your account. For questions about your Personal
Information on our Service, please contact security@bigtincan.com.

Our Site includes links to other Web sites whose privacy practices may differ
from those of Bigtincan. If you submit personal information to any of those
sites, your information is governed by their privacy statements. We encourage
you to carefully read the privacy statement of any Web site you visit.




7. SECURITY

The security of your information is important to us. When you enter sensitive
information (such as a credit card number) on our order forms, we encrypt the
transmission of that information using secure socket layer technology (SSL).

We follow generally accepted standards to protect the information submitted to
us, both during transmission and once we receive it. No method of electronic
transmission or storage is 100% secure, however. Therefore, we cannot guarantee
its absolute security. If you have any questions about security, you can contact
us at security@bigtincan.com.




8. OUR POLICY TOWARD CHILDREN

Our Services are not directed to persons under 16. We do not knowingly collect
personally identifiable information from children under 16. If a parent or
guardian becomes aware that his or her child has provided us with Personal
Information without their consent, he or she should contact us at
info@Bigtincan.com. If we become aware that a child under 16 has provided us
with Personal Information, we will take steps to delete such information from
our files.




9. GDPR

While Bigtincan applies the same level of care to its customers around the
world, Bigtincan also complies with the European Union’s General Data Protection
Regulation (“GDPR”), which went into effect on May 25, 2018. Specifically,
Bigtincan complies with the GDPR requirements by providing its customers with
full knowledge of what data is transferred from a customer environment and how
Bigtincan encrypts the data, whether it is in transit or at rest, ensuring in
accordance with the GDPR that the data would be unintelligible to any person who
is not authorized to access it. As a data processor of data provided by our
customers, you can learn more about how Bigtincan treats data and complies with
the GDPR by reviewing our Data Processing Addendum which is available upon
request from Bigtincan. We offer our customers a Data Processing Addendum (DPA),
which incorporates the EU Standard Contractual Clauses (“SCCs,” also known as
the EU Model Clauses) and include Bigtincan’s organizational measures. The SCCs
are a valid and recognized legal mechanism for ensuring that any personal data
leaving the European Economic Area will be transferred in compliance with EU
data-protection laws. Bigtincan continues to maintain the operational processes
necessary to meet the stringent SCC requirements for the transfer of personal
data to processors, which in turn allows us to provide our customers with
contractual guarantees for the protection of their personal data. Bigtincan
offers a DPA that includes GDPR-specific language to ensure that Bigtincan and
our customers have appropriate GDPR-specific contractual provisions in place to
allow for the legal transfer of personal data.

If you have questions regarding either of these statements or to obtain
additional documentation, you may view our website or contact us
at gdpr@Bigtincan.com.




10.  CONTACTING US

If you have any questions about this Privacy Policy, please contact us at: Level
6, 338 Pitt Street, New South Wales Australia 2000, or security@bigtincan.com.




11.  CHANGES TO OUR PRIVACY POLICY

This Privacy Policy may change from time to time. If we make a change to this
privacy policy that we believe materially reduces your rights, we will provide
you with notice (for example, by email). And we may provide notice of changes in
other circumstances as well. By continuing to use the Service after those
changes become effective, you agree to be bound by the revised Privacy Policy.




PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Effective Date: January 1, 2020

Last Reviewed on: February 15, 2020

This Privacy Notice for California Residents supplements the information
contained in Bigtincan’s Privacy policy and applies solely to all visitors,
users, and others who reside in the State of California (“consumers” or “you”).
We adopt this notice to comply with the California Consumer Privacy Act of 2018
(CCPA) and any terms defined in the CCPA have the same meaning when used in this
notice.

INFORMATION WE COLLECT

Our Website collects information that identifies, relates to, describes,
references, is capable of being associated with, or could reasonably be linked,
directly or indirectly, with a particular consumer or device (“personal
information”). In particular, Bigtincan’s website, https://www.bigtincan.com/
(“Website”), has collected the following categories of personal information from
its consumers in California within the last twelve (12) months:

CategoryExamplesCollectedA. Identifiers.Name, email address, telephone number,
Internet Protocol address.YESB. Personal information categories listed in the
California Customer Records statute (Cal. Civ. Code § 1798.80(e)).Name, email
address, telephone number.



Some personal information included in this category may overlap with other
categories.

YESC. Protected classification characteristics under California or federal
law.Age (40 years or older), race, color, ancestry, national origin,
citizenship, religion or creed, marital status, medical condition, physical or
mental disability, sex (including gender, gender identity, gender expression,
pregnancy or childbirth and related medical conditions), sexual orientation,
veteran or military status, genetic information (including familial genetic
information).NOD. Commercial information.Records of Bigtincan products or
services considered on our website.YESE. Biometric information.Genetic,
physiological, behavioral, and biological characteristics, or activity patterns
used to extract a template or other identifier or identifying information, such
as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke,
gait, or other physical patterns, and sleep, health, or exercise data.NOF.
Internet or other similar network activity.Browsing history, search history,
information on a consumer’s interaction with a website, application, or
advertisement.YESG. Geolocation data.Physical location or movements.YESH.
Sensory data.Audio, electronic, visual, thermal, olfactory, or similar
information.NOI. Professional or employment-related information.Current or past
job history or performance evaluations.NOJ. Non-public education information
(per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34
C.F.R. Part 99)).Education records directly related to a student maintained by
an educational institution or party acting on its behalf, such as grades,
transcripts, class lists, student schedules, student identification codes,
student financial information, or student disciplinary records.NOK. Inferences
drawn from other personal information.Profile reflecting a person’s preferences,
characteristics, psychological trends, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes.NO

 

Personal information does not include:

 * Publicly available information from government records.
 * Deidentified or aggregated consumer information.
 * Information excluded from the CCPA’s scope, like:
   * Health or medical information covered by the Health Insurance Portability
     and Accountability Act of 1996 (HIPAA) and the California Confidentiality
     of Medical Information Act (CMIA) or clinical trial data;
   * Personal information covered by certain sector-specific privacy laws,
     including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act
     (GLBA) or California Financial Information Privacy Act (FIPA), and the
     Driver’s Privacy Protection Act of 1994.

Bigtincan obtains the categories of personal information listed above from the
following categories of sources:

 * Directly from you. For example, from forms you complete.
 * Indirectly from you. For example, from observing your actions on our Website.

USE OF PERSONAL INFORMATION

We may use, or disclose the personal information we collect for one or more of
the following business purposes:

 * To fulfill or meet the reason you provided the information. For example, if
   you share your name and contact information or ask a question about our
   products or services, we will use that personal information to respond to
   your inquiry.
 * To provide, support, personalize, and develop our Website, products, and
   services.
 * To process your information requests.
 * To provide you with support and to respond to your inquiries, including to
   investigate and address your concerns and monitor and improve our responses.
 * To personalize your Website experience and to deliver content and product and
   service offerings relevant to your interests, including targeted offers and
   ads through our Website, third-party sites, and via email or text message
   (with your consent, where required by law).
 * To help maintain the safety, security, and integrity of our Website, products
   and services, databases and other technology assets, and business.
 * For testing, research, analysis, and product development, including to
   develop and improve our Website, products, and services.
 * To respond to law enforcement requests and as required by applicable law,
   court order, or governmental regulations.
 * As described to you when collecting your personal information or as otherwise
   set forth in the CCPA.

Bigtincan will not collect additional categories of personal information or use
the personal information we collected for materially different, unrelated, or
incompatible purposes without providing you notice.

SHARING PERSONAL INFORMATION

Bigtincan may disclose your personal information to a third party for a business
purpose. When we disclose personal information for a business purpose, we enter
a contract that describes the purpose and requires the recipient to both keep
that personal information confidential and not use it for any purpose except
performing the contract.

We share your personal information with the following categories of third
parties:

 * Service providers.
 * Data aggregators.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following
categories of personal information for a business purpose:

[Category A: Identifiers.]

[Category B: California Customer Records personal information categories.]

[Category D: Commercial information.]

[Category F: Internet or other similar network activity.]

[Category G: Geolocation data.]

We disclose your personal information for a business purpose to the following
categories of third parties:

 * Service providers.
 * Data aggregators

Sales of Personal Information

In the preceding twelve (12) months, Company has not sold personal information

YOUR RIGHTS AND CHOICES

The CCPA provides consumers (California residents) with specific rights
regarding their personal information. This section describes your CCPA rights
and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Bigtincan disclose certain information to you
about our collection and use of your personal information over the past 12
months. Once we receive and confirm your verifiable consumer request
(see Exercising Access, Data Portability, and Deletion Rights), we will disclose
to you:

 * The categories of personal information we collected about you.
 * The categories of sources for the personal information we collected about
   you.
 * Our business or commercial purpose for collecting that personal information.
 * The categories of third parties with whom we share that personal information.
 * The specific pieces of personal information we collected about you (also
   called a data portability request).
 * If we disclosed your personal information for a business purpose, providing
   disclosures for a business purpose, identifying the personal information
   categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Bigtincan delete any of your personal
information that we collected from you and retained, subject to certain
exceptions. Once we receive and confirm your verifiable consumer request
(see Exercising Access, Data Portability, and Deletion Rights), we will delete
(and direct our service providers to delete) your personal information from our
records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for
us or our service provider(s) to:

 1.  Complete the transaction for which we collected the personal information,
    provide a good or service that you requested, take actions reasonably
    anticipated within the context of our ongoing business relationship with
    you, or otherwise perform our contract with you.
 2.  Detect security incidents, protect against malicious, deceptive,
    fraudulent, or illegal activity, or prosecute those responsible for such
    activities.
 3.  Debug products to identify and repair errors that impair existing intended
    functionality.
 4.  Exercise free speech, ensure the right of another consumer to exercise
    their free speech rights, or exercise another right provided for by law.
 5.  Comply with the California Electronic Communications Privacy Act (Cal.
    Penal Code § 1546 et. seq.).
 6.  Enable solely internal uses that are reasonably aligned with consumer
    expectations based on your relationship with us.
 7.  Comply with a legal, regulatory or other governmental obligation.
 8.  Make other internal and lawful uses of that information that are compatible
    with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above,
please submit a verifiable consumer request to us by either:

 *  Phone: (617) 981-7557
 *  Email: security@bigtincan.com
 *  Physical Address: Bigtincan Mobile Pty Ltd, Level 6, 338 Pitt Street,
   Sydney, New South Wales, Australia 2000.

Only you, or a person registered with the California Secretary of State that you
authorize to act on your behalf, may make a verifiable consumer request related
to your personal information. You may also make a verifiable consumer request on
behalf of your minor child.

You may only make a verifiable consumer request for access or data portability
twice within a 12-month period. The verifiable consumer request 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 cannot respond to your request or provide you with personal information if we
cannot verify your identity or authority to make the request and confirm the
personal information relates to you.

