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PRIVACY POLICY

Last Updated AUGUST 2024

1. Overview

HighLevel Inc. (“HighLevel,” “we,” “us,” and “our”) respects your privacy and is
committed to protecting it through compliance with this Privacy Policy (“Privacy
Policy”). This Privacy Policy describes how we collect and use your Personal
Information when you visit our website at https://www.gohighlevel.com or
otherwise use the Platform as described further in the Terms of Service, and
that you may provide in electronic messages to HighLevel.



Please read this Privacy Policy to understand our policies and practices
regarding your Personal Information and how we will handle it. If you do not
agree with our policies and practices, do not use the Platform.  By accessing or
using the Platform, you agree and consent to this Privacy Policy.



HighLevel may change this Privacy Policy at any time, at its discretion. Your
continued use of the Platform after we make changes is deemed to be acceptance
of and consent to those changes, so please check the Privacy Policy periodically
for updates.



This Privacy Policy is subject to and governed by the HighLevel Terms of
Service. The Services are part of the Platform and are described further in the
Terms of Service.

2. The Types of Information That HighLevel Collects About You and How HighLevel
Collects Information About You

HighLevel may collect two types of information from you when you visit the
Platform: Personal Information and Non-Personal Information (collectively
“Information”).



 * “Personal Information” refers to data by which you may be personally
   identified, such as name, email address, employer, job title and department,
   and telephone number.
   
   

 * “Non-Personal Information” means data that is about you, but does not
   identify you specifically. If you do nothing during your visit to our
   Platform but browse, read pages, or view content, we will gather and store
   Information about your visit that does not identify you personally.



We collect Information:



 * Directly from you when you provide it to us. When you subscribe to a
   newsletter, create an account, make a purchase or request information from
   HighLevel, we will ask for things like your name, contact, billing, shipping
   and communication information, and account ID or credentials in order to
   fulfill your request. If you set up an appointment with us through the
   Platform, attend a trade show or event, or otherwise contact us, you may also
   voluntarily provide similar information.  If you submit any Personal
   Information about other people to us or to our service providers, you are
   responsible for making sure that you have the authority to do so and to allow
   us to use their Personal Information in accordance with this Privacy Policy
   (for example, by You asking for their consent).
   
   

 * From third parties. We obtain information through partners, vendors,
   suppliers and other third parties.  The parties from whom we obtain
   information are typically corporate enterprises (although some may also be
   educational or public enterprises) and they may be located in any of the
   locations in which we do business.  These enterprises largely fall into the
   following categories: Advertising and marketing companies, data set and
   information vendors, public database providers, social media platforms,
   partners, providers of products or services, hosts or vendors at events or
   trade shows, research partners, or enterprises that use HighLevel Services. 
   We take steps to confirm that information we receive from these third parties
   has been collected with your consent or that these parties are otherwise
   legally permitted to disclose your Personal Information to us.  We might also
   obtain information through a partner, or co-create datasets with a partner,
   as part of our business operations.  This kind of data is used for work like
   improving the Platform and other HighLevel Services, enhancing existing
   products and developing new capabilities and features.  In some cases we
   combine Personal Information about individuals that we receive from multiple
   sources, including directly collected from you or through your use of the
   Platform.
   
   

 * Automatically as you navigate through the Platform or during the time in
   which you utilize our Services.  We collect information about how you
   interact with the Platform through the use of cookies, pixel tags, and
   similar technologies.  Please view our separate Cookies Policy for more
   information on our use of cookies and similar technologies, how you can
   manage cookies and how we respond to Do Not Track signals.

3. How HighLevel Uses Personal Information It Collects About You and the
Purposes for the Collection and Use

We use Personal Information that we collect about you or that you provide to us
for the following purposes:



 * For Functionality and Development of the Platform and HighLevel Services. We
   use information to provide, offer, and personalize the Platform and other
   HighLevel Services provided to you.  Some information, like your IP address,
   is used to communicate with your device to provide network connectivity,
   measure usage levels of the Platform, diagnose server problems and provide
   security features.  Other business purposes that depend on use of your
   information include data analysis related to testing, modifying, improving or
   developing new products, services and technologies, and to identify trends.
   Some Platform features may leverage artificial intelligence (“AI”) tools to
   enhance performance capabilities. We do NOT retain Personal Information to
   develop, improve, or train generalized AI or machine learning models,
   including user data provided via third party APIs, including but not limited
   to Google Workspace APIs. HighLevel Platform’s use and transfer to any other
   app of information received from Google APIs will adhere to Google API
   Services User Data Policy, including the Limited Use requirements. We use
   cookies to make our websites and the Platform operate, work more efficiently,
   and provide analytic information. Technologies similar to cookies, such as
   pixel tags are also used in connection with the Platform. For more
   information on our use of cookies, please read our Cookies Policy.
   
