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 * Current: Your Data, Privacy and Security is Important to Us


YOUR DATA, PRIVACY AND SECURITY IS IMPORTANT TO US

Our privacy tools are here to help you understand more about online
advertising—from the basics to policies to partner requirements. We hope you
find this information useful. If you have any questions that aren’t answered
here, please reach out to us at privacy@MeritB2B.com, contact us at +1 (800)
368-7602 or complete this form.


PRIVACY & ACCESSIBILITY

Overview

June 2021 – MERITB2B LLC

This Privacy Policy describes how MeritB2B gathers and uses data to market its
products and services and to fulfil our customer’s business needs, when it
provides data and services through its “OmniChannelBASE US & International, “and
“Meritbase” Databases and other related products. It is applicable for postal,
email, telephone and online channels including visitors to the MeritB2B website.
The Policy does not cover or apply to the practices of any third parties, nor
does it cover our use of Human Resource, (HR) Data.

MeritB2B provides marketing services and products to our customers to enable
them to engage with their chosen audience of individuals and/or businesses. We
receive third party information from other, vetted, reputable and compliant
companies which may include your name, your postal address, email address and or
telephone number or supplemental information obtained including demographic and
Personally Identifiable Information (“PII”.)

MeritB2B does not collect, hold or use sensitive information such as Social
Security numbers, credit card numbers, banking information, biometric or health
data.

We work with carefully vetted only third-party companies that have demonstrably
high standards, been approved by MeritB2B and have a high regard for, and
processes to respect and comply with applicable privacy law, consistent with
MeritB2B’s own standards. We are committed to protecting your privacy rights and
take this issue seriously. We have internal policies to uphold the security of
the data in our possession whilst meeting the legitimate needs of our customers.

MeritB2B is the one of world’s leading source of business information and
insight. Since 2000, MeritB2B has collected information about businesses to
deliver products and services that assist our customers in making critical
commercial decisions. Our global business database contains more than 50 million
business records. Some of the information in the business records may be
classified as personal information under various laws such as information
relating to an individual (e.g. a sole trader, a partnership, a company
director, a beneficial owner, a trustee, a professional contact.)

This privacy notice explains how we collect, share and protect business
information. MeritB2B are Pro Privacy and always respect your choices and rights
as an individual. We will always work to comply with any applicable privacy
legislation and share with you any information we hold about you as an
individual. This policy also covers the MeritB2B website: www.MeritB2B.com

MeritB2B values your privacy

This Privacy Policy of MeritB2B outlines how your personally identifiable
information and other information about you will be collected, used, and shared
in connection with your access to and/or use of MeritB2B.com and any content,
features, services, or other offerings that MeritB2B may provide in connection
therewith, including in relation to any communication that MeritB2B may send.
This Privacy Policy also describes your choices and rights regarding the use,
access to and correction or deletion of your user information. By using the
Site, you acknowledge that you understand that we will use your user information
in accordance with this Privacy Policy.

Notice to EU/UK individuals: this Privacy Statement is intended to comply with
Regulation (EU) 2016/679 of the European Parliament and of the Council of the
European Union 27 April 2016 (the “General Data Protection Regulation” or
“GDPR”), and the UK equivalent (the “UK GDPR”), and provide appropriate
protection and care with respect to the treatment of information in accordance
with the GDPR.

Notice to California residents: this Privacy Statement is intended to comply
with the California Consumer Privacy Act (“CCPA”) and other applicable
California law.

Notice to Nevada consumers: this Privacy Statement is intended to comply with
Nevada Senate Bill 220.

Notice to Vermont: this Privacy Statement is intended to comply with Vermont’s
Protection of Personal Information: Data Brokers Statute.

Notice to Virginia consumers: this Privacy Statement is intended to comply with
Virginia’s Consumer Data Protection Act.

If you have any comments or queries about this Privacy Statement, or how we use
your user information, please contact us on privacy@meritb2b.com.

Accessibility Statement



MeritB2B is committed to making our website accessible for all customers,
including those with disabilities. Consistent with this goal, we have taken a
number of steps to enhance our site and increase its usability by those who
access the web using assistive technology. We will continue to enhance our
digital properties to deliver accessible experiences.

If you are having trouble accessing www.MeritB2B.com, or if you feel that we are
not abiding by this privacy policy please contact us at privacy@MeritB2B.com

 * 
   OVERVIEW OF SERVICES WE PROVIDE TO MARKETERS AND ADVERTISERS
   
   MeritB2B LLC 
   
   provide a range of data driven marketing products and services including
   offering insight and analytical services as well as marketing customized
   databases that may contain PII. These services often involve a combination of
   data that we have licensed or obtained from public sources, or carefully
   screened data partners and may contain various analytics and algorithms that
   we have applied to the data, in order to help our customers understand their
   customers and (in some cases) to analyze or enhance the data files that they
   hold. The data that we license can be provided by our customers and partners
   in the form of name, address, job title, telephone, email and information
   about what individuals may have purchased or be responsible for purchasing.
   Transactional data with credit card or banking information is not sold,
   processed or collected by MeritB2B.
   
   MeritB2B may engage in digital advertising programs, by utilizing our
   marketing databases to deliver online targeted advertising for marketers
   using third party online networks. We work hard to ensure that we deliver the
   appropriate audience for our clients whilst upholding and respecting the
   right to privacy and the right not to participate in these programs. Our
   advertising partners may deploy cookies, web beacons or similar technologies
   through websites or email messages sent by MeritB2B or their own online
   channels and partners. The technology facilitates relevant advertisements to
   appear as you browse the web, based on your actual, recent website browsing
   and email activity or known interests derived from your browsing history.
   
   Our Purpose for Collecting Information
   
   MeritB2B collects personal information so that we can supply commercial data
   about organizations to other organizations.
   
   We collect personal information so that we can license and sell professional
   business contact information for marketing and data management purposes.
   
   How Do We Use and Share Information?
   
   MeritB2B uses the information that we collect to operate our websites, offer
   customers a variety of business information products and services for use in
   making marketing decisions. MeritB2B also licenses professional business
   contact information to authorized resellers and third-party businesses for
   marketing and data management purposes.
   
   We may use your professional business contact information to match it with
   other public and private sources in order to create anonymous segments of
   information (this is non-personally identifying information, such as
   demographic, behavioral and technical information, extracted from the
   underlying Data) for use by MeritB2B and/or third parties to target
   advertising messages to you on third party sites and services. Such segments
   do not reveal or contain your personal information. You may opt-out from
   certain targeting advertising by following the instructions in the section
   below entitled “What are your choices regarding Cookies”.
   
   Aggregated website visitor data may be used to determine usage patterns or
   interests of visitors to the website and users of our products, or for
   purposes related to technical support or security of the website, products
   and computer systems. Usage information, such as functions accessed by a
   UserID, may be tracked within the products. We do this to respond to
   questions from the user, for market research, and to improve the design and
   functionality of the products. We may also aggregate corporate or industry
   information accessed by all of our customers. We do this in order to
   appreciate the types of companies and industries for which our customers
   require information, which in turn improves the quality of the products.