Making a verifiable consumer request does not require you to create an account
with us. However, we do consider requests made through your password-protected
account sufficiently verified when the request relates to personal information
associated with that specific account.

We will only use personal information provided in a verifiable consumer request
to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within thirty (30) days
of its receipt. If we require more time (up to 90 days), we will inform you of
the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that
account. If you do not have an account with us, we will deliver our written
response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the
verifiable consumer request’s receipt. The response we provide will also explain
the reasons we cannot comply with a request, if applicable. For data portability
requests, we will select a format to provide your personal information that is
readily useable and should allow you to transmit the information from one entity
to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request
unless it is excessive, repetitive, or manifestly unfounded. If we determine
that the request warrants a fee, we will tell you why we made that decision and
provide you with a cost estimate before completing your request.

OTHER CALIFORNIA PRIVACY RIGHTS

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users
of our Website that are California residents to request certain information
regarding our disclosure of personal information to third parties for their
direct marketing purposes. To make such a request, please send an email to
privacy@bigtincan.com or write us at:

Attn: Bigtincan Privacy officer

Phone: (617) 981-7557

Email: security@bigtincan.com

Address: Bigtincan Mobile Pty Ltd, Level 6, 338 Pitt Street, Sydney, New South
Wales, Australia 2000

CHANGES TO OUR PRIVACY NOTICE

Bigtincan reserves the right to amend this privacy notice at our discretion and
at any time. When we make changes to this privacy notice, we will post the
updated notice on the Website and update the notice’s effective date. Your
continued use of our Website following the posting of changes constitutes your
acceptance of such changes.

CONTACT INFORMATION

Bigtincan reserves the right to amend this privacy notice at our discretion and
at any time. When we make changes to this privacy notice, we will post the
updated notice on the Website and update the notice’s effective date. Your
continued use of our Website following the posting of changes constitutes your
acceptance of such changes.

Phone: (617) 981-7557

Website: https://www.bigtincan.com/

Email: security@bigtincan.com

Postal Address:

Bigtincan Mobile Pty Ltd

Attn: Legal – Global Privacy Officer

Level 6, 338 Pitt Street, Sydney, New South Wales, Australia 2000




BRAINSHARK, INC. PRIVACY POLICY

Brainshark, Inc. a wholly owned subsidiary of Bigtincan (“Brainshark, “we,” or
“us”) is committed to protecting the privacy of your information and wants you
to be familiar with how we collect, use, and disclose information. This Privacy
Policy describes our information and privacy practices with regard to our
websites and applications.


1. WEBSITES COVERED

This Privacy Policy covers the information and privacy practices of Brainshark
on all of its websites, including but not limited to https://www.brainshark.com,
and all of its applications. including but not limited to mobile applications
(collectively referred to as “Brainshark’s Websites” or “Websites”). The use of
information collected through Brainshark’s services will be limited to the
purpose of providing and enhancing the service for which the Customer has
engaged Brainshark.

Brainshark’s Websites may contain links to third party sites that are not owned
or controlled by Brainshark. Additionally, Brainshark’s services are used by
customers to deliver video presentations that are embedded and linked within
their own websites and third-party sites. Brainshark is not responsible for the
information practices or content of its customers or third-party sites. Please
be aware that we are not responsible for the privacy practices of such other
sites. We encourage you to be aware when you leave Brainshark’s Websites and to
read the privacy policies of each and every website that collects personally
identifiable information. This Privacy Policy applies only to information
collected by Brainshark’s Websites.


2. INFORMATION COLLECTED

Brainshark offers a variety of applications and services that are collectively
referred to as the “Services.” Brainshark collects information from individuals
who visit Brainshark’s Websites (“Visitors”) and individuals who register to use
the Services (“Customers”). Customers include both paying subscribers as well as
subscribers of its free services. Customers should refer to www.brainshark.com
and Brainshark’s Terms and Conditions
(www.brainshark.com/company/terms-conditions) for the appropriate offering.

The types of information Brainshark collects may include:

 * Information you provide to Brainshark – When expressing an interest in
   obtaining additional information about the Services or registering to use the
   Services, Brainshark may require you to provide personal contact information
   such as your name, your company name, your job title or role, your address,
   your phone number, and your email address.
 * Website navigational information – Brainshark uses commonly used information-
   gathering tools, such as cookies and Web beacons, to collect information as
   you navigate Brainshark’s Websites (“Website Navigational Information”). This
   Website Navigational Information includes standard information from your web
   browser (such as browser type, version, and language), your Internet Protocol
   (“IP”) address, and the actions you take on Brainshark’s Websites (such as,
   pages viewed, links clicked).
 * Information you publish to Brainshark blogs or public portals – Brainshark’s
   Websites include public blogs and portals that allow Visitors to submit and
   publish comments.
 * Billing information – Where Brainshark permits purchases to be made directly
   through its Websites, Brainshark may require you to provide billing
   information, such as your billing name, address, and email address.
 * Information you provide to Customers – A capability of the Services allows
   Customers to request registration information from viewers of their video
   presentation content. For example, presentations created by our Customers may
   include a guest book registration form. Brainshark is not responsible for the
   information practices of its Customers, and does not access this information
   except with a Customer’s permission to provide support and assistance.


3. USE OF INFORMATION COLLECTED

Brainshark uses data about Visitors and Customers to perform the following
actions:

 * To respond to your request – such as to create a Brainshark account, provide
   login information for a webinar for which you have registered, or provide
   technical support.
 * For marketing purposes – Brainshark may use information that Visitors provide
   to contact them to further discuss their interest in the Services and to send
   them information regarding Brainshark or its Services.
 * To improve Brainshark’s Websites and products – Brainshark may use Website
   Navigational Information to provide Visitors and Customers with relevant
   content and in the aggregate to identify trends and usage patterns.
 * To deliver messages that help you use the Service – As part of helping its
   Customers use the Service effectively, Brainshark communicates with its
   Customers about new features and product releases, best practices, scheduled
   site maintenance notifications, customer events, and more. To increase the
   relevancy of this information, communications may be customized to your
   designated user role within an application (for example: administrator,
   author), the products or editions you have specifically licensed, or your
   usage of the application.
 * To process your payment – Brainshark uses billing information solely to
   process payment for Services for which the Customer has provided that
   information. Brainshark utilizes a third-party payment service to process
   credit card payments. Credit card information is sent directly by you to the
   third-party payment service. Brainshark does not have access to your full
   credit card number and does not store such information in its own systems.
   Brainshark is not responsible for the third-party payment service’s
   information practices or compliance with any applicable laws.
 * To deliver the features of the Service – Customers use the Services to
   create, share, and track online and mobile video presentations. As part of
   the sharing feature, Customers may provide the email address of an individual
   with whom they wish to share presentations via the Services. Brainshark uses
   this information only to provide the share function of the Services. Tracking
   information includes the date and time that a presentation was viewed, IP
   address and location, what portions of the presentation were viewed and in
   what order, and responses to interactive questions or surveys. Individuals
   may be associated with this tracking information, either through information
   they provide to the Customer, or by a unique identifier that the Customer has
   associated with an individual and has passed to a personalized presentation
   URL. Reporting and notification features enable Customers to receive tracking
   information via emailed reports or to pass data to their other systems.
   Brainshark does not use or access information about individuals that is
   collected by its Customers in their use of the Services except with such
   Customers’ permission in providing support and assistance. Brainshark does
   not sell this information.


4. SHARING OF INFORMATION COLLECTED

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

Unless described in this Privacy Policy, Brainshark does not share, sell, rent,
or trade any information collected through its Websites or Services with third
parties for their promotional purposes.

Brainshark occasionally partners with third parties who co-sponsor events with
Brainshark (such as webinars and other live events). In these cases, both
parties may share personal information that you provide when registering for the
co-sponsored event to allow the co- sponsor to contact you regarding products,
programs, services, and promotions that they believe may be of interest to you.
While Brainshark chooses to partner with reputable third parties that respect
your information, Brainshark is not responsible for the information practices of
its third-party partners.

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

We reserve the right to disclose your information as required by law and when we
believe that disclosure is necessary to protect our rights or to comply with a
judicial proceeding, court order, or legal process.

In the event that Brainshark is a party to a merger with, or acquisition by,
another company, or its assets are otherwise entirely or substantially acquired,
your information will be among the assets transferred. You will be notified via
email or prominent notice on our Websites, for thirty (30) days or the timeframe
as defined and required by statute or regulation, of any such change in
ownership or control of your personal information. Information concerning
deletion or removal of your personal information or any changes that you wish to
make to your personal information will be made available at that time.


5. COMMUNICATIONS PREFERENCES

Brainshark partners with third parties to either display advertising on our
website or to manage our advertising on other sites. Our third-party partners
may use technologies such as cookies to gather information about your activities
on this site and other sites in order to provide you advertising based upon your
browsing activities and interests. If you wish to not have this information used
for the purpose of serving you interest-based ads, you may elect to turn off
cookies or use your browser’s privacy settings to mask your identity, or you may
opt-out by the following consumer choice mechanisms, please visit:

Digital Advertising Alliance (DAA)’s self-regulatory opt-out page
(http://optout.aboutads.info/) and mobile application-based “AppChoices”
download page (https://youradchoices.com/appchoices)

 * European Interactive Digital Advertising Alliance (EDAA)’s consumer opt-out
   page (http://youronlinechoices.eu)
 * Network Advertising Initiative (NAI)’s self-regulatory opt-out page
   (http://optout.networkadvertising.org/)

Please note you will continue to receive generic ads.

Brainshark offers Customers and Visitors who provide contact information a means
to choose how Brainshark uses the information provided. Visitors and any
recipients of marketing messages from Brainshark may click on the “unsubscribe”
link located on the bottom of the Brainshark’s marketing emails. Customers can
change their communication preferences at any time through their profile page
when logged in to the Service or you can decide not to receive communications
that help you use the Service.

Some email communications are part of the Services, such as the ability to
receive reports or view notifications via email. For help in managing these
emails,
contact support@brainshark.com.

Customers do not have the option to cancel receiving transactional emails
related to their account with Brainshark or the Services.

For certain editions of the Services, Brainshark may need to communicate with
the primary business contact or site administrators of a Customer’s company.


6. PUBLIC BLOGS, PORTALS, AND CUSTOMER ARTICLES

Brainshark’s Websites include public blogs, portals, and customer articles that
allow Visitors to submit and post comments. Brainshark also provides portal
solutions for its customers.

Any personal information you choose to submit in these forums may be read,
collected, or used by others who visit these forums. Brainshark is not
responsible for the personal information you choose to submit to public forums
for posting. If you do not want information to be public, please do not post it
to these forums. To request removal of your personal information from our blog,
portals, or customer articles contact us at support@brainshark.com. In some
cases, Brainshark may not be able to remove your personal information, but we
will notify you via email if we are unable to do so and briefly explain the
reasons.