   

 * For Customer Support, Platform Updating and Reporting. The Platform may use
   information to provide HighLevel with updates and reports, and to check that
   the Platform is working properly.  Update functions may automatically check
   your system to see whether files need to be refreshed, updated, or
   modernized, in order to provide you with the up-to-date security, versions,
   features, options and controls associated with your systems or devices.  We
   rely on information to analyze performance and improve and maintain the
   Platform.  We also rely on Personal Information you provide to us to provide
   you with customer support for the Platform and other HighLevel Services, and
   to verify eligibility for promotional offers.
   
   

 * For Business Operations. We use information to operate our business; for
   example, to perform accounting, auditing, billing, reconciliation, and
   collection activities. Other business purposes that depend on use of your
   Personal Information include crime or fraud monitoring and prevention,
   protecting our legal rights, and performing contractual obligations.  We also
   use Personal Information to contact you to advertise, market and sell
   HighLevel Services in accordance with your communications preferences.
   
   

 * To Communicate. We use contact information to send messages; to provide
   HighLevel Services; to respond to customer service requests; to provide
   alerts such as security updates or changes in our policies or about
   subscriptions that are ending; and to send marketing or informational
   materials like newsletters or white papers, in accordance with your
   communication preferences.  We occasionally conduct surveys, or do focused
   research or studies which may require you to voluntarily share Personal
   Information in order to participate.  These activities typically have
   additional notices that provide more information about the use of your
   Personal Information and to which you may be asked to consent.
   
   

 * For Advertising and Marketing. We may use Personal Information collected from
   you, combined with information about what advertisements you viewed and other
   information we collect, to enable us to provide personalized content and to
   study the effectiveness of advertising and marketing campaigns.  You may
   choose whether to allow or deny uses or sharing of your device’s location by
   changing your device settings, but if you choose to deny such uses or
   sharing, we may not be able to provide you with certain personalized
   HighLevel Services and content on the Platform.
   
   

 * For Statistical Purposes to Improve the Platform. We may compile Platform
   statistics into traffic reports, which help HighLevel understand, anticipate,
   and respond to user needs.  If we learn, for example, of heightened interest
   in certain aspects of the HighLevel Platform, we are likely to highlight that
   information on the Platform home page. This Information helps us create a
   better overall experience for Platform users.



LEGAL BASIS FOR OUR USE (APPLICABLE ONLY TO EEA AND UNITED KINGDOM VISITORS): 
If you are in the European Economic Area or the United Kingdom, our legal basis
for collecting and using the Personal Information described above will depend on
the Personal Information concerned and the specific context in which we collect
it.



However, we will collect Personal Information from you only where we have your
consent to do so, where we need the Personal Information to perform a contract
with you, where we have a legal obligation to do so, or where the processing is
in our legitimate interests (such as processing for administrative purposes,
direct marketing, product development or improvement, preventing fraud or
criminal acts and in support of information security) and not overridden by your
data protection interests or fundamental rights and freedoms. 



If we ask you to provide Personal Information to comply with a legal requirement
or to perform a contract with you, we will make this clear at the time of
collection. We will also tell you whether the requirement for that information
is mandatory and explain any consequences to you if you do not provide the
information.



Similarly, if we collect and use your Personal Information based on our
legitimate interests (or those of any third party), we will take reasonable
steps to provide clear notice and describe our legitimate interests.



HighLevel is the Data Controller of all Personal Information collected through
the Platform in the EEA and the United Kingdom, except with respect to the
Services (where HighLevel is the Data Processor) or where a supplemental Privacy
Policy says otherwise. The contact details for HighLevel are set out in the "HOW
TO CONTACT US” section.



If you have questions about or need further information concerning the legal
basis on which we collect and use your Personal Information for any specific
processing activity, please contact us using the contact details provided under
the “HOW TO CONTACT US” Section below.