 * 
   DATA COLLECTED WHEN YOU VISIT OUR WEBSITE
   
   MeritB2B may collect and store the information you voluntarily provide to us
   by visiting our website – meritb2b.com. For instance, you may provide
   information to us through registration to events or by completing a form to
   request information, which may ask for personal information, such as your
   name, the company you work for, business title, postal address, email
   address, telephone number, and other information. Also, please note that if
   we obtain personally identifiable information about you, we may contact you,
   unless you have requested that we add your details to our “do-not-contact”
   database. You can also opt out of receiving any further information by
   notifying us at the address below or writing to privacy@meritb2b.com.
   
   MeritB2B may also automatically collect and aggregate other non-personal
   information from your visit to meritb2b.com by the use of cookies. “Cookies”
   are text files a web site uses to track visitor activity, repeat visits,
   pages viewed, to the end of improving our visitors’ online experience and
   modifying content and targeting advertising based on online behavior. You can
   disable or deny the use of cookies and the subsequent gathering of
   information by adjusting your browser settings. The information collected by
   our technology platforms may include the type of web browser or operating
   system used, the IP address and we may also retain information about the
   pages or content viewed on our website. Any information gathered when
   visiting our website could be used by us to process inquiries that you
   initiated, to promote our own products and services to you, to notify you of
   events and or new product information and may also be disclosed to our
   clients for their business purposes.
   
   What Information We Collect
   
   Products and Services
   
   MeritB2B collects information on businesses and business professionals. The
   business information that we collect includes the following:
   
   Company and business professional information, including business contact
   information such as name, title, address, phone number, fax number, and
   e-mail address, domain names, we collect a limited amount of non-business
   personal information on business individuals (such as a personal,
   non-business email address) to increase the accuracy of our business contact
   information, but we never publish such information in any of our business
   products or solutions. In addition, we corroborate and build business contact
   emails by way of various verification methods and data points;
   
   Detailed company profiles and statistics, including number of employees;
   
   Company operational histories, including territories, subsidiaries,
   affiliates, and lines of business;
   
   Summary business information regarding net worth;
   
   IP addresses are used to analyze trends regarding MeritB2B products and
   services and to increase accuracy of our business data sets, as well as to
   assist us in matching IP addresses to business contact information.
   
   Website visitors and Customers
   
   Personal Information You Provide Through Websites:
   
   Includes name, address, telephone number, email address, employer, job title.
   We collect personal information from website visitors when subscribe to email
   newsletters and alerts, fill out a form to request additional information;
   access whitepapers and webinars.
   
   Personal Information Collected In The Scope Of Marketing Activities:
   
   Your personal information may be collected when we conduct webinars, demand
   generation campaigns, when we disseminate white papers, e-books or similar
   content, when you click on landing pages, in the course of Pay-Per-Click
   campaigns, and similar events and methods.
   
   When you sign up to participate in MERITB2B hosted tutorials/webinars, and
   social media, we will collect personally identifiable information in order to
   establish your profile.
   
   Information Collected Automatically Through Computer Tracking:
   
   We also collect information about website visitors such as IP address,
   browser type, or operating system, areas of the website visited and the
   website from which a visitor came. We collect and analyze this information
   for the continued improvement of the Products, Websites, and our business. We
   routinely use this web log information to administer and improve our website.
   While some of this information may be traceable to an individual, we only
   seek to identify individuals (i) whom we believe are using our website for
   improper purposes, (ii) when necessary to assist them with their user
   experience, (iii) for marketing purposes, including third party marketing ,
   (iv) or to otherwise use the information as described in this policy.
   
   MeritB2B analyzes IP addresses of visitors to our websites and match business
   information from our various databases and received from third parties
   against the IP addresses to learn more about what types of businesses are
   visiting our websites and the browsing preferences of such businesses on our
   websites. We use the information derived from these analytical activities,
   which may be combined with non-personally identifiable behavioral information
   received from third parties, to better model and refine our general marketing
   activities and may, from time to time and to the extent permitted by law,
   directly market our products and services to these businesses based on the
   information we have learned about their browsing activities while on our
   websites.
   
   MeritB2B does not respond to Do Not Track Signals.

 * 
   DATA SECURITY
   
   MeritB2B has procedures and technologies in place to safeguard our data
   assets which may contain your personal information. Access to data is only by
   authorized employees for legitimate business purposes. We use reasonable
   measures to ensure that partners with whom we work also have sufficient
   security processes are in place to ensure secure transfer.
   
   MeritB2B maintains commercially reasonable security measures to protect
   personal information against unauthorized access and disclosure and that are
   consistent with our business operations and generally accepted industry
   standards. These measures include the implementation of technical, physical
   and administrative security safeguards. MeritB2B requires employees to
   complete privacy and security training. MeritB2B also implements a
   third-party service provider due diligence program to ensure that our vendors
   likewise employ adequate data collection, processing, transfer, management
   and security measures in carrying out their services on our behalf.
   
   We cannot ensure or warrant the security of any information that you transmit
   to us and you agree that you provide this information and engage in such
   transmissions at your own risk. Once we receive information from you, we will
   endeavor to maintain its security on our systems. MeritB2B has established
   policies and procedures for securely managing information and protecting Data
   against unauthorized access and we continually assess our data privacy,
   information management and data security practices. We do this in the
   following ways:
   
   Establishing policies and procedures for securely managing information;
   
   Limiting employee access to information;
   
   Protecting against unauthorized access to customer data by using data
   encryption, authentication and virus detection technology, as required;
   
   Requiring service providers with whom we do business to comply with relevant
   data privacy legal and regulatory requirements;
   
   Monitoring our websites through recognized online privacy and security
   organizations;
   
   Conducting background checks on employees and providing Data Privacy training
   to our team members;
   
   Continually assessing our data privacy, information management and data
   security practices.

 * 
   COOKIES, WEB BEACONS, PIXEL TAGS, AND GIFS
   
   What are Cookies, Flash Cookies, Web Beacons, Pixel Tags and GIFs and how are
   they used?
   
   A cookie is a small text file that is stored on your computer’s hard drive
   and that often includes an anonymous unique identifier. When you visit a
   website, that website’s computer asks your computer for permission to store
   this text file in a section of your hard drive that is specifically
   designated for cookies. Each website can send its own cookie to your browser
   if your browser’s preferences allow it. Your browser will only permit a
   website to access the cookies that it has previously sent to you and not the
   cookies sent to you by other websites
   
   We use cookies to store login or other information on your computer, which
   serves to improve our website functionality and tailor our services to your
   preferences and interests. Other uses include preventing, detecting and
   investigating potentially prohibited or illegal activities, including
   enforcing our Terms of Use agreement. Cookies allow us to calculate the
   aggregate number of people visiting our website and to assess which parts of
   the site are most popular. This information helps us to constantly improve
   our website and better serve our customers and some of our cookies may be
   tied to personally identifiable information. We do not store credit/debit
   card numbers in cookies.
   