Our blog is also managed by a third-party application that may require you to
register to post a comment. We do not have access or control of the information
posted to the blog managed by that third-party application. You will need to
contact or login into the third-party application if you want the personal
information that was posted to the comments section removed. To learn how the
third-party application uses your information, please review their privacy
policy.


7. TRANSFER OF INFORMATION

Your information may be transferred to and maintained on information systems
located outside of your state, province, or other governmental jurisdiction
where the privacy laws may not be as protective as those in your jurisdiction.
If you are located outside of the United States and choose to provide personal
information to us, Brainshark transfers the information to the United States and
processes it there. Regarding these data flows, Brainshark participates in the
EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks (“Privacy Shield”), and is
committed to applying the Privacy Shield Principles to all personal information
received from countries in the European Economic Area (EEA) and Switzerland in
reliance on the Privacy Shield.


8. EU-U.S. AND SWISS-US PRIVACY SHIELD

Brainshark complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S.
Privacy Shield Frameworks (Privacy Shield) as set forth by the U.S. Department
of Commerce regarding the collection, use, and retention of personal information
transferred from the European Union and the United Kingdom and Switzerland, to
the United States in reliance on Privacy Shield. Brainshark has certified to the
Department of Commerce that it adheres to the Privacy Shield Principles with
respect to such information. 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 our
certification, please visit https://www.privacyshield.gov/.

Brainshark is responsible for the processing of personal data it receives, under
each Privacy Shield Framework, and subsequently transfers to a third party
acting as an agent on its behalf. Brainshark complies with the Privacy Shield
Principles for all onward transfers of personal data from the EU and
Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy
Shield Frameworks, Brainshark is subject to the regulatory enforcement powers of
the U.S. Federal Trade Commission. In certain situations, we may be required to
disclose personal data in response to lawful requests by public authorities,
including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed
satisfactorily, please contact our U.S.-based third party dispute resolution
provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website
[https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may
invoke binding arbitration when other dispute resolution procedures have been
exhausted.


9. PASSIVE COLLECTION

As is true of most websites, we gather certain information automatically. This
information may include Internet protocol (IP) addresses, browser type, Internet
service provider (ISP), referring/exit pages, the files viewed on our site
(e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or
clickstream data to analyze trends in the aggregate and administer the site.


10. TRACKING TECHNOLOGIES

Brainshark and its partners use cookies or similar technologies to analyze
trends, administer the website, track users’ movements around the website, and
to gather demographic information about our user base as a whole. You can
control the use of cookies at the individual browser level, but if you choose to
disable cookies, it may limit your use of certain features or functions on our
Websites or Services.


11. CHILDRENS’ PRIVACY

Brainshark’s Websites and the Services are not directed to individuals under the
age of 18. As Brainshark provides Services to businesses and business
professionals, Brainshark does not knowingly contact or collect personal
information from children under the age of 16. If an adult becomes aware that a
child in their care has provided Brainshark with personal information, they
should contact us at support@brainshark.com. If you believe that we have
mistakenly or unintention ally collected such information, please notify us at
the contact address below so that we may immediately delete the information from
our servers.


12. SECURITY

To prevent unauthorized access or disclosure, to maintain data accuracy, to
allow only the appropriate exercise of Customers’ personal information while
also protecting the confidentiality, integrity, and availability of Customers’
personal information, Brainshark employs a variety of industry standard security
technologies. Security is provided on the data, application, and hosting level.
The security infrastructure includes a physically secure data center, proven
firewall protection, intrusion prevention measures, role-based authorization,
and additional proprietary security measures. Additional security of Customer
login and presentation content is provided as part of Brainshark’s Services.
Please refer to the products section of www.brainshark.com or contact
Brainshark’s sales team for more information about included features and options
that can be configured specifically for Customers’ needs. These options vary by
the product licensed.

Brainshark limits access to Customers’ personal information and data to those
Brainshark and third-party persons who have a specific business purpose for
maintaining and processing such information. Brainshark employees and
third-party persons who have access to Customers’ personal information are made
aware of their responsibilities to protect the confidentiality, integrity, and
availability of that information and have been provided training or instructions
on how to do so.

When you enter personal or sensitive information on Brainshark’s order forms,
Brainshark will encrypt the transmission of that information using reasonable
security.

If you have any questions about security on our Websites, you can contact us at
support@brainshark.com.


13. DATA SUBJECTS’ RIGHTS

Upon request, Brainshark will provide you with information about whether we
hold, or process on behalf of a third party, any of your personal information.
To request this information please contact us at support@brainshark.com.

You may access, correct, or request deletion of your personal information by
logging in to your account, contacting us at support@brainshark.com or by
completing this form (www.brainshark.com/contact-sales).

Brainshark collects information under the direction of its Customers and has no
direct relationship with the individuals whose personal information it
processes. If you are an individual who would no longer like to be contacted by
one of our Customers through the use of our Services, please contact the
Customer that you interact with directly. An individual who seeks access, or who
seeks to correct, amend, or delete inaccurate data should direct their query to
the applicable Customer (the data controller). If requested to remove data, we
will respond within a reasonable timeframe.

We may transfer personal information to companies that help us provide our
Services. Transfers to subsequent third parties are covered by the service
agreements with our Customers.

In certain circumstances we may be required by law to retain your personal
information including personal information we process on behalf of our Customers
or may need to retain your personal information in order to continue providing a
Service.


14. RIGHT TO LODGE A COMPLAINT

If you believe that Brainshark is not processing your personal information in
accordance with the requirements set out herein or applicable EEA data
protection laws, you can at any time lodge a complaint with the data protection
authority of the EEA country in which you live.

For more information on how to contact the EU Data Protection Authorities, click
here (http://ec.europa.eu/newsroom/article29/news-overview.cfm).

For more information on how to contact the Swiss Federal Data Protection and
Information Commissioner, click here
(https://www.edoeb.admin.ch/edoeb/en/home.html).


15. ADDITIONAL IMPORTANT INFORMATION SHARING WITH SERVICE PROVIDERS

We may share your information with third parties who provide services on our
behalf to help with our business activities. These companies are authorized to
use your personal information only as necessary to provide these services to us.

These services may include:

 * Payment processing
 * Providing customer service
 * Sending marketing communications

Brainshark reserves the right to use or disclose information provided if
required by judicial inquiry, court order, law, or regulation and/or Terms and
Conditions or if Brainshark reasonably believes that use or disclosure is
necessary to protect Brainshark’s rights.


16. SOCIAL MEDIA WIDGETS

Brainshark’s Websites may include social media features, such as the Facebook
“Like” button, and widgets, such as the “Share This” button or interactive
mini-programs that run on our Websites. These features may collect your Internet
protocol address, which page you are visiting on our Websites, and may set a
cookie to enable the feature to function properly. Social media features and
widgets are either hosted by a third party or hosted directly on our Websites.
Your interactions with these features or widgets are governed by the privacy
statement of the company providing them.


17. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect changes to our
information and privacy practices. If we make any material changes, we will
notify you by email (sent to the e- mail address specified in your account) or
by means of a written notice on our Websites prior to the change becoming
effective. We encourage you to periodically review this page for the latest
information about Brainshark’s information and privacy practices.


18. CONTACTING US

Contact info@brainshark.com for questions regarding this Privacy Policy or the
information and privacy practices of Brainshark’s Websites.

If you are a Customer and would like help managing your communication
preferences, please contact support@brainshark.com.

Brainshark’s data protection officer is Craig Tata (privacy@brainshark.com)

Brainshark’s address is:
Brainshark, Inc.
260 Charles Street – Suite 101
Waltham, MA 02453




VOICEVIBES, INC PRIVACY POLICY

This Privacy Policy describes how Voice Vibes, Inc.(“VoiceVibes”)may collect
information from or about you when you visit our website and use our service.
VoiceVibes values your privacy and is providing this Privacy Policy to explain
what information we collect and how that information may be used by VoiceVibes
when you interact with VoiceVibes online.

This Privacy Policy includes the following:

 1.  OUR COMMITMENT TO YOUR PRIVACY
 2.  THE INFORMATION AND DATA WE COLLECT
 3.  HOW WE USE YOUR DATA
 4.  WHAT DATA OR INFORMATION MAY BE SHARED WITH THIRD PARTIES
 5.  HOW LONG WE SAVE YOUR DATA
 6.  HOW TO EDIT OR MODIFY DATA
 7.  HOW TO CANCEL YOUR VOICEVIBES ACCOUNT
 8.  CHILDREN’S PRIVACY
 9.  INFORMATION SECURITY
 10.  ADDITIONAL INFORMATION FOR EU, UK AND SWITZERLAND BASED USERS 11. PRIVACY
     NOTICE FOR CALIFORNIA RESIDENTS
 11. WHEN THE VOICEVIBES PRIVACY POLICY APPLIES/LINKS
 12. CHANGES TO PRIVACY POLICY
 13. ACCEPTANCE
 14. CONTACT


1. OUR COMMITMENT TO YOUR PRIVACY

Introduction – Our goal at VoiceVibes is to help you achieve your goals of
learning to communicate more effectively. As we continue to develop our service,
we are committed to respecting your privacy and protecting your personal
information. We have created our Privacy Policy to inform you about the types of
personal information that we may collect from you and how it will be handled.
Please take a few minutes to review our policy before using our service or
submitting any personal information.

International Users – VoiceVibes is hosted and operated entirely in the United
States

and is subject to United States law. Any personal information that you provide
to VoiceVibes is being transferred to VoiceVibes solely in the United States and
will be hosted on United States servers. You consent to the transfer of your
personal information totheUnitedStates.
IfyouareavisitorfromtheEuropeanUnion,UnitedKingdomor Switzerland, please see
“HOW WE HANDLE DATA FROM VISITORS FROM THE UNITED KINGDOM, SWITZERLAND OR ANY
COUNTRY BELONGING TO THE EUROPEAN UNION,” below.


2. THE INFORMATION AND DATA WE COLLECT

General Site Usage
When using the Website for information purposes only, i.e. when you do not
provide us with any information, VoiceVibes only collects the personal data that
your browser transmits to our server. If you wish to view our Website,
VoiceVibes collects the following data, which is technically necessary for us to
display our Website to you and to ensure stability and security (Legal basis is
Art. 6 para. 1 sentence 1 lit. f GDPR)

 * IP address,
 * Date and time of the request,
 * Time zone,
 * Content of the request (specific page),
 * Access status/HTTP status code,
 * Amount of data transferred in each case,
 * Website from which the request comes, • Browser,
 * Operating system and its interface,
 * Language and version of the browser software.

In addition to the aforementioned data, cookies are stored on your computer when
you use our Website. Cookies are small text files that are stored on your hard
disk by the browser you use and through which certain information flows to the
user that places the cookie. Cookies cannot run programs or transmit viruses to
your computer. They serve to make the Internet more user-friendly and effective
overall.