RETENTION OF YOUR PERSONAL INFORMATION: We will only retain your Personal
Information for as long as reasonably necessary to fulfill the purposes we
collected it for, including for the purposes of satisfying any legal,
regulatory, tax, accounting or reporting requirements and for other purposes
described in this Privacy Policy.  We may retain your Personal Information for a
longer period in the event of a complaint or if we reasonably believe there is a
prospect of litigation in respect to our relationship with you.



To determine the appropriate retention period for Personal Information, we
consider the amount, nature and sensitivity of the Personal Information, the
potential risk of harm from unauthorized use or disclosure of your Personal
Information, the purposes for which we process your Personal Information and
whether we can achieve those purposes through other means, and the applicable
legal, regulatory, tax, accounting or other requirements.  In some circumstances
you can ask us to delete your data: see “YOUR LEGAL RIGHTS” below for further
information.  And in some circumstances we will anonymize your Personal
Information (so that it can no longer be associated with you) for research or
statistical purposes, in which case we may use this information indefinitely
without further notice to you.

4. How HighLevel Protects Your Information

The Platform is designed to provide reasonable and appropriate administrative,
technical and organizational security measures to protect your Personal
Information against risks such as temporary or permanent loss, destruction, and
unauthorized or unlawful access, alteration, use or disclosure.  We require our
suppliers and vendors to apply similar protections when they access or use
Personal Information that we share with them.  Users of the Platform must also
do their part in protecting the data, systems, networks, and service they are
utilizing.  No technology, data transmission or system can be guaranteed to be
100% secure.  If you have reason to believe that your interaction with us is no
longer secure (for example, if you feel that your password to any HighLevel
account has been compromised), please immediately notify us by contacting us
using the instructions in the “HOW TO CONTACT US” section below.

5. When HighLevel Shares Your Information

We work through our affiliates to provide the Platform and other HighLevel
Services.  We also work with authorized suppliers and business partners.  When
we share your Personal Information with these companies, we put in place
appropriate measures to limit the use of your information only for legal and
authorized purposes that are consistent with this Privacy Policy, as well as
appropriate confidentiality and security measures.



We also share information with third parties for advertising and marketing; when
required by law or to respond to legal process; to protect our customers; to
protect lives; to maintain the security of the Platform; and to protect our
legal rights.  We may disclose Personal Information that we collect or you
provide as described in this Privacy Policy:

 * With Affiliates and Subsidiaries. For purposes limited to and consistent with
   this Privacy Policy.
   
   

 * With Suppliers. Our authorized vendors and suppliers may require Personal
   Information to provide services we have contracted for, such as product
   delivery, website hosting, data analysis, IT services, auditing, or customer
   service.  We use a wide variety of software and tools at HighLevel, and we
   process Personal Information using these tools as a regular course of
   business.  Our contracts with suppliers and vendors include provisions to
   protect your Personal Information and limit its use.
   
   

 * With Partners. We occasionally have relationships with third parties that are
   not suppliers or vendors but are working with us to offer certain
   opportunities such as marketing and similar promotions, to enable joint
   products or research studies, or to facilitate services on the Platform.  In
   these cases, additional terms or Privacy Policies may be provided.  For third
   parties or uses not described in this Privacy Policy, we share your
   information only with a lawful basis to do so.



 * For Advertising and Marketing. We share your information with our third-party
   company partners to prepare and deliver advertising and marketing content, to
   provide content services and to enable them to provide you with more
   personalized ads and to study the effectiveness of our campaigns.
   
   
   In particular, we use third-party companies to communicate regarding goods
   and services that may be of interest to you, in accordance with your
   preferences.  You may receive this content by a variety of means such as
   email, phone or when you access and use the Platform or other HighLevel
   Services, and other websites.  Content may be based on information obtained,
   for example, through prior purchases or transactions, through your device’s
   physical location, through information about what advertisements and content
   you have viewed, or through cookies and similar technologies relating to your
   access to and use of the Platform and other websites. Please read our Cookies
   Policy for more information. You can choose whether to allow or deny uses
   and/or sharing of your device’s location by changing your device settings,
   but if you choose to deny such uses or sharing, our partners may not be able
   to provide you with the applicable Platform Services and content.