   For new visitors, we use first party cookies or Web beacons (placed on your
   browser by MeritB2B) to collect limited data, such as the date, time, and
   areas of our website that are visited, as well as the website from which the
   new visitor came. We may use IP addresses to derive certain other information
   concerning businesses visiting our websites as described in this policy, but
   we do not analyze this information in a way which would reveal the identity
   of the individual browsing our websites. When you select one of our products
   or services, register for a newsletter or e-mail alert, fill out an online
   form, we may try to identify your browser and we may combine information from
   cookies, Web beacons, code and other information collected online with other
   data that we maintain about you. By improving the features, marketing, and
   content of our website and by making your online experience more convenient
   and meaningful, we are able to better serve our customers’ needs.
   
   We may use local shared objects, also known as Flash cookies, to display
   content based upon what you view on our site to personalize your visit. Flash
   cookies are different from browser cookies because of the amount of, type of,
   and how Data is stored. Cookie management tools provided by your browser will
   not remove Flash cookies.
   
   A Web beacon is a graphic image, such as a pixel tag or clear GIF, which is
   placed on a Web page or in an e-mail message to monitor user activity, such
   as whether the Web page or e-mail message is accessed or clicked. They are
   often invisible because they are very small in size. They are also used on
   many Web pages for alignment purposes.
   
   We sometimes use Web beacons to provide an independent accounting of how many
   people visit our website or to gather statistics about browser usage on our
   website. Some of our Web pages and HTML-formatted e-mail newsletters use Web
   beacons in conjunction with cookies. It is difficult for you to limit the use
   of Web beacons because there is no easy way to distinguish their use from
   alignment and other purposes. Web beacons may also be loaded from a different
   Web server than the rest of the page.
   
   Some of our e-mails may also contain pixels or code to gather information
   regarding e-mail behavior and analytics. We may share this encrypted
   information with third parties for e-mail analytics purposes.
   
   Third Party Cookies
   
   Some of our business partners, such as third-party advertisers, use cookies
   that originate from their websites. We have no access to, or control over,
   these cookies. For more information, please see the “Third Party Advertisers”
   section below.
   
   We use third party advertising companies to serve ads when you visit our
   website. In the course of serving advertisements, our third-party advertisers
   and partners may place or recognize a unique third-party cookie on your
   browser. These companies may use information about your visits to MeritB2B’s
   and other websites in order to provide advertisements on this site and other
   sites about goods and services that may be of interest to you. These
   third-party partners monitor how guests use websites and determine which
   online features they prefer. We may report information to our partners about
   our customers and the products and services they order, as well as
   aggregated, non-identifiable information about our guests’ use of our
   website. For more information, please see the “Third Party Advertisers”
   section below.
   
   Third Party Advertisers
   
   We use third party advertising companies to serve our Internet ad banners on
   our website and other websites on which we advertise. The use of third-party
   cookies and other tracking technologies is not covered by our privacy policy.
   We do not have access to or control over any third-party tracking
   technologies. Third party advertisers may also use a third-party analytics
   provider to place third party cookies on your browser in order to collect
   anonymous and aggregated session Data, such as the ads that are viewed. If
   you view a Web page where our ads appear, the advertising company may place a
   cookie on your computer or use a Web beacon to access a cookie that they
   previously placed on your computer. These companies do not collect
   information that can personally identify you, but they may use information
   about your visits to our website and other websites to measure the
   effectiveness of ads. We do not disclose any personally identifiable
   information to these companies. We share aggregate website usage information
   with third party advertisers and partners for the purpose of effectively
   targeting our online advertisements. Unless you are previously notified,
   these advertising companies do not link any online behavior or cookies with
   other information that can be used to personally identify you, such as your
   name, address, telephone number or e-mail address, when working with
   MeritB2B.
   
   These third-party advertising networks also track visitors’ online usage and
   behavior patterns. These companies may use information about your visits to
   MeritB2B and other websites in order to provide advertisements on this site
   and other sites about goods and services that may be of interest to you. The
   result of these efforts is the creation of an online profile that attempts to
   predict individual user interests, preferences and purchasing habits. The
   third-party advertising networks then accordingly customize the advertising
   content served to users when visiting other websites.
   
   What are your choices regarding Cookies
   
   Most Internet browsers allow users to decide whether to accept cookies and
   how long to keep them on their hard drive. You may reset your browser to
   refuse cookies and still use our website, although website access and
   functionality may be slower and less convenient.
   
   The website https://www.allaboutcookies.org/ offers some helpful information
   as does the US FTC https://www.consumer.ftc.gov/articles/0042-online-tracking

 * 
   COLLECTION OF SENSITIVE PERSONALLY IDENTIFIABLE INFORMATION
   
   MeritB2B does not collect or hold sensitive personally identifiable
   information (“SPI”) associated with certain customers or customers’ clients.
   To confirm, we do not collect, process or ‘sell’ Financial, Banking, Credit
   Card, Health, Medical, Insurance, Social Security or Passport information.
   Likewise, we do not process, collect or ‘sell’ information relating to
   religion, creed, country of origin, race, religion, ethnicity, education,
   sexuality, disability, educational history, professional history, job
   performance, age, marital or relationship history.

 * 
   PRIVACY SHIELD
   
   On July 16, 2020, the European Court of Justice invalidated Privacy Shield as
   a Transfer Mechanism for data between EU and US companies.  MeritB2B intends
   to utilize alternative transfer mechanisms going forward for EU data
   transfers. Even though Privacy Shield was invalidated, MeritDirect will
   continue to honor its commitments with respect to EU personal data
   transferred in accordance with Privacy Shield.
   
   “EUROPEAN USERS – EU-US Privacy Shield & Swiss-US Privacy Shield
   
   MeritB2B and its subsidiaries have elected to participate in and have
   committed to comply with the EU-US & Swiss-US Privacy Shield, collectively
   known as the ‘Privacy Shield Frameworks.’
   
   MeritB2B has self-certified via the US Dept. of Commerce that it will comply
   with all principles and requirements of the Privacy Shield Framework, with
   regards to our handling and storage of EU and Swiss Subject’s personal data
   described below.
   
   (Our Privacy Shield Certification applies only to services we provide as a
   data processor and does not apply to our “OmniChannelBASE International”
   Database.
   