Use of cookies and HTML 5 Local Storage:
a) This Website uses the following types of cookies, the scope and functionality
of which are explained below:

 * Transient cookies (see c),
 * Persistent cookies (see d).

b) In addition to our use of cookies, this website also uses HTML 5 Local
Storage to store website preferences and session information.

c) Transient cookies are deleted automatically when you close your browser. This
includes session cookies, which store a so-called session ID that can assign
different requests of your browser to the joint session. This will allow your
computer to be recognized when you return to our Website. Session cookies are
deleted when you log out or close your browser.

d) Persistent cookies and HTML 5 Local Storage are automatically deleted after a
specified period, which may vary depending on the cookie or Local Storage
setting. You can delete cookies and Local Storage at any time in the security
settings of your browser.

e) You can configure your browser settings according to your wishes and refuse
to accept HTML 5 Local Storage, third party cookies or any cookies, for example.
Please note that, in this event, you may not be able to use all functions of our
Website.

When You Create an Account – In order to access VoiceVibes’ services, we require
users to register with us. When you create an account with VoiceVibes, we ask
for some personal information, including your name, email address, year of
birth, etc.

Use of Collected Information – We use the information we collect in the
following ways: • To 0perate, maintain, and improve our services. For example,
we can use audio recordings for internal R&D purposes to improve the quality of
VoiceVibes’ services

 * To create your account, identify you as a user, and customize VoiceVibes
   services for your account.
 * To send you administrative communications. These may include administrative
   emails, confirmations, technical notices, surveys, updates, and security
   alerts.
 * To respond to your comments and questions and provide you with user support.
 * To process payments which you make to VoiceVibes.
 * To protect, investigate, and deter against fraudulent, unauthorized, or
   illegal
   activity.

Email – Your email address will be your VoiceVibes account user name, which you
will use to log-on to your account. We do not display your email address to
other users. Instead, others will see the name or nickname you enter in your
profile settings.

Other Registration Information – No other registration information will be made
public.

When You Add Information to Your Account – You can update your VoiceVibes
account or add information to your account at any time. Whenever you add this
type of information, we collect it and store it in your VoiceVibes account.

When You Use the Mobile App – You will be invited to download the VoiceVibes
Recorder App and enter your username and password. This App enables you to
record your speeches and upload them for analysis by the VoiceVibes service.

When You Upload Audio in Your VoiceVibes Account – When you upload your voice
audio data, recorded through the mobile App, web browser, or by other means, the
audio file will be transferred to our servers. This data is stored and used to
provide the VoiceVibes service and is associated with your account. Each time an
upload occurs, we log data about the transmission. Some examples of the log data
are the sync time, date, and the IP address used when uploading.

When you Share your Audio File with an Instructor or a Peer – When your account
is associated with an organization, access to your audio recordings, audio
scores/ratings and associated metadata may be made available to instructors and
administrators for thatorganization.
See“WhatDataorInformationMayBeSharedwithThirdParties,” below.

When You Make Purchases Through Our Website – We do not view or store your
credit card information. That information is handled by our third-party payment
processor. If you are logged into your VoiceVibes account when you make a
purchase through our website, we associate that order with your VoiceVibes
account.

When You Contact Us for Help – Whenever you contact VoiceVibes for assistance,
we collect your name and email address along with additional information you
provide in your request so that we can provide you with adequate assistance and
improve the VoiceVibes service. You can also contact VoiceVibes through public
forums such as Facebook or Twitter, but we cannot guarantee or maintain the
privacy of your communications to us if you choose these public forums.

Information from Other Sources – We do not collect any information about you
from other sources outside of your interactions with the VoiceVibes mobile App
and/or service unless you or your organization have provided permission to do
so.


3. HOW WE USE YOUR DATA

General Administration – We use the information that you share with us to
provide you with new and improved services and to better understand your needs.
For example, we use the information you provide for internal research and
development, business decision making, website trend analysis, record keeping,
demographic reporting, finalizing your registration, communication with you
regarding service assistance, and notifying you about updates to our services
and policies.

Speech Rating System – A large component to the VoiceVibes service is rating
your voice recordings to assist you in your goal of more effective
communication. The voice recordings that you upload to your VoiceVibes account
will be rated through VoiceVibes software, and in rare cases may be rated by
individuals against certain criteria. These individual raters will not access
other personally identifiable information. Short samples from your speech that
do not contain personally identifiable information (other than your voice
characteristics) may be manually clipped and saved under an anonymous
identification number. These audio samples may be made available to third-party
raters via a VoiceVibes-hosted website or a third-party website. You may opt out
of this individual rating service by contacting privacyofficer@myvoicevibes.com.


4. WHAT DATA OR INFORMATION MAY BE SHARED WITH THIRD PARTIES

Overview – We do not sell, trade, or otherwise transfer your personally
identifiable information to third parties. This does not include, however,
trusted third parties who assist us in operating our website, conducting our
business, or servicing you, so long as those parties agree to keep your
information confidential. In addition, we may also release your information when
we believe that it is appropriate to comply with the law, enforce our website
policies, or protect the rights, property, or safety of VoiceVibes, its users,
or others.

Sharing with Your Group – In the event that your account is associated with an
organization, access to your audio recordings, audio scores/ratings and
associated metadata may be made available to instructors and administrators for
that organization — for example, recordings in an account associated with a
college or university may be visible to the relevant instructors. Additionally,
when recordings are “shared” by you in the VoiceVibes application, this allows
instructors and/or other VoiceVibes users in the same class or group to access
them. Instructors and administrators may develop reports containing audio
scores/ratings, your name, and associated metadata to determine trends and
progress of the organization’s VoiceVibes participants.

Third-Party Channel-Partners –Wemayshareinformationforresearchpurposes. If you
signed up through a link or site provided by a Channel Partner, such as the
Center for Creative Leadership (CCL), you may have executed terms that vary from
this agreement. In some cases, the Channel Partner has been granted the right to
own or use your data in different ways. To access your agreement, refer to your
agreement with the third-party organization that provided your VoiceVibes
account invite link.

Third-Party Agents – We may employ individuals or other companies to perform
business functions on our behalf. These trusted entities may have access to
information that is required to perform their services but are prohibited by
contract and commitments to your confidentiality from utilizing the information
for any other purpose. Thesetypesofservicesmayincludedataanalysis, transcription
of audio recording, rating collection, payment processing, information
technology and related infrastructure, email delivery, and other similar
services.

Disclosure to Government Authorities, Etc. – We may share personal information
as we believe necessary or appropriate (a) to comply with applicable laws; (b)
to comply with lawful requests and legal process, including to respond to
requests from public and government authorities to meet national security or law
enforcement requirements; (c) to enforce our Policy; and (d) to protect our
rights, privacy, safety or property, and/or that of you or others.

Mergers and Acquisitions – Circumstances may arise where for business reasons,
we decide to sell, expand, merge, or otherwise reorganize our business in the
United States or another country. A transaction like this may involve the
disclosure of personally identifying information to prospective or actual
purchasers and/or receiving such information from sellers. It is our practice to
seek appropriate protection for your information in these types of transactions,
including notifying you if a different company will receive this information.
Any successor in a merger or acquisition shall be bound by this Privacy Policy.

Third-Party Links – We may provide links to external websites in order to make
certain content and services available to you. These websites are beyond our
control and are not governed by our Privacy Policy. Therefore, we are not
responsible for the privacy practices or the content of third party websites and
cannot be responsible for the protection and privacy of any information you
provide to these sites. When you leave the VoiceVibes website, we encourage you
to read the privacy policy of any other website you visit, particularly websites
that ask for your personal information.

Cookies – A cookie is a small file containing a string of characters that is
stored on a user’s hard drive. VoiceVibes may send one or more cookies to your
computer in order to uniquely identify your browser. In general, cookies help us
determine whether you have previously visited VoiceVibes’ website and allow us
to track the use of our website. Your VoiceVibes cookies will not contain any
personally identifiable information whether you have registered or not.
Purpose – We use cookies to store your account information and the preferences
you have made while using VoiceVibes. We may also use cookies to track the
number of visitors to our website and to help us understand how visitors use the
website.

Third-Party Cookies – Advertising partners may help VoiceVibes deliver
interactive advertising, such as banner ads, and may also use their own cookies
to better understand the types of advertising and promotions that are most
appealing to our customers.

Disabling Cookies – While most web browsers automatically accept cookies by
default, you may choose to disable or decline cookies from a particular website.
Please be aware that if you disable all cookies or even just the cookies
delivered by VoiceVibes, this may impact your ability to use our website as well
as others.

Browser Controls for “Do Not Track” – Some newer browsers have “Do Not Track”
(DNT) features. When engaged, most DNT features send a signal or preference to
websites that you do not want to be tracked. Those websites or their third-party
advertisers or content providers may continue to engage in activity you may view
as tracking, even after you use the DNT, depending on the websites’ privacy
practices. Because there is not yet a common understanding of how to interpret
the DNT signal, VoiceVibes does not currently respond to the browser DNT
signals. We continue to work with the online industry to define a common
understanding of DNT signals and to remain compliant with industry standards.

Data That You Direct Us to Share – You can direct us to share data with other
parties. For example, you may authorize us to send status updates to your
Facebook or Twitter account or direct us to share data with your employer as
part of a corporate training program. Once you direct us to share your data with
a third party, that data is governed by the third-party’s privacy policy.


5. HOW LONG WE SAVE YOUR DATA

Personally Identifiable Information – Your personally identifiable information
shall be retained by the Company unless you request that it be deleted by
contacting privacyofficer@myvoicevibes.com. Your information will only be used
for Company research purposes to develop new and improved services and to better
understand customers’ needs.

Non-Personally Identifiable Information – We may retain and use non-personally
identifiable information such as aggregate data, performance metrics, usage
statistics and other data that has been anonymized.


6. HOW TO EDIT OR MODIFY DATA

Data that you provide to VoiceVibes through the website can be deleted from your
account from the Manage tab. If you remove data from your account, it will no
longer appear to you or others who use the VoiceVibes service. Backups of that
data may remain associated with your VoiceVibes account and in our archive
servers.


7. HOW TO CANCEL YOUR VOICEVIBES ACCOUNT

You can cancel your VoiceVibes account by sending an email titled “Request to
TerminatemyVoiceVibesAccount”toprivacyofficer@myvoicevibes.com. Uponany
cancellation, your personally identifiable information shall be retained by the
Company unless you request that it be deleted by contacting
privacyofficer@myvoicevibes.com.


8. CHILDREN’S PRIVACY

VoiceVibes is not directed at persons under the age of 13. We do not knowingly
collect any personally identifiable information from children under the age of
13. If a parent or guardian becomes aware that their child has provided us with
information without their consent, they should contact the VoiceVibes Privacy
Officer at privacyofficer@myvoicevibes.com, and we will delete such information
as soon as reasonably practicable.