 * For Connections to Social Networks and Third Party Services. Where you are
   using our Services and have chosen to connect your social networks profiles
   to the HighLevel Services, or if you authorize a third party service to
   access your account, you are agreeing to provide information about you to the
   social networks and the third party services under their respective terms and
   privacy policies. For example, if you choose to connect your YouTube account
   to the HighLevel Services, this connection uses YouTube’s API services, and
   the Google Privacy Policy (located here) will apply to you. If you have
   authorized us to access your information via the YouTube API services, in
   addition to our normal procedure for deleting stored data, you may revoke our
   access to your data via the Google security settings page, located here.



 * Sales, Mergers & Acquisitions. We may disclose Personal Information as part
   of a contemplated or actual corporate transaction such as a reorganization,
   merger, sale, joint venture, assignment, transfer or other disposition of all
   or any portion of our business, assets or stock (including in connection with
   any bankruptcy or similar proceedings).



 * With Your Consent. HighLevel may disclose your Personal Information to any
   other person or entity where you consent to the disclosure. For information
   about how to decline our advertising and marketing, please see the section
   entitled "Your Choices & Rights" below.



 * We do NOT share your phone number or opt-in consent with third parties unless
   we’ve received your express written consent to do so.

We also share non-personally identifiable information, such as anonymized or
aggregated information, with suppliers for purposes such as analysis,
identifying trends in the areas of our products and to help research and develop
new HighLevel Services.



HighLevel does not sell any of your Personal Information for monetary
compensation.

6. Information From Children

We do not knowingly collect, use, or disclose Information from children under
16.  If we learn that we have collected the Personal Information of a child
under 16—or the equivalent minimum age depending on the jurisdiction, such as 13
in the United States per the Children’s Online Privacy Protection Act—we will
take steps to delete the information as soon as possible.  If you are under 16,
do not provide any Information about yourself to HighLevel, including your name,
address, telephone number or email address. If you become aware that Information
of a child under 16 years of age has been provided, please use one of the
methods provided under the “HOW TO CONTACT US” section below.

7. Links to Other Websites and Services

We are not responsible for the practices employed by websites or services linked
to or from the Platform, including the information or content contained
therein.  This Privacy Policy does not address, and we are not responsible for,
the policies and practices of third parties or other organizations that are not
operating on HighLevel’s behalf, including policies and practices related to
privacy and security, data collection, processing, use, storage, and
disclosure.  This includes: (a) any third party operating any site or service to
which the Platform links – the inclusion of a link on the Platform does not
imply endorsement of the linked site or service by us or by our affiliates; or
(b) any app developer, app provider, social media platform provider, operating
system provider, wireless service provider or device manufacturer (such as
Facebook, Apple, Google, Microsoft, LinkedIn, etc.) - including any Personal
Information you disclose to other organizations through or in connection with
the Platform or other HighLevel Services.

8. Do Not Track

Some browsers incorporate a "Do Not Track" (“DNT”) feature that, when turned on,
signals to websites and online services that you do not want to be tracked.  At
this time, the Platform does not respond to DNT signals.

9. YOUR LEGAL RIGHTS

HighLevel respects your rights in how your Personal Information is used and
shared. Depending on where you live, you may have rights to request access or
corrections to your personal data and make choices about the kinds of marketing
materials you receive (or choose not to receive marketing from HighLevel at
all). See below for more information, depending on your location.

10. European Privacy Rights

If you are in Europe, you may have additional rights under the GDPR, the UK
GDPR, or nFADP.  Additional choices and rights may be available to you depending
on which HighLevel Services you use.



 * Access, Correction to or Deletion of Your Information. If you would like to
   correct or update your Personal Information, or to request access to or
   deletion of your Personal Information, you may contact us by visiting the
   Platform or by using the contact details provided under the “HOW TO CONTACT
   US” section below.  If you request a change to or deletion of your Personal
   Information, please note that we may still need to retain certain information
   for recordkeeping purposes, and/or to complete any transactions that you
   began prior to requesting such change or deletion (e.g., when you make a
   purchase or enter a promotion, you may not be able to change or delete the
   Personal Information provided until after the completion of such purchase or
   promotion). Some of your information may also remain within our systems and
   other records where necessary for compliance with applicable law.
   
