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PRIVACY POLICY

EFFECTIVE DATE: June 27, 2024

 1. About DSG

Demand Science Group, LLC, and its subsidiaries and affiliates (collectively
“DemandScience”, “DSG”, “we”, “us”, or “our”) provides an integrated platform
serving the B2B market with a suite of products that help marketing
organizations improve demand generation.  We provide our solutions, such as
Klarity (“Products and Services”) to a wide range of B2B businesses globally
leveraging our expertise across content syndication, ABM Display, and B2B Data. 

 2. Commitment to Privacy 

DSG respects privacy and are committed to protecting personal information, or
information identifying a natural person (“Personal Data”).  In this Privacy
Policy (“Policy”), we describe the types of Personal Data we collect; why we
collect it; the lawful bases for doing so; how we collect Personal Data, use
Personal Data, and disclose Personal Data; and any of your rights, including
access to your Personal Data. 

 3. Application of This Policy

This Policy applies to the Personal Data we collect when you purchase or use any
of our Products and Services, including visits to our website
at demandscience.com (“Website”). 

This Policy also applies to Business Contact Information (“BCI”) that is readily
available in the public domain, such as business name, first and last name,
business telephone number, job titles, work e-mail addresses and location in
which a business is located and an individual works.  BCI information is
collected and maintained in our B2B database.  Affiliates offering our Products
and Services that also determine the purposes and means of processing BCI
Information are Leadiro UK Limited and DS Intelligence LLC. 

By purchasing or using our Products and Services, or reading this Policy, you
agree that your Personal Data will be handled as described in this Policy. Your
purchase or use of the Products and Services, and any dispute over privacy, is
subject to this Policy and our applicable Terms of Use, including its applicable
limitations on damages and the resolution of disputes. The Terms of Use are
incorporated by reference into this Policy. 

By purchasing or using our Products and Services, or reading this Policy, you
are deemed to have agreed to the provisions of this Policy, unless you are in
the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland,
in which case you are acknowledging that you have been provided this Policy.
Without prejudice to your rights under applicable laws, this Policy is not
contractual and does not form a part of your contract with DSG or its affiliates
or subsidiaries. 

In addition, this Policy applies to Personal Data we collect or use about job
applicants or employees who are California residents (“Job Applicant and
Employee Data”). We collect, use, and disclose Job Applicant and Employee Data
for different reasons than other Personal Data we may collect, use, or disclose.
For more information about how we collect, use, or disclose Job Applicant and
Employee Data, please scroll down to the section titled “Additional Information
for Job Applicants and Employees About the CCPA”. If you would like more
information, please contact us using the information in section “19. Contact Us”
below.

 4. What Personal Data Do We Collect About You and Why?

Personal Data, as we use it in this Policy, means information that directly
identifies you and therefore, can be associated with you. This includes, but is
not limited to, your first and last name, and contact information such as your
physical address, email address, Internet Protocol address (“IP address”) and
phone number.  Personal Data may also include your professional or
employment-related details and details regarding your interaction with our
Website or email marketing. 

Personal Data We Collect Directly from You.

If you request a whitepaper or other specific content, subscribe to our
newsletters, or complete the web form on the Contact Us page, we ask you to fill
out a brief form that requests information such as your name, company, title,
e-mail address, and telephone, as well as your areas of interest and of course
the content of any message to us. Similarly, if you provide comments on any blog
or community page we may host, you will need to log in – although you may do
that via your social network account such as Facebook, Twitter, or LinkedIn. 

Of course, we collect information from you when you respond to an online or a
telemarketing survey. 

Our Website may include social media features or widgets, such as the Facebook,
YouTube, and Twitter buttons. These features may also collect your IP address,
which pages you are visiting on our Website, and may set a cookie (see below)
even if you do not ‘click’ on the social media widget. These features may also
give you the option to post information about your activities on our Website to
your social media profile page to share with others within your network. Your
interactions with these widgets and any data they may collect even if you do not
click on them are governed by the privacy policy of the company providing them. 

Personal Data We Receive from Information Readily Available in the Public
Domain.

DSG affirmatively collects and receives BCI from various third-party sources,
including our partners.  BCI is information pertaining to businesses and
individuals that is readily available in the public domain, including but not
limited to:  business name, first and last name, business telephone number, job
titles, work e-mail addresses and location in which a business is located and an
individual works. We collect this information to provide our Products and
Services to our customers. 

Personal Data We Collect Automatically.

We may automatically collect the following information about your use of our
Website through cookies, web beacons, and other technologies: your domain name;
your browser type and operating system; web pages you view; links you click;
your IP address; the length of time you visit our Website; and the referring
Uniform Resource Locator (“URL”), or the webpage that led you to our Website. We
also use cookies and other tracking mechanisms in emails that we send you. In
the email context, these tools help us know whether you’ve opened our message
and whether you have interacted with the content at all. We may combine this
information with other information that we have collected about you, including,
where applicable, your username, name, and other Personal Data. (Please see
below at Section 9, “Our Use of Cookies and Other Tracking Mechanisms” for more
information on these tools).