9. INFORMATION SECURITY

Security Practices – We have incorporated security measures like password
hashing and idle session logout to protect against the loss, misuse, and
alteration of the information under our control. Further, only authorized
affiliates, service providers, subsidiaries, and employees, who have agreed to
keep the information on VoiceVibes secure and confidential, will have access to
our information. While we will make every effort to ensure that the information
you provide us will be kept secure, there is no way for us to absolutely
guarantee the security of your personal information.

No Liability for Acts of Third Parties – VoiceVibes uses a combination of
technical and administrative security controls to maintain the security of your
data, exercising all reasonable efforts to safeguard the confidentiality of your
personal information. However, transmissions protected by industry-standard
security technology and implemented by human beings cannot be made entirely
secure. Consequently, VoiceVibes shall not be liable for unauthorized disclosure
of personal information due to no fault of its own, including—but not limited
to—errors in transmission and unauthorized acts of VoiceVibes staff and/or third
parties.


10. ADDITIONAL INFORMATION FOR EU, UK AND SWITZERLAND-BASED USERS

Data protection regulations in Europe require VoiceVibes to disclose additional
information regarding Personal Data collected from European users, and to limit
VoiceVibes’ use of such information in specific ways. This section provides
additional information applicable to European Personal Data, which may not apply
to users in other geographies.

If you are accessing VoiceVibes from the United Kingdom, Switzerland or any
country belonging to the European Union, please be advised that it is our policy
and intent to adhere to the principles of Regulation (EU) 2016/679 of the
European Parliament and of the Council of 27 April 2016, as amended (commonly
known as the General Data Protection Regulations, or “GDPR”) for your personal
data that it receives from the United Kingdom, Switzerland or any country
belonging to the European Union. Therefore, the following provisions shall apply
to your personal information if you are accessing the VoiceVibes services from
the United Kingdom, Switzerland or any country belonging to the European Union
and, although the Privacy Policy, in whole, applies to everyone using VoiceVibes
services, to the extent that the following provisions conflict with the
provisions provided elsewhere in this Privacy Policy, the following provisions
will apply to you.

VoiceVibes is not directed at persons under the age of 16 in the United Kingdom,
Switzerland or any country belonging to the European Union, and we do not
knowingly collect any personally identifiable information from such children
under the age of 16. If you are aware of a user under the age of 16 using any
VoiceVibes product or service, please contact us at
privacyofficer@myvoicevibes.com. If a parent or guardian becomes aware that
their child under the age of 16 has provided us with information without their
consent, they should contact the VoiceVibes Privacy Officer at
privacyofficer@myvoicevibes.com, and we will delete such information as soon as
reasonably practicable.

Information on the collection of personal data

 1. Personal data are all data that make you personally identifiable, e.g. name,
    address, email addresses, user behaviour.
 2. When you contact us by e-mail or via a contact form, the data you provide
    (your email address, if applicable, your name and your telephone number)
    will be saved by us in order to answer your questions. VoiceVibes will
    delete the data collected in this context when its storage is no longer
    necessary or restrict the processing if statutory retention obligations
    exist.
 3. If VoiceVibes makes use of contracted service providers for individual
    functions of our services or would like to use your data for advertising
    purposes, VoiceVibes will inform you in detail about the respective
    processes below. VoiceVibes does not directly collect sensitive personal
    information (e.g. information that reveals race, ethnic origin, political
    affiliations, etc.), but it is possible that you will provide such
    information in the content of your voice recordings.
 4. VoiceVibes will use personal information only in ways that are compatible
    with the purposes for which it was collected or subsequently authorized by
    the individual. VoiceVibes will take reasonable steps to ensure that
    personal information is relevant to its intended use, accurate, complete,
    and current.

Your rights

 1. You have the following rights regarding personal data concerning you:
    * Right of information,
    * Right of correction or deletion,
    * Right of limitation of processing,
    * Right of opposition to the processing,
    * Right of data portability
 2. You also have the right to complain to a data protection supervisory
    authority about our processing of your personal data.

Data Portability
Upon request, VoiceVibe shall provide individuals with their personal data that
has been provided to VoiceVibes in a structured, commonly used and
machine-readable format.

Right to Erasure
Upon request, VoiceVibes shall delete an individual’s personal information
without undue delay; provided, however, VoiceVibes has the right to retain such
personal information as may be necessary for (i) compliance with legal
obligations or for a task carried out in the public interest; (ii) for reasons
of public interest in the area of public health; (iii) for archiving purposes in
the public interest, scientific or historical research purposes or statistical
purposes if VoiceVibes takes appropriate measures for data minimization that no
longer permits the identification of the individual; and (iv) for the
establishment, exercise or defense of legal claims.

Termination/Deactivation

When you terminate or deactivate your VoiceVibes account, data that can identify
you will be removed from the VoiceVibes service, and if you consented during
sign-up, we can retain your data after your account has been closed, but you are
also able to revoke this consent at any time, either before, during or after
account closure.

Access and Correction
Upon request, VoiceVibes will grant individuals reasonable access to personal
information that it holds about them. In addition, VoiceVibes will permit
individuals to correct, amend, supplement or delete information that is
demonstrated to be inaccurate orincomplete.
VoiceVibeswillnotifyanythirdpartyagenttowhomthepersonal information has been
disclosed that such personal information has been corrected, unless doing so
proves to be impossible or involves disproportionate effort.

Use of social media plug-ins

 1. VoiceVibes currently uses the following social media plug-ins: Facebook,
    LinkedIn, Twitter, YouTube. VoiceVibes uses the so-called two-click
    solution. This means that when you visit our Website, no personal data is
    initially passed on to the providers of the plug- ins. You can recognise the
    provider of the plug-in by the marking on the box above its initial letter
    or the logo. VoiceVibes offers you the possibility to communicate directly
    with the provider of the plug-in via the button. Only if you click on the
    marked field and thereby activate it, the plug-in provider receives the
    information that you have accessed the corresponding Website of our online
    offer. In addition, the data mentioned in the section “Collection of
    personal data when you visit our Website” of this Privacy Policy will be
    transmitted. In the case of Facebook, the IP address is anonymised
    immediately after collection, according to the respective provider. By
    activating the plug-in, personal data is transferred from you to the
    respective plug-in provider and stored there. Since the plug-in provider
    collects data mainly via cookies, VoiceVibes recommends that you delete all
    cookies before clicking on the greyed-out box using your browser’s security
    settings.
 2. VoiceVibes has no influence on the data collected and data processing
    processes, nor is VoiceVibes aware of the full extent of data collection,
    the purposes of processing, or the storage periods. VoiceVibes does not have
    information on the deletion of the data collected by the plug-in provider.
 3. The plug-in provider stores the data collected about you as user profiles
    and uses these for the purposes of advertising, market research and/or
    demand-oriented design of its Website. Such an evaluation takes place in
    particular (also for non-logged-in users) for the representation of suitable
    advertisements and in order to inform other users of the social network
    about your activities on our Website. You have a right of objection to the
    creation of these user profiles, whereby you must contact the respective
    plug-in provider to exercise this right. Through the plug-ins, VoiceVibes
    offers you the ability to interact with social networks and other users, so
    that VoiceVibes can improve our service and make it more interesting for you
    as a user. The legal basis for the use of the plug-ins is Art. 6 para. 1
    sentence 1 lit. f GDPR.
 4. The data is passed on regardless of whether you have an account with the
    plug-in provider and are logged in there. If you are logged in with the
    plug-in provider, your data collected with us will be directly assigned to
    your existing account with the plug-in provider. If you click the activated
    button and, for example, link the page, the plug-in provider also stores
    this information in your user account and shares it publicly with your
    contacts. VoiceVibes recommends that you log out regularly after using a
    social network, especially before activating the button, as this way you can
    avoid being assigned to your profile with the plug-in provider.
 5. Further information on the purpose and scope of data collection and its
    processing by the plug-in provider can be found in the privacy policy of
    these providers listed below. They will also provide you with further
    information about your rights in this regard and how to set options to
    protect your privacy.
 6. Addresses of the respective plug-in providers and URLs with their data
    protection information:
    a) LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California
    94043, USA;http://www.linkedin.com/legal/privacy-policy. LinkedIn has
    submitted to the EU- US Privacy Shield,
    https://www.privacyshield.gov/EU-US-Framework.
    b) Facebook Inc, 1601 S California Ave, Palo Alto, California 94304,
    USA; http://www.facebook.com/policy.php; further information on data
    collection: http://www.facebook.com/help/186325668085084,
    http://www.facebook.com/about/privacy/your-info-on-other#applications.
    Facebook has submitted to the EU-US Privacy Shield,
    https://www.privacyshield.gov/EU-US-Framework
    c) Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California
    94103, USA; https://twitter.com/privacy. Twitter has submitted to the EU-US
    Privacy
    Shield, https://www.privacyshield.gov/EU-US-Framework.
    d) YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066,
    USA; https://policies.google.com/privacy?hl=en&gl=en.

Integration of YouTube video

 1. VoiceVibes have integrated YouTube videos into our online website, which are
    stored on http://www.YouTube.com and can be played directly from our
    website. These are all integrated in the “extended data protection mode”,
    i.e. no data about you as a user will be transmitted to YouTube if you do
    not play the videos. Only when you play the videos will the data referred to
    in paragraph 2 be transmitted. VoiceVibes has no influence on this data
    transmission.
 2. By visiting the Website, YouTube receives the information that you have
    accessed the corresponding subpage of our Website. In addition, the data
    mentioned in the section “Collection of personal data when you visit our
    Website” of this Privacy Policy will be transmitted. This does not depend on
    whether YouTube provides a user account through which you are logged in or
    whether no user account exists. If you are logged into Google, your
    information will be directly associated with your account. If you do not
    wish to be associated with your profile on YouTube, you must log out before
    activating the button. YouTube stores your data as user profiles and uses
    them for purposes of advertising, market research and/or demand-oriented
    design of its website. Such evaluation takes place in particular (even for
    non-logged-in users) to provide demand- oriented advertising and to inform
    other users of the social network about your activities on our Website. You
    have the right to object to the creation of these user profiles, but you
    must contact YouTube to exercise this right.
 3. Further information on the purpose and scope of data collection and
    processing by YouTube can be found in YouTube’s privacy policy. There you
    will also find further information about your rights and how to set options
    to protect your privacy. Google also processes your personal data in the USA
    and has submitted to the EU-US Privacy Shield,
    https://www.privacyshield.gov/EU-US-Framework.

Choice.

You can contact us any time to opt-out of (a) promotional communications, or (b)
any new processing of your personal information that we may carry out beyond the
original purpose, or (c) the transfer of your personal information outside the
United Kingdom, Switzerland or any country of the European Union (opting out of
this subsection (c) will cause VoiceVibes’ services to be ineffective upon
opt-out).

Transfers to Agents.

VoiceVibes will obtain assurances from its agents that they will safeguard
personal information consistently with GDPR, including providing the same level
of protection as is required under GDPR. Where VoiceVibes has knowledge that an
agent is using or disclosing personal information in a manner contrary to GDPR,
VoiceVibes will take reasonable steps to prevent or stop the use or disclosure.