   
   At your request and where the law requires us to do so, we will confirm what
   Personal Information we hold about you.  You may also have a legal right to
   obtain a copy of your Personal Information.  You can make such a request by
   making a written request in one of the ways described in the “HOW TO CONTACT
   US” section below.  We may charge a processing fee for this service where
   permitted by law and we will require evidence of your identity before
   fulfilling your request.



 * Data Privacy Rights Specific to Individuals in the European Economic Area,
   the United Kingdom, and Switzerland. You can object to processing of your
   Personal Information, ask us to restrict processing of your Personal
   Information, or request portability of your Personal Information.  You can
   exercise these rights by making a written request in one of the ways
   described in the “HOW TO CONTACT US” section below.
   
   Similarly, if we have collected your Personal Information with your consent,
   you can withdraw your consent at any time.  Withdrawing your consent will not
   affect (1) the lawfulness of any processing we conducted prior to your
   withdrawal, or (2) processing your Personal Information under other legal
   bases.
   
   If you believe we are using your Personal Information in a way that is
   inconsistent with this Privacy Policy or for more information about your
   rights, contact your local data protection authority.  Additionally, under
   the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S.
   DPF, you may contact JAMS Mediation, Arbitration, and ADR Services
   (https://www.jamsadr.com/eu-us-data-privacy-framework) to address complaints
   and provide appropriate recourse free of charge to you.  Under certain
   conditions, you may invoke binding arbitration. For additional information on
   pre-arbitration requirements, please see Annex I of the DPF Principles.



 * Advertising and Marketing Choices. We give you many choices regarding our use
   and disclosure of your Personal Information for advertising and marketing
   purposes.  You may access or update your contact details and modify your
   communication preferences by using one of the methods provided under the “HOW
   TO CONTACT US” section below.  Please also note that if you choose not to
   receive marketing communications from us, we may still send you
   communications related to your products or the Platform, such as information
   about a security update, service issue or product delivery.  Some advertising
   content is delivered through the Platform’s use of cookies and similar
   technologies.  Our Cookies Policy includes more information on HighLevel’s
   use of such technologies for advertising and other purposes.

11. International Compliance

HighLevel is a global company with its headquarters in the United States.  As
such, we may transfer your Personal Information between the United States and
our affiliates and business partners in other countries.  We may also transfer
your Personal Information to our third party service providers, who may be
located in a different country to you.



HighLevel transfers information internationally in order to operate efficiently,
to improve performance, and to create redundancies to protect information in the
event of an outage or other problem.  In so doing, we will process your Personal
Information in a way that meets the commitments of this Privacy Policy and
complies with the law wherever we transfer it.



Whenever HighLevel transfers Personal Information beyond the country of origin,
we will do so in accordance with applicable laws.  For Personal Information
originating in the European Economic Area (EEA), the United Kingdom (UK), or
Switzerland that is transferred to a HighLevel entity outside the EEA, UK, or
Switzerland, HighLevel participates in the EU-U.S. Data Privacy Framework
(EU-U.S. DPF) and, as applicable, the UK extension to the EU-U.S. DPF, and/or
the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF). HighLevel commits to the
DPF Principles and, as needed, will take additional steps to provide appropriate
safeguards for the Personal Information we transfer. The Federal Trade
Commission has jurisdiction over HighLevel’s compliance with the EU-U.S. DPF,
the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF).  HighLevel may be
required to disclose Personal Information in response to lawful requests by
public authorities, including to meet national security or law enforcement
requirements. HighLevel is liable in cases of onward transfers to third parties.

12. Data Privacy Framework

HighLevel Inc. and LeadConnector LLC comply with the EU-U.S. Data Privacy
Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S.
Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of
Commerce. HighLevel has certified to the U.S. Department of Commerce that
HighLevel and LeadConnector adhere to the EU-U.S. Data Privacy Framework
Principles (EU-U.S. DPF Principles) with regard to the processing of personal
data received from the European Union in reliance on the EU-U.S. DPF and from
the United Kingdom (and Gibraltar) in reliance on the UK Extension to the
EU-U.S. DPF. HighLevel has certified to the U.S. Department of Commerce that
HighLevel and Leadconnector adhere to the Swiss-U.S. Data Privacy Framework
Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal
data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is
any conflict between the terms in this privacy policy and the EU-U.S. DPF
Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To
learn more about the Data Privacy Framework (DPF) program, and to view our
certification, please visit https://www.dataprivacyframework.gov/. HighLevel
further agrees to notify you without undue delay, if its self-certifcation under
any of the Data Privacy Framework is withdrawn, terminated, revoked or otherwise
invalidated and provide take appropriate steps to stop and remediate and
unauthorized processing of such personal data.