   The US Dept. Of Commerce Privacy Shield Members list can be found
   here https://www.privacyshield.gov
   
   PRIVACY SHIELD
   MeritB2B LLC and it’s division of Dovetail Database – a MeritB2B company,
   complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy
   Shield Framework as set forth by the U.S. Department of Commerce regarding
   the collection, use, and retention of Personal Data (as defined below) from
   European Union member countries (including Iceland, Norway and Lichtenstein,
   aka the European Economic Area or EEA) and Switzerland into the United States
   under the Privacy Shield. MeritDirect has certified that it adheres to the
   Privacy Shield Principles of Notice; Choice; Accountability for Onward
   Transfer; Security; Data Integrity and Purpose Limitation; Access; and
   Recourse, Enforcement, and Liability. If there is any conflict between the
   policies in this MeritB2B LLC (U.S.) Privacy Shield Policy (“Privacy Shield
   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 page, please visit https://www.privacyshield.gov. This
   certification specifically excludes the MeritB2B product OmniChannelBASE
   International.
   
   Definitions
   “Data Subject” means the individual to whom any given Personal Data covered
   by this Privacy Shield Policy refers.
   
   “Personal Data” means any information relating to an individual residing in
   the European Union and Switzerland that can be used to identify that
   individual either on its own or in combination with other readily available
   data.
   
   “Sensitive Personal Data” means Personal Data regarding an individual’s
   racial or ethnic origin, political opinions, religious or philosophical
   beliefs, trade-union membership, physical or mental health, or sexual life.
   
   Scope and Responsibility
   This Privacy Shield Privacy Policy (the “Policy”) applies to all personal
   information received by MeritB2B from applicable MeritB2B clients in the
   United States from the European Economic Area and from Switzerland under the
   Privacy Shield Frameworks.
   MeritB2B receives marketing data from each MeritB2B client and manages this
   data in a marketing database system that is used only by that specific
   MeritB2B client. The data that MeritB2B receives is from each MeritB2B
   client, not the data subjects and MeritB2B acts in its capacity as a data
   processor. The data subject provides their data to each respective MeritB2B
   client. Data subjects do not provide information directly to MeritB2B,
   therefore the MeritB2B client with whom the data was placed retains control
   of that data. Each MeritB2B client uses their respective marketing database,
   which MeritB2B hosts and maintains for the MeritB2B client, for the MeritB2B
   client’s marketing purposes to the MeritB2B client’s data subjects Some types
   of Personal Data may be subject to other privacy-related requirements and
   policies. For example:
   
    * Personal Data regarding and/or received from a client is also subject to
      any specific agreement with, or notice to, the client, as well as
      additional applicable laws and professional standards.
    * All employees of MeritB2B that have access in the U.S. to Personal Data
      covered by this Privacy Shield Policy are responsible for conducting
      themselves in accordance with this Privacy Shield Policy. Adherence by
      MeritB2B to this Privacy Shield Policy may be limited to the extent
      required to meet legal or regulatory obligations. Note that we may be
      required to release the personal data of EEAC or Swiss individuals in
      response to lawful requests from public authorities including to meet
      national security and law enforcement requirements. We will provide notice
      if our Privacy Policy changes.
   
   MeritB2B employees responsible for engaging third parties, to which Personal
   Data covered by this Privacy Shield Policy will be transferred, are
   responsible for obtaining appropriate assurances that such third parties have
   an obligation to conduct themselves in accordance with the applicable
   provisions of this Privacy Shield Principles, including any applicable
   contractual assurances required by Privacy Shield.
   
   Privacy Shield Principles
   MeritB2B commits to subject to the Privacy Shields’ Principles all Personal
   Data received by MeritB2B in the U.S. from European Union member countries
   and Switzerland in reliance on the respective Privacy Shield framework.
   
    1. Notice
       MeritB2B’s Clients notify Data Subjects covered by this Privacy Shield
       Policy about its data practices regarding Personal Data received by
       MeritB2B’s clients in the U.S. from European Union member countries and
       Switzerland in reliance on the respective Privacy Shield framework,
       including the types of Personal Data it collects about them, the purposes
       for which it collects and uses such Personal Data, the types of third
       parties to which it discloses such Personal Data and the purposes for
       which it does so, the rights of Data Subjects to access their Personal
       Data, the choices and means that MeritB2B offers for limiting its use and
       disclosure of such Personal Data, how MeritB2B’s obligations under the
       Privacy Shield are enforced, and how Data Subjects can contact MeritB2B
       with any inquiries or complaints.
    2. Choice
       For personal information, MeritB2B’s client will offer individuals the
       opportunity to choose (opt-in) whether their personal information is (a)
       to be disclosed to a non-agent third party, or (b) to be used for a
       purpose other than the purpose for which it was originally collected or
       subsequently authorized by the individual. (Opt-in may be provided to
       data subjects by the MeritB2B client with whom the data subject placed
       their personal information.)If Personal Data covered by this Privacy
       Shield Policy is to be used for a new purpose that is different from that
       for which the Personal Data was originally collected or subsequently
       authorized, or is to be disclosed to a third party, MeritB2B will notify
       their client who is the data controller, and update this policy
       accordingly.
    3. Accountability for Onward Transfer
       In the event we transfer Personal Data covered by this Privacy Shield
       Policy to a third party agent, we will do so consistent with any notice
       provided to Data Subjects and any consent they have given, and only if
       the third party has given us contractual assurances that it will (i)
       process the Personal Data for limited and specified purposes consistent
       with any consent provided by the Data Subjects, (ii) provide at least the
       same level of protection as is required by the Privacy Shield Principles
       and notify us if it makes a determination that it cannot do so; and (iii)
       cease processing of the Personal Data or take other reasonable and
       appropriate steps to remediate if it makes such a determination. If
       MeritB2B has knowledge that a third party acting as a controller is
       processing Personal Data covered by this Privacy Shield Policy in a way
       that is contrary to the Privacy Shield Principles, MeritB2B will take
       reasonable steps to prevent or stop such processing.With respect to our
       agents, we will transfer only the Personal Data covered by this Privacy
       Shield Policy needed for an agent to deliver to MeritB2B the requested
       product or service. Our current business model does not transfer data to
       third parties. In the course of providing contractual services, however,
       we may have to transfer data to a third party who provides address
       hygiene services. Furthermore, we will (i) permit the agent to process
       such Personal Data only for limited and specified purposes; (ii) require
       the agent to provide at least the same level of privacy protection as is
       required by the Privacy Shield Principles; (iii) take reasonable and
       appropriate steps to ensure that the agent effectively processes the
       Personal Data transferred in a manner consistent with MeritB2B’s
       obligations under the Privacy Shield Principles; and (iv) require the
       agent to notify MeritB2B if it makes a determination that it can no
       longer meet its obligation to provide the same level of protection as is
       required by the Privacy Shield Principles. Upon receiving notice from an
       agent that it can no longer meet its obligation to provide the same level
       of protection as is required by the Privacy Shield Principles, we will
       take reasonable and appropriate steps to stop and remediate unauthorized
       processing.  MeritB2B remains liable under the Privacy Shield Principles
       if an agent processes Personal Data covered by this Privacy Shield Policy
       in a manner inconsistent with the Principles, except where MeritB2B can
       prove it is not responsible for the event giving rise to the damage.
    4. Security
       MeritB2B takes reasonable and appropriate measures to protect Personal
       Data covered by this Privacy Shield Policy from loss, misuse, and
       unauthorized access, disclosure, alteration, and destruction, taking into
       due account the risks involved in the processing and the nature of the
       Personal Data.
    5. Data Integrity and Purpose Limitation
       MeritB2B limits the collection of Personal Data covered by this Privacy
       Shield Policy to information that is relevant for the purposes of
       processing. MeritB2B does not process such Personal Data in a way that is
       incompatible with the purposes for which it has been collected or
       subsequently authorized by the Data Subject. MeritB2B takes reasonable
       steps to ensure that such Personal Data is reliable for its intended use,
       accurate, complete, and current. MeritB2B takes reasonable and
       appropriate measures to comply with the requirement under the Privacy
       Shield to retain Personal Data in identifiable form only for as long as
       it serves a purpose of processing, which includes MeritB2B’s obligations
       to comply with professional standards, MeritB2B’s business purposes and
       unless a longer retention period is permitted by law, and it adheres to
       the Privacy Shield Principles for as long as it retains such Personal
       Data.
    6. Access
       Data Subjects whose Personal Data is covered by this Privacy Shield
       Policy have the right to access such Personal Data and to correct, amend,
       or delete such Personal Data if it is inaccurate or has been processed in
       violation of the Privacy Shield Principles (except when the burden or
       expense of providing access, correction, amendment, or deletion would be
       disproportionate to the risks to the Data Subject’s privacy, or where the
       rights of persons other than the Data Subject would be violated). These
       requests can be made directly to the applicable MeritB2B client. As a
       data processor MeritB2B is contractually bound to forward requests
       received directly from an individual covered by the Privacy Shield
       Frameworks to the appropriate MeritB2B client, who remains the data
       controller. MeritB2B will update the MeritB2B client marketing database
       with correct data and will make any changes MeritB2B receives from that
       MeritB2B client
    7. Recourse, Enforcement, and Liability
       MeritB2B’s participation in the EU-U.S. Privacy Shield Framework and the
       Swiss-U.S. Privacy Shield Framework is subject to investigation and
       enforcement by the Federal Trade Commission.In compliance with the
       Privacy Shield Principles, MeritB2B commits to resolve complaints about
       your privacy and our collection or use of your Personal Data. Data
       Subjects with inquiries or complaints regarding this Privacy Shield
       Policy should first contact MeritB2B at: privacy@meritb2b.com.  MeritB2B
       has further committed to refer unresolved privacy complaints under the
       EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent
       dispute resolution mechanism, the BBB EU Privacy Shield. If you do not
       receive timely acknowledgment of your complaint, or if your complaint is
       not satisfactorily addressed, please visit
       https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more
       information and to file a complaint.Under certain conditions detailed in
       the Privacy Shield, individuals with residual complaints may be able to
       invoke binding arbitration before the Privacy Shield Panel to be created
       by the U.S. Department of Commerce and the European Commission.  MeritB2B
       agrees to periodically review and verify its compliance with the Privacy
       Shield Principles, and to remedy any issues arising out of failure to
       comply with the Privacy Shield Principles. MeritB2B acknowledges that its
       failure to provide an annual self-certification to the U.S. Department of
       Commerce will remove it from the Department’s list of Privacy Shield
       participants.
   