Security.

VoiceVibes will take reasonable precautions to protect personal information in
its possession from loss, misuse, and unauthorized access, disclosure,
alteration, and destruction.

Enforcement.

VoiceVibes will conduct compliance audits of its relevant privacy practices to
verify adherence to this Privacy Policy. Any employee that VoiceVibes determines
is in violation of this Privacy Policy will be subject to disciplinary action up
to and including termination of employment.

Retention of Personal Information.

If your VoiceVibes account becomes inactive because it was not timely renewed,
and you have not opted in to permit us to retain your personal information, we
will keep your personal information for a period of three months prior to
beginning the process of deleting it. This will enable us to promptly reactivate
your account in the event you renew during the initial three month period. Once
the process of deleting your personal information has begun, it is possible that
it may take up to an additional three months for all copies of your personal
information to be removed from all of VoiceVibes’ systems, backups, log files,
and archives.

Objection or revocation of the processing of your data

 1. If you have given your consent to the processing of your data, you can
    revoke it at any time. Such revocation affects the lawfulness of processing
    your personal data after you have made it known to us.
 2. If we base the processing of your personal data on the weighing of
    interests, you may object to the processing. This is the case in particular
    if processing is not necessary to fulfil a contract with you, which we
    explain in the following description of the functions. When you do object,
    we would ask you to explain the reasons why we should not process your
    personal data. In the event of a justified objection, we will examine the
    situation and either stop or adjust data processing, or point out to you our
    compelling reasons worthy of protection, on the basis of which we will
    continue processing.
 3. Of course, you can object to the processing of your personal data for the
    purposes of advertising and data analysis at any time. You can inform us
    about your contradiction using the following contact data:

VoiceVibes, Inc.
7224 Shub Farm Rd.
Marriottsville, MD 21104
USA
email: privacyofficer@myvoicevibes.com

Contact/Dispute Resolution

Any questions or concerns regarding the use or disclosure of, or any of your
rights regarding, your personal information should be directed to the VoiceVibes
Privacy Officer at privacyofficer@myvoicevibes.com. VoiceVibes will investigate
and attempt to resolve complaints and disputes regarding use and disclosure of
personal information by reference to the principles contained in this Privacy
Policy.


11. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Effective Date: January 1, 2020
Last Reviewed on: February 22, 2021

This Privacy Notice for California Residents supplements the information
contained in Bigtincan’s Privacy policy and applies solely to all visitors,
users, and others who reside in the State of California (“consumers” or “you”).
We adopt this notice to comply with the California Consumer Privacy Act of 2018
(CCPA) and any terms defined in the CCPA have the same meaning when used in this
notice.

Information We Collect on Our Website collects information that identifies,
relates to, describes, references, is capable of being associated with, or could
reasonably be linked, directly or indirectly, with a particular consumer or
device (“personal information”). In particular, Bigtincan’s website,
https://www.bigtincan.com/ (“Website”), has collected the following categories
of personal information from its consumers in California within the last twelve
(12) months:

A. Identifiers. Examples: Name, email address, telephone number, Internet
Protocol address. Collected: YES

B. Personal information categories listed in the California Customer Records
statute (Cal. Civ. Code § 1798.80(e)). Examples: Name, email address, telephone
number. Some personal information included in this category may overlap with
other categories. Collected: YES

C. Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin,
citizenship, religion or creed, marital status, medical condition, physical or
mental disability, sex (including gender, gender identity, gender expression,
pregnancy or childbirth and related medical conditions), sexual orientation,
veteran or military status, genetic information (including familial genetic
information). Collected: OPTIONAL

D. Commercial information. Examples: Records of Bigtincan products or services
considered on our website. Collected: YES

E. Biometric information. Examples: Genetic, physiological, behavioral, and
biological characteristics, or activity patterns used to extract a template or
other identifier or identifying information, such as, fingerprints, faceprints,
and voiceprints, iris or retina scans, keystroke, gait, or other physical
patterns, and sleep, health, or exercise data. Collected: YES

F. Internet or other similar network activity. Examples: Browsing history,
search history, information on a consumer’s interaction with a website,
application, or advertisement. Collected: YES

G. Geolocation data. Examples: Physical location or movements. Collected: YES

H. Sensory data. Examples: Audio, electronic, visual, thermal, olfactory, or
similar information. Collected: YES

I. Professional or employment-related information. Examples: Current or past job
history or performance evaluations. Collected: NO

J. Non-public education information (per the Family Educational Rights and
Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Examples: Education
records directly related to a student maintained by an educational institution
or party acting on its behalf, such as grades, transcripts, class lists, student
schedules, student identification codes, student financial information, or
student disciplinary records. Collected: YES

K. Inferences drawn from other personal information. Examples: Profile
reflecting a person’s preferences, characteristics, psychological trends,
predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: YES

Personal information does not include:

 * Publicly available information from government records.
 * Deidentified or aggregated consumer information.
 * Information excluded from the CCPA’s scope, like:
 * Health or medical information covered by the Health Insurance Portability and
   Accountability Act of 1996 (HIPAA) and the California Confidentiality of
   Medical
   Information Act (CMIA) or clinical trial data;
 * Personal information covered by certain sector-specific privacy laws,
   including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act
   (GLBA) or California Financial Information Privacy Act (FIPA), and the
   Driver’s Privacy Protection Act of 1994.

Bigtincan obtains the categories of personal information listed above from the
following categories of sources:

 * Indirectly from you. For example, from observing your actions on our Website.
 * Directly from you. For example, from forms you complete.

Use of Personal Information We may use, or disclose the personal information we
collect for one or more of the following business purposes:

 * To fulfill or meet the reason you provided the information. For example, if
   you share your name and contact information or ask a question about our
   products or services, we will use that personal information to respond to
   your inquiry.
 * To provide, support, personalize, and develop our Website, products, and
   services.
 * To process your information requests.
 * To provide you with support and to respond to your inquiries, including to
   investigate and address your concerns and monitor and improve our responses.
 * To personalize your Website experience and to deliver content and product and
   service offerings relevant to your interests, including targeted offers and
   ads through our Website, third-party sites, and via email or text message
   (with your consent, where required by law).
 * To help maintain the safety, security, and integrity of our Website, products
   and services, databases and other technology assets, and business.
 * For testing, research, analysis, and product development, including to
   develop and improve our Website, products, and services.
 * To respond to law enforcement requests and as required by applicable law,
   court order, or governmental regulations.
 * As described to you when collecting your personal information or as otherwise
   set forth in the CCPA.

Bigtincan will not collect additional categories of personal information or use
the personal information we collected for materially different, unrelated, or
incompatible purposes without providing you notice.

Sharing Personal Information Bigtincan may disclose your personal information to
a third party for a business purpose. When we disclose personal information for
a business purpose, we enter a contract that describes the purpose and requires
the recipient to both keep that personal information confidential and not use it
for any purpose except performing the contract.

We share your personal information with the following categories of third
parties:

 * Disclosures of Personal Information for a Business Purpose
 * In the preceding twelve (12) months, Company has disclosed the following
   categories of personal information for a business purpose:
   * [Category A: Identifiers.]
   * [Category B: California Customer Records personal information categories.]
   * [Category D: Commercial information.]
   * [Category F: Internet or other similar network activity.]
   * [Category G: Geolocation data.]

We share your personal information with the following categories of third
parties:

 * Service providers.
 * Data aggregators.
 * Disclosures of Personal Information for a Business Purpose
 * In the preceding twelve (12) months, Company has disclosed the following
   categories of personal information for a business purpose:
   * [Category A: Identifiers.]
   * [Category B: California Customer Records personal information categories.]
   * [Category D: Commercial information.]
   * [Category F: Internet or other similar network activity.]
   * [Category G: Geolocation data.]

We disclose your personal information for a business purpose to the following
categories of third parties:

 * Service providers.
 * Data aggregators

Sales of Personal Information

In the preceding twelve (12) months, Company has not sold personal information
Your Rights and ChoicesThe CCPA provides consumers (California residents) with
specific rights regarding their personal information. This section describes
your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Bigtincan disclose certain information to you
about our collection and use of your personal information over the past 12
months. Once we receive and confirm your verifiable consumer request (see
Exercising Access, Data Portability, and Deletion Rights), we will disclose to
you:

 * The categories of personal information we collected about you.
 * The categories of sources for the personal information we collected about
   you.
 * Our business or commercial purpose for collecting that personal information.
 * The categories of third parties with whom we share that personal information.
 * The specific pieces of personal information we collected about you (also
   called a data portability request).
 * If we disclosed your personal information for a business purpose, providing
   disclosures for a business purpose, identifying the personal information
   categories that each category of recipient obtained.

Deletion Request Rights
You have the right to request that Bigtincan delete any of your personal
information that we collected from you and retained, subject to certain
exceptions. Once we receive and confirm your verifiable consumer request (see
Exercising Access, Data Portability, and Deletion Rights), we will delete (and
direct our service providers to delete) your personal information from our
records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for
us or our service provider(s) to:

 1. Complete the transaction for which we collected the personal information,
    provide a good or service that you requested, take actions reasonably
    anticipated within the context of our ongoing business relationship with
    you, or otherwise perform our contract with you.
 2. Detect security incidents, protect against malicious, deceptive, fraudulent,
    or illegal activity, or prosecute those responsible for such activities.
 3. Debug products to identify and repair errors that impair existing intended
    functionality.
 4. Exercise free speech, ensure the right of another consumer to exercise their
    free speech rights, or exercise another right provided for by law.
 5. Comply with the California Electronic Communications Privacy Act (Cal. Penal
    Code § 1546 et. seq.).
 6. Enable solely internal uses that are reasonably aligned with consumer
    expectations based on your relationship with us.
 7. Comply with a legal, regulatory or other governmental obligation.
 8. Make other internal and lawful uses of that information that are compatible
    with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above,
please submit a verifiable consumer request to us by either:

 * Phone: (617) 981-7557
 * Email: privacy@bigtincan.com
 * Physical Address: Bigtincan Mobile Pty Ltd, Level 6, 338 Pitt Street, Sydney,
   New South Wales, Australia 2000.

Only you, or a person registered with the California Secretary of State that you
authorize to act on your behalf, may make a verifiable consumer request related
to your personal information. You may also make a verifiable consumer request on
behalf of your minor child.

You may only make a verifiable consumer request for access or data portability
twice within a 12-month period. The verifiable consumer request 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 cannot respond to your request or provide you with personal information if we
cannot verify your identity or authority to make the request and confirm the
personal information relates to you.

Making a verifiable consumer request does not require you to create an account
with us. However, we do consider requests made through your password protected
account sufficiently verified when the request relates to personal information
associated with that specific account.