13. California Privacy Rights

This section is addressed to California residents only and provides more
information about your rights under the California Consumer Privacy Act or
“CCPA” (California Civil Code Section 1798.100 et seq.), as amended. Subject to
certain exceptions, the CCPA grants to California residents the rights to: be
notified about the collection, use, disclosure, sale or sharing of their
Personal Information; request access to, deletion of, or correction of their
Personal Information; request to opt out of the “sale” or “sharing” of Personal
Information (where such information is sold or shared); limit the use or
disclosure of Sensitive Personal Information (as defined under CCPA); and to not
be discriminated against for exercising such rights.



HighLevel does not sell your Personal Information.  If you wish to exercise your
right to opt-out of HighLevel using your Personal Information for
cross-contextual targeted advertising purposes (called “sharing” under the
CCPA), you may do so by using the details in the “HOW TO CONTACT US” section or
the appropriate withdrawal mechanism provided to you on the Platform.



You can request access to, correction of or deletion of your Personal
Information by using the details in the “HOW TO CONTACT US” section.  If you
request a deletion of your Personal Information, please note that HighLevel may
still need to retain certain information for recordkeeping purposes, to complete
any transactions that you began prior to requesting such deletion, to comply
with applicable law, or for other purposes permitted by CCPA.  If you submit a
request to exercise rights under CCPA, HighLevel will ask you to provide certain
information to verify your identity.  This information will depend on your prior
interactions with HighLevel and the sensitivity of Personal Information at
issue.  If HighLevel denies your request, we will explain why.



You can designate an authorized agent to make a request under the CCPA on your
behalf in certain circumstances. If you use an authorized agent for this
purpose, HighLevel may ask you to verify your identity or that you provided the
authorized agent signed permission to submit a request under the CCPA.  If you
provide an authorized agent with power of attorney pursuant to Probate Code
sections 4000 to 4465, it may not be necessary to perform these steps and
HighLevel will respond to any request from such authorized agent in accordance
with the CCPA.



The Privacy Policy describes the categories of Personal Information that
HighLevel collects and how HighLevel uses such Personal Information. If
HighLevel collects Sensitive Personal Information, we limit our use of the
Sensitive Personal Information to uses: (1) you have authorized, (2) that are
required to fulfill your requests for goods or services, or (3) that are
otherwise allowed by the CCPA or required by other laws or regulations.



The categories of Personal Information collected, disclosed, and sold from
California residents over the preceding 12 months and HighLevel’s applicable
retention periods include:

Personal Information Category Retention Period Business Purpose Collected
Disclosed Sold

Identifiers (such name, address, IP address, email, etc.)

See Section 3 of Privacy Policy: “Retention of Your Personal Information”

For functionality, customer support, business operations, communication,
advertising and marketing, and statistical purposes.

Yes

Yes

No

Personal information defined in Civil Code Section 1798.80(e) (such as
signature, SSN, financial information, and insurance information, etc.)

No

No

No

Protected personal information (such as gender, religion, sexual orientation, or
disability)

No

No

No

Commercial information (such as products or services purchased, obtained, or
considered, or other purchasing or consuming histories or tendencies, etc.)

See Section 3 of Privacy Policy: “Retention of Your Personal Information”

For development, customer support, business operations, communication,
advertising and marketing, and statistical purposes.

Yes

No

No

Biometric information

No

No

No

Internet or other similar network activity (such as information on a consumer’s
interaction with a website, application, or advertisement, etc.)

See Section 3 of Privacy Policy: “Retention of Your Personal Information”

For functionality, business operations, and statistical purposes.