   Changes to this Privacy Shield Policy
   This Privacy Shield Policy may be amended from time to time consistent with
   the requirements of the Privacy Shield. Appropriate notice regarding such
   amendments will be given.

 * 
   OMNICHANNELBASE INTERNATIONAL – A MERITB2B LLC PRODUCT
   
   Privacy & Fair Processing Notice
   MeritB2B’s global business database contains records from individuals and
   countries residing in the EU as well as other regions. Some of the
   information we collect may be classified as “personal data” under European
   Union (EU) law as it is information relating to an individual (e.g. a sole
   trader, a partnership, a company director, a beneficial owner, a trustee, a
   professional contact etc.). This privacy notice provides the information we
   are required to give in relation to the processing of personal data under EU
   law.
   
   The purpose of this section of our Privacy Policy is help you understand the
   data we may collect and hold about you and how we use it, relating
   specifically to our OmniChannelBASE International Database which contains
   personal data of EU and Swiss Citizens.
   
   MeritB2B LLC is the data controller of your personal data for the purposes of
   creating the OmniChannelBASE International Database. Our group companies are
   as follows: MeritB2B LLC and Dovetail, A Division of MeritB2B – “MeritB2B
   LLC”
   
   MeritB2B is committed to protecting and respecting your privacy and will
   comply with the applicable EU data protection laws in all our dealings with
   your personal data.
   
   MeritB2B provides marketing services and products to our customers to enable
   them to engage with their chosen audience of individuals and/or businesses.
   We enter into commercial agreements with our customers to help them market
   and grow their business and to further our company.
   
   In order to create OmniChannelBASE International Database, we work with
   carefully screened, third party data partners who may have collected and
   processed data about you as an individual.
   
    * This information which may include your name, your postal address, email
      address and or telephone number or supplemental information obtained
      including demographic and Personally Identifiable Information (“PII”.)
    * Information you provided when you registered or subscribed to business
      publications, online and offline, business events and newsletters
    * Information about you at your place of work, such as your name, your
      business telephone number and email address, that is available in the
      public domain, for example on a website or public register;
    * Information that is provided by telephone interviews. This includes
      information provided about your place of work and could include
      information about technology use, number of employees at your place of
      work and type and size of business etc.
    * MeritB2B does not collect, hold or use sensitive information such as
      Social Security numbers, credit card numbers, banking and financial
      information, bio-metric and health data or data regarding ethnicity, or
      affiliation to Trade or Political groups.
   
   Security – Where We Store Your Personal Data
   MeritB2B has procedures and technologies in place to safeguard our data
   assets which may contain your personal information. Access to data is only by
   authorized employees for legitimate business purposes. We use reasonable
   measures to ensure that partners with whom we work also have sufficient
   security processes are in place to ensure secure transfer. The data that we
   collect from our partners may be transferred to, and stored at, a destination
   outside the United Kingdom and the European Economic Area (“EEA”). We will
   store all information about you on secure servers and our data processors are
   members of Privacy Shield and upholds standards approved by the EU and Swiss
   Data Protection Authorities or have committed to be bound by the Standard
   Contractual Clauses for the Transfer of Personal Data to Processors
   Established in third countries under EU Directive 95/46 (pursuant to
   Commission Decision 2010/87/EU, currently available at. To learn more about
   the Privacy Shield program, and to view our certification page, please visit.
   
   Such data may also be processed by staff operating outside the UK or the EEA
   who work for us or for one of our suppliers. We will take all steps
   reasonably necessary to ensure that any personal data transferred outside the
   UK or the EEA is treated securely and in accordance with the applicable data
   protection laws.
   