 5. How We Use Personal Data

We use Personal Data for the following purposes:  

To fulfill or meet the reason you provided the Personal Data. To communicate
with you about your purchase or use of our Products and Services, to respond to
your inquiries or request for information, and for other marketing and client
service purposes. 

To tailor the content and information that we may send through development of
your profile, to offer content customization, and personalized help and
instructions, and to otherwise personalize your experiences while visiting our
Website and to help connect you with others who may have Products or Services in
which you’ve expressed an interest. 

For marketing purposes. For example, we may use your Personal Data, such as your
email address or phone number, to send you content, surveys, news and
newsletters, or to otherwise contact you about our Products and Services or
information we think may interest you. We may also use automatically collected
Personal Data to determine whether and how you have interacted with any email
messages we have sent you. 

To provide our customers with access to a database of accurate business data
records including BCI which enables them to promote their goods and services
employing direct marketing to the right people (i.e., decision makers,
influencers, champions) in other businesses, and to promote your business so it
can be found when it is searched for by other businesses. 

To better understand how visitors access and use our Website, both on an
aggregated and individualized basis, in order to improve our Website. For
testing, research, analysis, and our development of our Products and Services.
To evaluate or conduct a merger, divestiture, restructuring, reorganization,
dissolution, or other sale or transfer of some or all of our assets, whether as
a going concern or as part of bankruptcy, liquidation, or similar proceeding, in
which Personal Data held by us about our Website users is among the assets
transferred. 

If we would like to use your Personal Data for any purposes other than those
described, we will obtain your prior consent unless there are other lawful bases
for processing your Personal Data (please see below at Section 7). 

 6. How We Disclose Your Personal Data

We may disclose your Personal Data within DSG, and externally with third parties
as discussed below.   

When we disclose your Personal Data, we enter into a contractually binding
agreement with the recipient of the Personal Data which requires the recipient
to comply with the European Union General Data Protection Regulation (“GDPR”),
the UK GDPR, the Canadian Personal Data Protection and Electronic Documents Act
(“PIPEDA”), as well as any implementing regulation thereof of any jurisdiction,
and any applicable data privacy laws and regulations of the United States or any
US state, Canada, or any other relevant jurisdictions.  

Internally, Within DSG. We may disclose your Personal Data internally, within
DSG. This may involve disclosing your Personal Data outside of the EEA and the
UK.  All DSG subsidiaries and affiliates have entered into an intra-company
transfer agreement committing to compliance with the GDPR, UK GDPR, PIPEDA, as
well all other applicable data privacy laws.   

Other Website Visitors. If you post a comment on the blog pages or any other
public area of our Website, your comment and identity will be available to, and
searchable by, all users of our Website. This does not apply to any personal
data you provide in a Contact Us inquiry. 

Upon Your Request or Instruction. When you request content from us or we present
you with an online or telemarketing survey, we will typically obtain your
direction to disclose limited Personal Data between DSG subsidiaries or
affiliates, or specified business customers. 

Service Providers. We may disclose the personal data we collect from you to
third party vendors, service providers, sub-processors, contractors or agents
who perform functions on our behalf. We only disclose Personal Data to our
service providers for the purpose of performing services on our behalf. We
require that these parties only process the Personal Data for limited and
specified purposes consistent with this Policy. 

Customers and Partners. We may disclose your Personal Data with our customers
and partners under lawful bases, including Consent and/or Legitimate Interest
(please see Section 7, below).  We may disclose or make your Personal Data
available to partners who provide services on our behalf, such as hosting
third-party software we have purchased and integrated into our website. 

Business Transfers. If DSG or any of its subsidiaries or affiliates are acquired
by or merged with another organization, if substantially all of our assets are
transferred to another organization, or as part of a bankruptcy proceeding, we
may transfer the personal data we have collected from you to the other
organization. 

In Response to Legal Process. We also may disclose the Personal Data we collect
from you in order to comply with the law, a judicial proceeding, court order, or
other legal process, such as in response to a court order or a subpoena. 

To Protect Us and Others. We also may disclose the Personal Data we collect from
you where we believe it is necessary to investigate, prevent, or take action
regarding illegal activities, suspected fraud, situations involving potential
threats to the safety of any person, violations of our Terms of Use or this
Policy, or as evidence in litigation in which we are involved. 

Other Purposes 

If we would like to disclose your Personal Data for any purposes other than
those described, we will obtain your prior consent, unless there are other
lawful bases for processing your Personal Data (please see Section 7, below). 