Yes

Yes

No

Geolocation data

No

No

No

Audio, electronic, visual, thermal, or olfactory information

No

No

No

Professional or employment-related information

No

No

No

Education information

No

No

No

Inferences (such as analytics and preferences

Yes

Yes

No

14. Colorado Privacy Rights

This section is addressed to Colorado residents only and provides more
information about your rights under the Colorado Privacy Act or “CPA.” Subject
to certain exceptions, the CPA grants to Colorado residents the rights to: be
notified about the collection, use, disclosure, or sale of their Personal
Information; request access to, deletion of, or correction of their Personal
Information; and request to opt out of the use of Personal Information for
targeted advertising, sale, or certain profiling.



You can request access to, correction of or deletion of your Personal
Information by using the details in the “HOW TO CONTACT US” section. If you
request a deletion of your Personal Information, please note that HighLevel may
still need to retain certain information for recordkeeping purposes, to complete
any transactions that you began prior to requesting such deletion, to comply
with applicable law, or for other purposes permitted by CPA.  If you submit a
request to exercise rights under CPA, HighLevel will ask you to provide certain
information to verify your identity. This information will depend on your prior
interactions with HighLevel and the sensitivity of Personal Information at
issue. If HighLevel denies your request, we will explain why. If we have not
responded to your request or asked for additional time to respond to your
request within 45 days after you send us a request, you have the right to appeal
our failure to take action. To appeal our failure to take action, contact us
using the details in the “HOW TO CONTACT US” section.



You can designate an authorized agent to make a request under the CPA on your
behalf in certain circumstances. If you use an authorized agent for this
purpose, HighLevel may ask you to verify your identity or that you provided the
authorized agent signed permission to submit a request under the CPA.

15. Connecticut Privacy Rights

This section is addressed to Connecticut residents only and provides more
information about your rights under the Connecticut Data Privacy Act or “CTDPA.”
You can exercise your rights by using the details in the “HOW TO CONTACT US”
section. If we inform you that we decline to take action regarding your request,
you have the right to appeal our failure to take action by contacting us using
the details in the “HOW TO CONTACT US” section.

16. Utah Privacy Rights

This section is addressed to Utah residents only and provides more information
about your rights under the Utah Consumer Privacy Act or “UCPA.” You can
exercise your rights by using the details in the “HOW TO CONTACT US” section.

17. Virginia Privacy Rights

This section is addressed to Virginia residents only and provides more
information about your rights under Virginia’s Consumer Data Protection Act or
“VCDPA.” Subject to certain exceptions, the VCDPA grants to Virginia residents
the rights to: be notified about the collection, use, disclosure, or sale of
their Personal Information; request access to, deletion of, or correction of
their Personal Information; request to opt out of the use of Personal
Information for targeted advertising, sale, or certain profiling; and to not be
discriminated against for exercising such rights.



You can request access to, correction of or deletion of your Personal
Information by using the details in the “HOW TO CONTACT US” section. If you
request a deletion of your Personal Information, please note that HighLevel may
still need to retain certain information for recordkeeping purposes, to complete
any transactions that you began prior to requesting such deletion, to comply
with applicable law, or for other purposes permitted by VCDPA.  If you submit a
request to exercise rights under VCDPA, HighLevel will ask you to provide
certain information to verify your identity. This information will depend on
your prior interactions with HighLevel and the sensitivity of Personal
Information at issue. If HighLevel denies your request, we will explain why. If
we inform you that we decline to take action regarding your request, you have
the right to appeal our failure to take action. To appeal our failure to take
action, contact us using the details in the “HOW TO CONTACT US'' section.

18. How To Contact Us About This Privacy Policy

To ask questions about this Privacy Policy and our privacy practices, contact us
at legal@gohighlevel.com or by mail at:



HighLevel Inc.

ATTN: Legal Department400 North Saint Paul St., Suite 920

Dallas, Texas 75201



For the UK:

Rickert Services Ltd U

- HighLevel Inc. -

PO Box 1487

Peterborough

PE1 9XX United

Kingdomart-27-rep-highlevel@rickert-services.uk



For the EU:

Rickert Rechtsanwaltsgesellschaft mbH

- HighLevel, Inc. -

Colmantstraße

1553115 Bonn

Germany

art-27-rep-highlevel@rickert.law



In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the
Swiss-U.S. DPF, HighLevel commits to resolve DPF Principles-related complaints
about our collection and use of your personal information. EU, UK, and Swiss
individuals with inquiries or complaints regarding our handling of personal data
received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF,
and the Swiss-U.S. DPF should first contact HighLevel at: legal@gohighlevel.com

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