   Legal Basis to Process Your Personal Data
   Under the applicable EU data protection laws, we need a lawful basis to
   collect and use your personal data. The law allows for six lawful bases to
   process people’s personal data, and one of them allows personal data to be
   legally collected and used if it is necessary for a legitimate interest of
   the organization – as long as on balance does not unduly impact the privacy
   rights and freedoms of individuals.
   
   Due to the nature of The OmniChannelBASE Database as we do not collect data
   from individuals directly, but rely on our third-party data providers, it is
   not practical for us to ask every individual for his/her consent. We have
   assessed our and our clients’ business interests in carrying out marketing
   activities and we have carefully considered the impact the collection and use
   of personal data could potentially have on individuals’ rights. Our
   OmniChannelBASE database contains only business data, which is used to
   promote business to other businesses and such activities are unlikely to
   affect the fundamental rights and freedoms of individuals concerned. We do
   not collect, process or retain any financial or sensitive personal data which
   could impact your rights or threaten your security. We have therefore
   concluded that the most appropriate lawful ground for the processing of your
   personal data is our and our client’s legitimate interests.
   
   In technical, legal terms we process personal data under the ground of
   “legitimate interest”. MeritB2B’s legitimate business interest is the supply
   of commercial data (and the marketing of our business.)
   
   In certain limited circumstances we may also rely on a specific consent
   provided by you for the processing of your personal data. MeritB2B respect
   your individual data rights, at any time you can withdraw your consent or be
   removed from our databases, as is your legal right, at any time by contacting
   us at the contact information below. We reserve the right to verify your
   identity as a condition to such removal. Further, we may retain certain
   personal data where we have an important legal reason to do so, such as for
   accounting or auditing persons.
   
   Uses Made of the Information
   We may use information held about you to:
   
    * Promote our clients’ goods and services to you and your business by
      marketing using channels such as direct mail, telephone, email or serving
      a digital ad to your computer or mobile device – “channels”;
    * Provide our clients with databases to enable our clients to promote their
      goods and services by using any or all of the channels above;
    * Provide you with information, products or services that you request from
      us via our website if you specifically request information;
    * If you are a client of ours, to communicate with you in any way that
      pertains to our services;
    * To notify you about changes to our service.
    * When contacting you for the above purposes we may do so by phone, post,
      email or other electronic means, unless you tell us otherwise. You may
      contact us to specify which if any channels are acceptable to contact you
      or to remove your information in its entirety as is your legal right.
    * We may share information, including personal data, with the following
      categories of third parties (which will allow your business to be found
      via online search engines or online directories, and also by prospective
      customers):
    * Suppliers of business to business goods and services, such as:
    * Employment and recruitment agencies
    * Research organizations
    * Advertisers
    * IT Hardware and Software and peripheral companies
    * Online services
    * Suppliers of electronic components
    * Office Equipment and Supplies
    * Suppliers of consulting and business services
    * HR and benefit suppliers and service providers
    * Manufacturers
    * Publishers and Media Providers
   
   Data Retention
   We collect and store personal data for the purpose of our business database.
   As such, we will only retain your personal data for as long as we believe it
   is up to date, i.e. as long as it is associated with a business that is
   included in our database. We verify our data periodically and if we learn
   that you are no longer involved with a business that is in our database, we
   will remove your data from our records.
   
   Your Rights
   You have the right to:
   
    * Request to see the personal data we hold about you. This includes the
      right to obtain a confirmation as to whether or not we process any of your
      personal data;
    * Request that we correct any inaccuracies in the personal data that we hold
      on you;
    * From May 25th, 2018, in certain circumstances you may have the right to be
      forgotten (i.e. to have your personally identifiable data deleted).
    * In certain situations, you have the right to ask for processing of your
      personal data to be restricted because there is some disagreement about
      its accuracy or legitimate usage;
    * Request that we do not process your personal data for direct marketing and
      that we will keep your contact details to ensure that no further contact
      is made;
    * Object to our processing of your personal data if we are relying on
      legitimate interest as the lawful ground for processing; and
    * Request the transfer of any personal data you have provided to us to a
      different organization.
   
   You may exercise these rights by contacting us at our contact information
   listed below. Please note that your exercise of these rights is conditioned
   by us exercising reasonable processes to verify your identity, and by us
   exercising our rights to keep certain data so long as we require it for an
   important reason, such as for accounting, auditing or legal purposes.
   
   If you have any concerns or complaints about our privacy activities relating
   to OmniChannelBASE International – a MeritB2B LLC Product, you can contact us
   by email privacy@meritb2b.com. Or you can write to us at Privacy Officer,
   MeritB2B, The Clubhouse, 8 St. James’s Square, St. James’s London, SW1Y 4JU,
   United Kingdom or to our Head Office – Privacy Officer, MeritB2B LLC, 2
   International Drive, Rye Brook, NY 10573 United States of America.
   
   You can also contact the UK’s Information Commissioner’s Office on + 44 (0)
   303 123 1113 (www.ico.org.uk).

 * 
   OPT-OUT AND CONSUMER PREFERENCES
   
   If you would like to opt-out of digital advertising programs that we engage
   in, through third-party platforms and networks (as well as those platforms
   and networks more generally), you may go to the following industry sources
   and "opt-out" channels, which provide opt-out resources to which many
   third-party platforms subscribe:
   
   http://www.networkadvertising.org/ or http://www.aboutads.info/choices
   
   You may opt-out of MeritB2B's corporate communications, used to promote our
   events and products and services at any time by using the unsubscribe
   mechanism within the email you receive, or you can use the opt-out contact
   info below.
   
   To opt-out of any of our database products and services utilized by our
   clients for legitimate business purposes, please click the unsubscribe button
   in any email you receive from us or you can use the following methods:
   
   CONTACT US
   
   We take your privacy seriously. To opt-out of any of the communication
   methods covered in this privacy policy, or if have any questions, comments
   and requests regarding this privacy policy or our data compliance, please use
   our dedicated Privacy 1 800 number; 1 800 368 7602, email us -
   privacy@meritb2b.com or click here https://go.meritb2b.com/YourRights.
   Alternatively you could also write to us at the below address:
   
   Attn: Privacy Manager
   MeritB2B
   2 International Drive, Suite 300
   Rye Brook
   NY 10573
   USA
   
   or
   
   Attn: Privacy Manager
   MeritB2B
   The Clubhouse
   8 St. James's Square
   St. James's
   London, SW1Y 4JU
   UK
   
   PRIVACY STATEMENTS UPDATES
   
   We may periodically update our privacy policy. Updates will be posted to our
   website, so please check back for any changes.
   
   Changes to Our Privacy Policy:
   
   Any changes we may make to our privacy policy in the future will be posted on
   this page and, where appropriate, notified to you by e-mail. MeritB2B
   respects your privacy rights and takes this issue seriously, we will fulfill
   all requests regarding any data we hold on you within all required time
   frames.
   
   If you have any questions, comments and requests regarding this privacy
   policy or our data compliance please contact us on: privacy@meritb2b.com or
   write to us at the above address.
   
   Privacy Policy Last Update: June 2021.