We will only use personal information provided in a verifiable consumer request
to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within thirty (30) days
of its receipt. If we require more time (up to 90 days), we will inform you of
the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that
account. If you do not have an account with us, we will deliver our written
response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the
verifiable consumer request’s receipt. The response we provide will also explain
the reasons we cannot comply with a request, if applicable. For data portability
requests, we will select a format to provide your personal information that is
readily useable and should allow you to transmit the information from one entity
to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request
unless it is excessive, repetitive, or manifestly unfounded. If we determine
that the request warrants a fee, we will tell you why we made that decision and
provide you with a cost estimate before completing your request.
Other California Privacy RightsCalifornia’s “Shine the Light” law (Civil Code
Section § 1798.83) permits users of our Website that are California residents to
request certain information regarding our disclosure of personal information to
third parties for their direct marketing purposes. To make such a request,
please send an email to privacy@bigtincan.com or write us at:

Attn: Bigtincan Privacy officer
Phone: (617) 981-7557
Email: privacy@bigtincan.com
Address: Bigtincan Mobile Pty Ltd, Level 6, 338 Pitt Street, Sydney, New South
Wales, Australia 2000


12. WHEN THE VOICEVIBES PRIVACY POLICY APPLIES/LINKS

The VoiceVibes Privacy Policy applies to all of our services, products, mobile
applications, and our website.

If you use external links that are offered on our website, this Privacy Policy
does not extend to those links. When VoiceVibes provide links, we endeavour to
ensure that they also comply with our Privacy Policy and security standards.
However, we have no influence on compliance with privacy policy and security
regulations by other providers and websites. Therefore, please also inform
yourself about the privacy policies provided on the websites of other providers.


13. CHANGES TO PRIVACY POLICY

The use of the information that we gather is subject to the Privacy Policy in
effect at the time the information is submitted. We reserve the right, however,
to update this Privacy Policy at any time. We will post any Privacy Policy
changes on this page, and if the changes are more significant, we will provide a
more prominent notice (including, for certain services, email notification of
privacy policy changes to registered users and/or display notifications on the
VoiceVibes website). We will not reduce your rights under this Privacy Policy
without your explicit consent. We will also keep prior versions of the Privacy
Policy in an archive for your review.


14. ACCEPTANCE

When a significant change to this Privacy Policy goes into effect, registered
users will be prompted to review the changes and to select whether they accept
or do not accept VoiceVibes’ planned updates.


15. CONTACT US

You can contact us with any questions or comments at:
privacyofficer@myvoicevibes.com.




MODUS WEBSITE PRIVACY POLICY

Modus Data Processing Agreement
Modus Website Terms of Use
Modus Master Terms of Service

Modus Engagement, Inc. (“Modus,” “we,” “our,” or “us”) takes your privacy
seriously, and we want you to know how we collect, use, share, and protect your
information. Some of the information may be “personal information” (also
referred to as “personal data”) which is information that identifies you
personally, alone or in combination with other information available to us.

This Privacy Policy (the “Policy”) applies to information collected by this
website or mobile applications to which this Policy is linked (the “Site”). If
you or your organization have subscribed to the Modus Sales Hub platform, then
privacy issues are governed by the Modus Master Terms of Service and the Modus
Data Processing Addendum. This Policy does not apply to third-party platforms or
websites to which this website may provide a link. There may be additional or
different privacy policies associated with use of our products and services. You
should review those privacy policies prior to your use of our products and
services.

Modus and its licensors own, operate, and maintain the Service. Modus is a
Delaware corporation with its principal place of business in Minneapolis,
Minnesota, U.S.A.

CONSENT

Please read this Policy before using this Site. By using this Site, you are
consenting to the collection, use, and disclosure of your information as set
forth in this Policy. This Policy is part of our Terms of Use that govern your
use of this Site. A link to the Terms of Use is provided [here].

Information you give us. We collect the information you manually provide when
you use this Site. For example, we collect the information you provide when you
contact us through the Site, such as name, email, and phone number and any other
information you provide in the message field. We may collect other information
from you if you fill out an online form or survey or when you conduct an online
transaction with us.

Information we collect automatically. When you interact with our Site, certain
information about your use of our Site is automatically collected. Much of this
information is collected through cookies, web beacons and other tracking
technologies, as well as through your web browser or device (e.g., IP address,
MAC address, browser version, etc.) We may place a text file called a cookie in
the browser files of your computer when you visit. The cookie may be stored on
your computer’s hard drive. The information we collect using cookies allows us
to recognize you as a user when you access the Site, and manage your
subscription if you have one.  If you decline our cookies, you will not be able
to access the Site.  We will not allow third parties other than those companies
that we hire to perform services or functions on our behalf to place their own
cookies on the Site, or use cookies to track your other browser activities.

Information we collect from other sources. We may also collect information about
you from other sources, including third parties from whom we purchase data. We
may combine this data with information provided by you when you use this Site.
This helps us update our records, identify new customers, and tailor our
advertising to provide services that may be of interest to you.

How We Use the Information We Collect

We will not sell or rent the information we collect about you. We may use the
information we collect for things like:

 * Responding to your contact, product demonstration, or other requests
 * Providing you with access to the Site or other products or services
 * Billing you for products or services you purchased
 * Providing ongoing service and customer support
 * Contacting you with information that might be of interest to you, including
   information about products and services or changes to this Policy
 * Asking for your opinion about our services or the products of others
 * Inviting you to participate in surveys
 * Keeping records
 * Analyzing, researching, developing and improving programs, products,
   services, and Site content
 * Operating, evaluating and improving our business
 * Marketing and advertising products and services as well as other marketing
   activities

We may also remove your personal identifiers (your name, e-mail address, etc.)
so that you are no longer identified as a single unique individual. Once we have
de-identified information, it is not personal information and may be treated
like public information.

Finally, we may use your information to protect our rights or property, or to
protect someone’s health, safety or welfare, and to comply with a law or
regulation, court order or other legal process.

DATA RETENTION

 We will retain your personal information for as long as needed to provide you
services, comply with our legal obligations, resolve disputes, and enforce
agreements.

WE MAY SHARE INFORMATION WITH THIRD PARTIES

We will not share your information collected from the Site with an unrelated
third party without your permission, except as otherwise provided in this
Privacy Policy or in an agreement with you. In the ordinary course of business,
we may share your information with companies that we hire to perform services or
functions on our behalf.  In all cases in which we share your information with a
third party for the purpose of providing a service to us, we will prohibit them
from keeping, disclosing or using your information except for the purpose of
providing the services we asked them to provide. We will not sell exchange or
publish your information, except in conjunction with a corporate sale, merger,
dissolution, or acquisition.

We may be legally compelled to release your information in response to a court
order, subpoena, search warrant, law or regulation. We may cooperate with law
enforcement authorities in investigating and prosecuting Site visitors who
violate our rules or engage in behavior which is harmful to other visitors (or
illegal).  We also may disclose your information to third parties if we feel
that the disclosure is necessary to protect our rights or property, protect
someone’s health, safety or welfare, or to comply with a law or regulation,
court order or other legal process.

YOUR CHOICES

You may opt out of any future contacts from us by notifying us
at support@modusengagement.com. Using the same contact email, you may ask that
we update or correct your personal information obtained through the Site, or
request access to or deletion of such information. There may be some limitations
on what we are able to delete or provide, and we may need additional information
to verify your identity before taking action. You will not be discriminated
against for exercising your choices under this section.

Your browser or device may include “Do Not Track” functionality. At this time,
we do not respond to browser “Do Not Track” signals.

SECURITY

We have implemented reasonable, generally accepted standards of technology and
operational security in order to protect your information from loss, misuse,
alteration, or destruction. Only authorized personnel and third-party vendors
have access to your information, and these employees and vendors are required to
use reasonable security precautions and treat the information as confidential.
Despite these precautions, we cannot guarantee that unauthorized persons will
not obtain access to your information. In particular, electronic transmissions
via the internet are not necessarily secure from interception, and we cannot
absolutely guarantee the security or confidentiality of such transmissions.

USERS IN THE EUROPEAN ECONOMIC AREA, SWITZERLAND, AND THE UNITED KINGDOM

 If you are a resident of the European Economic Area (“EEA”), Switzerland, or
the United Kingdom (“UK”), this section applies with respect to personal data
collected through your use of the Site.

Purposes of processing and legal basis for processing. As outlined above, we
process personal data in various ways. Such processing relies on the following
legal bases: (1) with your consent; (2) as necessary to provide services; and
(3) as necessary for our legitimate interests in providing services, including
your use of the Site, where those interests do not override your fundamental
rights and freedom related to data privacy.

Transfers. Modus is located in the United States.  By providing any information
to this Site, all users, including without limitation users in the member states
of the EEA, Switzerland, and the UK, consent to the collection, storage, forward
transfer, and processing of such information in the United States of America.
For our customers who are located in the EEA, Switzerland, or the UK, if you use
our products and, as such, we will process personal data on your behalf, our
services agreement with you will include a Data Processing Addendum that
incorporates the Standard Contractual Clauses adopted by the European Commission
and equivalent safeguards required by the data protection laws of Switzerland
and the UK.

Your rights. With respect to the processing of your personal data, you are
entitled to rights under the data protection laws applicable in Europe,
including (1) the General Data Protection Regulation (“GDPR”), Regulation
2016/679 of the European Parliament and of the Council of 27 April 2016, and (2)
the applicable data protection laws of Switzerland and the UK. If you wish to
exercise any such right, including the right to access, rectify, or request
erasure of personal data, please contact us using the contact information
provided below. In order to verify your identity, we may require you to provide
us with personal information prior to accessing any records containing
information about you.

CHILDREN UNDER THE AGE OF THIRTEEN

This Site is not directed to children under 13. We do not knowingly collect
information from children. If you believe we have collected information from a
child under the age of 13, please contact us.

LINKS TO OTHER WEBSITES

Our Site may link to other websites, which have their own privacy policies. We
are not responsible for the data practices of those websites. Please review the
privacy policy on the website you are visiting.

THIS POLICY MAY CHANGE

This policy was updated on April 27, 2021.  We reserve the right to modify this
Policy at any time. Any changes to this Privacy Policy will be listed in this
section, and if such changes are material, a notice will be included on the log
in page of the Site for a period of time. In addition, if we are changing our
privacy policy in a manner that might cause disclosure of information that you
have previously requested not be disclosed, we will contact you and give you the
ability to opt out of such disclosure.




IMSMART PRIVACY POLICY

imSMART Standard Terms and Conditions

Effective: 5/23/2018
CompareNetworks, Inc. (“CompareNetworks”) is committed to protecting your
privacy. We use the information we collect about you to provide you with
personalized information, services and tools. We will not share, sell or
disclose individually identifiable information to any third party other than as
disclosed within this privacy policy. Please read on for more details about our
privacy policy.