 7. Lawful Bases for Processing Personal Data

We process Personal Data in accordance with all applicable data privacy laws and
regulations.  If you are located in the European Union or Switzerland, the GDPR
applies.   

If you are located in the UK, the UK GDPR applies. Under either, there are six
lawful bases for processing of Personal Data: 

 * Consent. The processing is based on demonstrable, freely given, informed, and
   revocable consent for specific purposes. 
 * Performance of a Contract. The processing is necessary for the performance of
   a contract. 
 * Legal Obligation. The processing is necessary to comply with the law. 
 * Vital Interests. The processing is necessary to protect human lives. 
 * Public Task. The processing is necessary to perform a task in the public
   interest. 

 * Legitimate Interests. The processing is necessary for our legitimate
   interests, where those interests do not override the data protection
   interests, rights, and freedoms of the individuals. 

Consent, Performance of a Contract, and Legitimate Interests are the three
lawful bases that are most appropriate when we process Personal Data: 

Generally, Consent is the most appropriate lawful bases when: Individuals freely
consent to our processing of their Personal Data after being fully informed
(e.g., specific purposes, right to easily withdraw at any time).  

Generally, Performance of Contract is the most appropriate lawful bases when:
Our Products and Services are purchased and used, we need to process Personal
Data to fulfill our obligations under the written agreements.    

Generally, Legitimate Interests is the most appropriate lawful bases when: 

 * Owing to the nature of our business and the size of our databases, it is
   impractical for us to contact every individual to obtain his/her consent. 
 * The processing we do is unlikely to affect the fundamental rights and
   freedoms of the individuals whose data we process and make available to our
   Customers and Partners because: 

 1. Under our Business-to-Business (B2B) model, we only process BCI taken from
    the public domain (e.g., work e-mail addresses); 

 2. We provide BCI to help our customers promote their offerings to other
    businesses (i.e., B2B);  

 3. It is in the interest of the professionals whose BCI we process for us to
    maintain accurate information so that businesses can better reach the most
    relevant business contacts, thus promoting the legitimate interests of the
    individual and our customers; and 

 4. You always have the right to opt-out and restrict all further processing of
    your Personal Data.The controllers of our B2B databases are our
    subsidiary[ies] Leadiro UK Limited and DS Intelligence LLC. 

 8. How Long We Keep Your Personal Data

We typically only retain your Personal Data for the time necessary to realize
our legitimate business purposes and to comply with the law. 

 9. Our Use of Cookies and Other Tracking Technologies

We and our third-party service providers use cookies and other tracking
technologies to track information about your use of our Website. We may combine
this information with other Personal Data we collect from you (and our
third-party service providers may do so on our behalf). 

Currently, our systems do not recognize browser “do-not-track” requests. You
may, however, disable certain tracking as discussed in this section (e.g., by
disabling cookies). 

What are Cookies and how do they benefit you?

Cookies are small text files that are placed on your computer or mobile device
when you browse websites. 

Cookies are not actual programs or software. When you visit a website, it stores
a snippet of text from your visit; the next time you visit, this text is
retrieved by the website, and it enables the website to recognize you. Cookies
can be used differently depending on the actual website visited. Cookies allow
websites to store such things as user preferences. You can think of cookies as
providing a “memory” for the website, enabling it to recognize a user and
respond appropriately. Cookies on our Website do NOT store any personally
identifiable information such as names, addresses, email addresses or phone
numbers. 

For more details see: https://www.allaboutcookies.org/ 

Our cookies help us: 

 * Make our Website work as you would expect 
 * Remember your settings during visits 
 * Allow you to share pages (names/blog articles) with social networks like
   Facebook or Twitter 
 * Continuously improve our Website for you 

We do NOT use cookies to: 

 * Directly identify any individual who visits our Website. Any personally
   identifiable information (e.g., IP addresses and location) is processed
   anonymously using Google Analytics 
 * Collect any sensitive information, without your express permission 

What information is kept by the cookie? 

A cookie will typically hold: 

 * The name of the website that it has come from 
 * How long the cookie will stay on your computer or mobile device 
 * A value – usually a randomly generated unique number 

Granting Us Permission to Use Cookies

If the settings on the browser you are using to view our Website (Internet
Explorer, Google Chrome, Mozilla Firefox, etc.) are set up to allow cookies, we
take this, and your continued use of our Website, to mean that you accept and
consent to our use of cookies. Should you wish to remove or not use cookies from
our Website you can disable cookies through ‘Internet Options’ on your browser
menu at any time, however, please be aware that doing so will probably mean that
our Website may not work as well as you would expect. 