 * PRIVACY STATEMENT-CALIFORNIA RESIDENTS
   
   THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA) AND YOUR RIGHTS
   
   On June 28, 2018, California signed into law the California Consumer Privacy
   Act (CCPA) of 2018, which grants California residents new rights regarding
   the collection and disclosure of information about them. Effective January 1,
   2020, companies will be required to provide California residents with access
   to the categories of personal information collected about them, the specific
   pieces of personal information collected about them and categories of
   sources, and the types of third parties with whom the personal information
   was shared. CCPA also grants CA residents a right to delete their information
   and a right to opt out of future data sales and sharing. California residents
   are able to request access to a summary of any marketing data we have in our
   databases about you as an individual. This PRIVACY NOTICE FOR CALIFORNIA
   RESIDENTS supplements the information contained in the Privacy Statement of
   MERITB2B LLC and its subsidiaries (collectively, “we,” “us,” or “our”) and
   applies solely to visitors, users, and others who reside in the State of
   California (“consumers” “residents” or “you”).  We adopt this notice to
   comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other
   California privacy laws.  Any terms defined in the CCPA have the same meaning
   when used in this notice. Information We Collect We collect 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, we
   have collected the following categories of personal information from
   consumers within the last twelve (12) months:
   
    1. Identifiers
       * A real name, alias, postal address, unique personal identifier, online
         identifier, Internet Protocol address, email address, account name, or
         other similar identifiers.
    2. Personal information categories listed in the California Customer Records
       statute
       * A name, address, telephone number, email address and website. Some
         personal information included in this category may overlap with other
         categories.
    3. Protected classification characteristics under California or Federal law.
       * Gender, in terms of salutation or gender only, Mr., Mrs., MS, Male or
         Female etc.
    4. Internet or other similar network activity.
       * Browsing history, search history, information on a consumer’s
         interaction with a website, application, or advertisement.
    5. Professional or Employment- related Information – MeritB2B may process,
       collect or ‘sell’ information relating to a Californian’s resident’s job
       title, including name, email address, or corporate address, phone number
       and information about what you may be responsible for purchasing in your
       role, such as ‘computer software.’ The categories of entities to which we
       may sell that information are, generally, business to business services
       providers, advertising networks and data platforms, retailers of business
       products and services, data compilers and resellers, MeritB2B do not
       process, collect or ‘sell’ information pertaining to past employment
       history or any performance evaluations.
   
   We obtain the categories of personal information listed above from the
   following categories of sources:
   
    * Directly from our clients or their agents. For example, from documents
      that our clients provide to us related to the services for which they
      engage us.
    * Indirectly from our clients or their agents. For example, through
      information we collect from our clients in the course of providing
      services to them.
    * Directly and indirectly from activity on our website (www.meritb2b.com).
      For example, from submissions through our website portal or website usage
      details collected automatically.
    * From third parties that interact with us in connection with the services
      we perform and offer to our clients. For example, from carefully screened,
      third party data partners who may have collected and processed data about
      you as an individual and license that data to us.
   
   Use of Personal Information:  Our purposes in collecting and using personal
   information We may use or disclose the personal information we collect for
   one or more of the following business purposes:
   
    * To provide you with information, products or services that you request
      from us.
    * To provide you with email alerts, event registrations and other notices
      concerning our products or services, or events or news, that may be of
      interest to you.
    * To carry out our obligations and enforce our rights arising from any
      contracts entered into between you and us, including for billing and
      collections.
    * To improve our website and present its contents to you.
    * To service contracts with our clients to help them fulfill their marketing
      programs to develop new business and service existing business
    * For testing, research, analysis and product development.
   
    * To provide our data and data marketing services, which we generally
      describe below:
   
   Our Purposes for collecting, using and sharing Personal Information Data
   marketing services, for example:
   
    * Generally, creating data marketing tools and products for our marketer
      clients, as more fully described in our Privacy Policy (and on our
      websites). This includes our provision of datasets, data “appends”
      (connecting data across datasets), data “scoring” (providing inferences
      about potential consumer behavior), data hygiene services (helping
      customers to evaluate, validate and correct personal information they
      hold.
    * Helping our clients identify and understand their consumers better, by
      providing insights about them and managing loyalty programs, as well as
      providing financial and other scoring products.
    * Assisting our clients through our Services to provide their current and
      prospective customers with better service, improved offerings, and special
      promotions, for instance, advising on which current or prospective
      customers are most likely to be interested (or disinterested) in certain
      offers.
   
   Online targeting, for example:
   
    * Creating or helping to create defined audience segments based on common
      demographics and/or shared (actual or inferred) interests or preferences
      (e.g., technology professionals). When we do this, we work with a data
      partner that “matches” our or other Information through de-identification
      techniques (such as through coded data “hashing”) with online cookies and
      other identifiers, in order to target and measure ad campaigns online
      across various display, mobile and other media channels.
   
   Additional marketing services, for example (which may overlap with “data
   marketing services” above):
   
    * Assisting in targeting and optimizing of direct mail and email campaigns,
      display, mobile and social media marketing, including by providing
      customer insights.
    * Measuring the effectiveness of online or offline ad campaigns by
      determining which messages are most likely to be seen or opened by which
      types of consumers, or which types of ads are most likely to lead to
      purchases.
    * Analyzing and optimizing our clients’ (or their service providers’)
      proprietary databases, to assist in our client’s marketing campaigns to
      reach new customers.
   
   Operating our Services, for example: 
   
    * improving, testing, updating and verifying our own database.
    * developing new products.
    * operating, analyzing, improving, and securing our Services.
   
   Other internal purposes, for example: For internal research, internal
   operations, auditing, detecting security incidents, debugging, short-term and
   transient use, quality control, and legal compliance.  We use the information
   collected from our own website, from social networks, from other “business to
   business” interaction (such as at trade shows) or from data compilers for the
   above, as well as for our own marketing purposes. Sharing Personal
   Information We 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. In the preceding twelve (12)
   months, we have disclosed the following categories of personal information
   for a business purpose:
   
    * Category A: Identifiers
    * Category B: California Customer Records personal information categories
    * Category C: Protected classification characteristics under California or
      Federal law
    * Category D: Internet or other similar network activity
    * Category E: Professional or Employment- related Information
   
   We disclose your personal information for a business purpose to the following
   categories of third parties:
   
    * Our affiliates and clients
    * Service providers.
    * Third parties to whom you or your agents authorize us to disclose your
      personal information in connection with products or services we provide to
      you.
    * As noted above, we also “sell” information related to employment, such as
      name, job title, email address etc
   
   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 Right To Know If you are
   a California resident, you have the right to request that we 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 (which will require us to obtain certain information from you for
   purposes of verification), 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 or selling 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 sold or disclosed your personal information for a business purpose,
      two separate lists disclosing:
      * sales, identifying the personal information categories that each
        category of recipient purchased; and
      * disclosures for a business purpose, identifying the personal information
        categories that each category of recipient obtained.
   