OPTIONAL REGISTRATION

CompareNetworks does not require customers to register. Non-registered users may
access all information presented on CompareNetworks. However, registration does
allow customers to personalize and save information. The personal information
shared with CompareNetworks can be used to help tailor the content we provide on
CompareNetworks. Additionally, CompareNetworks may on occasion notify registered
users regarding promotions, special offers, updated information, and special
features.


REGISTRATION

When you register for the site we request certain personally identifiable
information from you on the registration form. During registration you are
required to give contact information (such as name and e-mail address). We use
this information to contact you about the services on our site in which you have
expressed interest, and by expressing an interest, you are deemed to have
consented to receiving information from CompareNetworks regarding those research
interests or subscription preferences, as applicable.


GET QUOTE

If you are not already registered with the site and wish to obtain a quote for
one of the products we offer, we will ask for your name, e-mail address and
other contact information. We use this information in conjunction with our
trusted partners, who will respond to your inquiry, and not for any other
purpose. By submitting a form to request a quote, you consent for your
information to be transmitted to the selected partner(s) specified in the quote
request, and for those selected partners to contact you about your inquiry.


CONTACT US

If you use our contact us forms we will use your name and e-mail address to
respond to your inquiry.


COMMUNICATIONS FROM THE SITE

We will occasionally send you information on products, services, special offers
or promotions. You may sign up for these e-mails on our home page. Out of
respect for your privacy, we present the option not to receive these types of
communications. Please see the Opt-Out section below.


NEWSLETTERS

If you wish to subscribe to our newsletter, we will use your e-mail address to
send the newsletter to you. Out of respect for your privacy, we provide you a
way to unsubscribe. Please see the Opt-out section below.


OPT-OUT

If you sign up for our newsletters, special promotion e-mails, and/or services
and later change your mind, an unsubscribe option will always be available in
our e-mail communications as well as by e-mailing us
at privacy@comparenetworks.com.


COOKIES

A cookie is a small text file that is stored on a user’s computer for
record-keeping purposes. We use cookies on this site. We do not link the
information we store in cookies to any personally identifiable information you
submit while on our site.

CompareNetworks uses cookies to deliver a better and more personalized service.
The cookie stores an encrypted key that allows the site to access information
such as e-mail address, name, and address. Since it is encrypted the cookie
itself stores no personal information.

The use of cookies by our tracking utility company is not covered by our privacy
policy. We do not have access to or control over these cookies. Our tracking
utility company uses session ID cookies to make it easier for you to navigate
our site.

Our third party tracking utility company employs a software technology called
clear gifs (a.k.a. Web Beacons/Web Bugs), that helps us better manage content on
our site by informing us what content is effective. Clear gifs are tiny graphics
with a unique identifier, similar in function to cookies, and are used to track
the online movements of Web users. In contrast to cookies, which are stored on a
user’s computer hard drive, clear gifs are embedded invisibly on Web pages and
are about the size of the period at the end of this sentence.


IP ADDRESSES

CompareNetworks collects IP addresses for the purposes of system administration,
to report aggregate information to our advertisers and to audit the use of our
site. When guests request pages from CompareNetworks sites, our servers and
third party tracking utilities log guests’ IP addresses.


CO-BRANDED SITES

Some pages may have the look and feel of being on one of the CompareNetworks
sites, however the information collected on these pages may not be covered under
our privacy policy. All information collected on these co-branded pages is owned
and controlled by that company’s privacy policy.

At times we may enter into co-branded relationships. When we enter into these
types of relationships we will share your name and e-mail address in order for
our co-branded partner to fulfill the service you have requested. Our privacy
policy does not apply to the information collected on these co-branded sites.
You should read the privacy policy of our co-branded partner.


E-NEWSLETTERS

CompareNetworks offers free electronic newsletters to users. CompareNetworks
gathers the e-mail addresses of users who voluntarily subscribe. Users may
remove themselves from this mailing list by clicking the unsubscribe link at the
bottom of the email. Users can also subscribe to newsletters at the time of
registration. CompareNetworks delivers newsletters, marketing and product
offerings via e-mail to only registered recipients. The e-mail tracking system
recognizes the URL that was clicked, and records some information about you and
your computer, such as the e-mail address that you provided to us, the browser,
operating system and IP address.


BLOG/FORUMS

If you use a blog or forum on some of our sites, you should be aware that any
personally identifiable information you submit there can be read, collected, or
used by other users of these blogs and forums, and could be used to send you
unsolicited messages. We are not responsible for the personally identifiable
information you choose to submit in these blogs or forums.

To request removal of your personal information from our blog, contact us
at privacy@comparenetworks.com.

In order to leave comments on some of our pages you can log in to our commenting
system by using sign-in services such as Facebook and Twitter Connect. These
services will authenticate your identity and provide you the option to share
certain personal information with us such as your name and e-mail address to
pre-populate our sign up form. Services like Facebook Connect give you the
option to post information about your activities on this Web site to your
profile page to share with others within your network. You also have the option
to share your transactions with your friends. If you wish to stop sharing your
transactions, you may do so by logging into your account center on these sites
and updating your profile. Any information shared on those sites is governed by
the privacy policies of those sites, and not this CompareNetworks Privacy
Policy.


USER REVIEWS/COMMENTS/TESTIMONIALS

We post customer comments or testimonials on our sites that may contain
personally identifiable information. We do obtain the customer’s consent via
e-mail prior to posting the comment or testimonial to post their name along with
their comment or testimonial. If you wish to update or delete your testimonial,
you can contact us at privacy@comparenetworks.com.


TELL-A-FRIEND

If you choose to use our referral service to e-mail a friend an article or blog
post from our sites, we will ask you for your friend’s name and e-mail address.
We will automatically send your friend a one-time e-mail inviting him or her to
visit the page you recommended. CompareNetworks stores this information for the
sole purpose of sending this one-time e-mail and tracking the success of our
referral program.

Your friend may contact us at privacy@comparenetworks.com to request that we
remove this information from our database.


PROTECTING YOUR PERSONAL INFORMATION

Your personal information can be password protected. Users should take
appropriate measures to protect the secrecy of their password. We follow
generally accepted industry standards to protect the personally identifiable
information submitted to us, both during transmission and once we receive it. No
method of transmission over the Internet, or method of electronic storage, is
100% secure, however. Therefore, while we strive to use commercially acceptable
means to protect your personal information, we cannot guarantee its absolute
security.

If you have any questions about security on our Web site, you can e-mail us
at privacy@comparenetworks.com.


SHARING WITH THIRD PARTIES

CompareNetworks may disclose user information as required by law and when we
believe that disclosure is necessary to protect our rights and/or if
CompareNetworks believes that disclosure is necessary to comply with a judicial
proceeding, court order, the law or with legal process served on CompareNetworks
Web site or protect and defend the rights or property of CompareNetworks or to
act in an emergency to protect someone’s safety. We use other third parties such
as a web-hosting platform who hosts the article comment sections of our sites.
When you sign up for our site we will share your name, e-mail address and name
as necessary for the third party to provide that service.

CompareNetworks may share aggregate data about our users with business partners,
advertisers or sponsors. Our motivation in doing so is to deliver better content
and services to our users. CompareNetworks may carefully select third parties to
send users information regarding their products or services unless the user has
opted-out as described above.


CONTESTS AND SWEEPSTAKES

CompareNetworks offers contests and sweepstakes in which we request certain
personal information. At a minimum, the required information includes name and
e-mail address; in some cases, the user must answer mandatory survey questions
about a range of other personal data. The information gathered in this manner is
used to verify the entrant’s identity, to send the entrant an e-mail
notification that their entry has been received, and to contact winners and/or
prize recipients. CompareNetworks may divulge this information to a third party,
provided the user gives express consent. Conditions which CompareNetworks will
disclose this information are when a user may expressly choose to receive
additional information from the contest sponsor, in which case the user’s
personally identifiable information is divulged to the advertiser. All
information about each contest is clearly posted during the event. All contests
and sweepstakes are conducted in full accordance with laws of the United States
of America. Updating your Personal Information

If your personal information changes, or if you no longer desire our service,
you may correct, update, or remove it by making the change within the account
section of the site or by e-mailing us at info@comparenetworks.com.

We will retain your information for as long as your account is active or as
needed to provide you services. If you wish to cancel your account or request
that we no longer use your information to provide you services contact us
at privacy@comparenetworks.com We will retain and use your information as
necessary to comply with our legal obligations, resolve disputes, and enforce
our agreements.


PERSONAL INFORMATION AND THE GDPR

In recognition and compliance with the General Data Protection Regulation,
CompareNetworks offers the following rights to our users:
• To view and update your personal data.
• To have your personal data deleted. You may contact us at
privacy@comparenetworks.com to request that we remove your information from our
database.
• To be notified of a breach of personal data. CompareNetworks will notify users
within 72 hours of our awareness of any data breach affecting users’ personal
data or as otherwise required by law.


PRIVACY POLICY FOR CHILDREN

CompareNetworks is for professionals and usage by children is not intended. The
safety of children is very important to us. Children (under age 16) should
always ask parents for permission before sending personal information to
CompareNetworks, or to anyone online.


LINKS TO OTHER SITES

When you are on a CompareNetworks site you could be directed to other sites that
are beyond our control. There are links to other sites from CompareNetworks
pages that take you outside our service. These other sites may send their own
cookies to users, collect data or solicit personal information. While
CompareNetworks strives to protect its users’ personal information and privacy,
we cannot guarantee the security of any information you disclose online.
CompareNetworks’ policy does not extend to anything that is inherent in the
operation of the Internet, and therefore beyond CompareNetworks control, and is
not to be applied in any manner contrary to applicable law or governmental
regulation.


SOCIAL MEDIA WIDGETS

Our Web site includes social media features, such as the Facebook “Like” button
and widgets, such as the “Share This” button or interactive mini-programs that
run on our site. These features may collect your IP address, which page you are
visiting on our site, and may set a cookie to enable the feature to function
properly. Social media features and widgets are either hosted by a third party
or hosted directly on our site. Your interactions with these features are
governed by the privacy policy of the company providing it.


CHANGES IN THIS PRIVACY STATEMENT

If we decide to change our privacy practices, we will post those changes to this
privacy statement, the home page, and other places we deem appropriate so that
you are aware of what information we collect, how we use it, and under what
circumstances, if any, we disclose it. We reserve the right to modify this
privacy statement at any time, so please review it frequently. If we change how
we use your personally identifiable information, we will notify you here, by
e-mail, or by means of a notice on our home page prior to the change becoming
effective.


OTHER

If you are sharing a computer, others can access your saved information. Another
person sharing a computer can set up their own account by simply going to custom
settings.

If you have questions or concerns regarding this privacy statement or other
CompareNetworks policies, please contact the company
at privacy@comparenetworks.com.

CompareNetworks Inc.
395 Oyster Point Blvd
STE 300
South San Francisco, CA 94080

Please see the disclaimer for additional related information.

If you have questions or concerns regarding this privacy statement or other
Comparenetworks, Inc. policies, please contact the company
at info@comparenetworks.com.


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