   Deletion Request Rights You also have the right as a California resident to
   request that we 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, we will delete (and direct our
   service providers to delete) your personal information from our records,
   unless an exception applies.  (Note that most of the information in our files
   is not obtained directly from consumers, so this deletion right may not
   apply.) We may deny your deletion request if retaining the information is
   necessary for us or our service providers to:
   
    * 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.
    * Detect security incidents, protect against malicious, deceptive,
      fraudulent, or illegal activity, or prosecute those responsible for such
      activities.
    * Debug products to identify and repair errors that impair existing intended
      functionality.
    * Exercise free speech ensure the right of another consumer to exercise
      their free speech rights, or exercise another right provided for by law.
    * Comply with the California Electronic Communications Privacy Act (Cal.
      Penal Code § 1546).
    * Engage in public or peer-reviewed scientific, historical, or statistical
      research in the public interest that adheres to all other applicable
      ethics and privacy laws, when the information’s deletion may likely render
      impossible or seriously impair the research’s achievement, if you
      previously provided informed consent.
    * Enable solely internal uses that are reasonably aligned with consumer
      expectations based on your relationship with us.
    * Comply with a legal obligation.
    * Make other internal and lawful uses of that information that are
      compatible with the context in which you provided it.
   
   Exercising your right to opt-out of the sale of your personal information
   California residents may opt out of the “sale” of their personal information.
   California law broadly defines what constitutes a “sale” – including in the
   definition making available a wide variety of information in exchange for
   “valuable consideration.” Depending what information we have about you, and
   whether we have included any of it in our marketing products and services, we
   may have sold (as defined by California law) certain categories of
   information about you in the last 12 months, as described in this Addendum.
   If you would like to opt out, and are a resident of California and wish to
   contact us; please use our dedicated 1 800 number; Email or Webform below.
   Exercising Access, Data Portability, Do Not Sell My Personal Information and
   Deletion Rights To exercise the access, data portability, and deletion rights
   described above, please submit a verifiable consumer request to us by either:
   
    * Calling our Toll-Free Number (800) 368-7602 and following the prompts on
      the recorded message
    * Visiting  DO NOT SELL MY PERSONAL INFO
    * Emailing CCPArequests@meritb2b.com
   
   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. The verifiable consumer request must:
   
    * Provide sufficient information that allows us to contact you and
      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 may reach out to you to obtain
      additional information so we can effectively verify you and fulfill your
      request
    * Making a verifiable consumer request does not require you to create an
      account with us.  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 We   will confirm receipt of request within 10 days and
   respond to a verifiable consumer request within 45 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. Non-Discrimination We will not discriminate against
   you for exercising any of your CCPA rights. Unless permitted by the CCPA, we
   will not:
   
    * Deny you goods or services.
    * Charge you different prices or rates for goods or services, including
      through granting discounts or other benefits, or imposing penalties.
    * Provide you a different level or quality of goods or services.
    * Suggest that you may receive a different price or rate for goods or
      services or a different level or quality of goods or services.
   
   Changes to Our Privacy Notice We reserve the right to amend this privacy
   notice at our discretion and at any time. When we make changes to this
   privacy notice, we will notify you through a notice on our website homepage.
   August 2020 – MERITB2B LLC
   
   OPT-OUT AND CONSUMER PREFERENCES
   
   If you would like to opt-out of digital advertising programs that we engage
   in, through third-party platforms and networks (as well as those platforms
   and networks more generally), you may go to the following industry sources
   and “opt-out” channels, which provide opt-out resources to which many
   third-party platforms subscribe:
   
   http://www.networkadvertising.org/ or http://www.aboutads.info/choices
   
   You may opt-out of MeritB2B’s corporate communications, used to promote our
   events and products and services at any time by using the unsubscribe
   mechanism within the email you receive, or you can use the opt-out contact
   info below.
   
   To opt-out of any of our database products and services utilized by our
   clients for legitimate business purposes, please click the unsubscribe button
   in any email you receive from us.
   
   CONTACT US
   
   We take your privacy seriously. To opt-out of any of the communication
   methods covered in this privacy policy, or if have any questions, comments
   and requests regarding this privacy policy or our data compliance, please
   email privacy@meritb2b.com or write to us at the below address:
   
   Attn: Privacy Manager
   MeritB2B
   2 International Drive, Suite 300
   Rye Brook
   NY 10573
   USA
   
   or
   
   Attn: Privacy Manager
   MeritB2B
   The Clubhouse
   8 St. James’s Square
   St. James’s
   London, SW1Y 4JU
   United Kingdom
   
   If you are a resident of California and wish to contact us; please use our
   dedicated 1 800 number; 1 800 368 7602, email us
   – CCPArequests@meritb2b.com or click here DO NOT SELL MY PERSONAL INFO
   
   DISCLOSURE OF INFORMATION
   
   MeritB2B may be required to disclose consumer information by a government
   enforcement authority or Court Order. In the event of a sale or merger,
   MeritB2B LLC may transfer data to the new owners or subsidiaries as required
   by the acquiring entity. In such event, the transfer of information would
   still remain subject to our privacy policy.
   
   PRIVACY STATEMENTS UPDATES
   
   Privacy Policy Last Update: June 2021
   
   We may periodically update our privacy policy. Updates will be posted to our
   website, so please check back for any changes
   
   Changes to Our Privacy Policy:
   
   Any changes we may make to our privacy policy in the future will be posted on
   this page and, where appropriate, notified to you by e-mail. MeritB2B
   respects your privacy rights and takes this issue seriously, we will fulfill
   all requests regarding any data we hold on you within all required time
   frames.
   
   If you have any questions, comments and requests regarding this privacy
   policy or our data compliance please contact us on: privacy@meritb2b.com or
   write to us at the above address.
   
   If you are a resident of California and wish to contact us; please use our
   dedicated 1 800 number; 1 800 368 7602, email us – CCPArequests@meritb2b.com
   or click here DO NOT SELL MY PERSONAL INFO
   
   ANNUAL USER RIGHTS REQUEST METRICS
   
   The CCPA requires certain businesses to compile and disclose metrics on an
   annual basis regarding their compliance with the CCPA and consumer rights
   requests. The metrics must be posted by July 1 of each year. MeritB2B has
   elected to report the required metrics on a calendar year basis for the
   period of January 1, 2020 through December 31, 2020. During the previous
   calendar year, MeritB2B facilitated the following requests from California
   residents who submitted requests via our online portal, by phone or mail:
   
     Requests to Know Requests to Delete Requests to Opt-Out Total Requests
   Received 2 12 21 Number of requests complied with in whole 2 12 21 Number of
   requests complied with in part 0 0 0 Number of requests denied due to
   inablity to verify consumer 0 0 0 Average number of days to substantively
   respond 3.5 3.1 3.9

Looking for 180byTwo’s privacy policy? Click here to view complete privacy
policy.  For California residents, click here.

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