Our use of cookies falls into a few categories such as: 

 * Website function cookies 
 * Social media cookies 
 * Third party and advertising cookies 
 * Analytics cookies 

More about Our Cookies

Website function cookies, such as session or preference cookies: 

Session cookies 

 * These only last until you close your browser 
 * They are not stored on your hard drive 

 * They are usually used to track the pages that you visit so that information
   can be customized for you during that visit 

Persistent cookies 

 * These are stored on your hard drive until you delete them, or they reach
   their expiry date 
 * These may, for example, be used to remember your preferences when you use our
   Website 

We use cookies to make our Website function including:

 * Holding information once you have logged in to save you from having to
   re-login each time you visit a different page during your session
 * Once you log off or close the browser the session cookie will be removed

Third-party functions 

Our Website, like most websites, includes functionality provided by third
parties. A common example is an embedded YouTube or Vimeo video. Disabling these
cookies is likely to break the functions offered by these third parties. 

Social Media Website Cookies 

To facilitate easy sharing or liking of content on social network platforms such
Facebook and Twitter, we have included sharing buttons on our Website. The
privacy implications on this will vary from social media network to social media
network and will be dependent on the privacy settings you have chosen on these
networks. 

Third Party Analytics: Anonymous Visitor & Behavior Statistics Cookies  

We use automated devices and applications, such as Google Analytics, to evaluate
usage of our Website. We use these tools to help us improve our Website,
performance and user experiences. These entities may use cookies and other
tracking technologies to perform their services. We do not disclose your
Personal Data to these third parties and we do not receive your personal data
from these third parties.  Unless you explicitly give us your information by
filling in a form or calling us, all data that analytics programs collect is
stored anonymously where we only see totals and not specific individual data. To
opt-out of the collection of this demographic information from Google Analytics
Demographics and Interest Reporting, you can use the Google Analytics Opt-out
Browser Add-on. 

Examples include:

 * How visitors reached our Website (e.g., from a search engine, an
   advertisement, from social media site etc.)
 * The activity of users on our Website such as the number of pages viewed, time
   spent on individual pages, the pages visitors exit from our Website
 * How often visitors return to our Website
 * Visitor technology used (e.g., browser, operating system, device, etc.)

These statistics help us make our Website as user-friendly as possible, to
ensure a good experience for all visitors. 

We use:

 * Google Analytics. A program that helps us measure site usage details
   including the examples above;
 * Website Improvement Cookies. We regularly test new designs or site features
   on our Website. We do this by showing slightly different versions of our
   Website to different people and anonymously monitoring how visitors respond
   to these different versions. Ultimately this helps us to offer you a better
   website;
 * Google Advertising. Some of our business partners or third parties use
   cookies or other tracking technologies on our Website, including:
   * Third-party vendors, including Google, show ads on websites on the
     internet;
   * Third-party vendors, including Google, use cookies to serve ads based on a
     user’s prior visits to our Website;
 * We have no access to or control over these cookies. Users may opt-out of
   Google’s use of cookies by visiting the Google advertising opt-out page;
 * We use cookies to understand and save your preferences for future visits and
   compile aggregate data about website traffic and website interaction so that
   we can offer better site experiences and tools in the future. We may contract
   with third-party service providers to assist us in better understanding our
   Website visitors. These service providers are not permitted to use the
   information collected on our behalf except to help us conduct and improve our
   business;
 * You may opt-out of the DoubleClick cookie by visiting the Google advertising
   opt-out page or you may opt-out of Google Analytics by visiting the Google
   Analytics opt-out page.

AdRoll Advertising

As you browse our Website, advertising Cookies will be placed on your computer
or mobile device so that we can understand your interests. Our display
advertising partner, AdRoll, then enables us to present you with retargeting
advertising on other websites based on your previous interaction with our
Website. The techniques our partners employ do NOT collect personal information
such as your name, email address, postal address, or telephone number. You can
visit this page to opt-out of AdRoll’s and their partner’s targeted
advertising. 

Turning Cookies Off

You can switch cookies off by adjusting your internet browser settings to stop
accepting cookies.  

Please be aware though that turning off cookies will impair the performance of
many websites and not just ours. 

Local Storage Objects. We may use Flash Local Storage Objects (“Flash LSOs”) to
store your website preferences and to personalize your visit. Flash LSOs are
different from browser cookies because of the amount and type of data stored.
Typically, you cannot control, delete, or disable the acceptance of Flash LSOs
through your web browser. For more information on Flash LSOs, or to learn how to
manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page,
choose “Global Storage Settings Panel” and follow the instructions. To see the
Flash LSOs currently on your computer, choose “Website Storage Settings Panel”
and follow the instructions to review and, if you choose, to delete any specific
Flash LSO. 

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with
a unique identifier, similar in function to cookies. In contrast to cookies,
which are stored on your computer’s hard drive, clear GIFs are embedded
invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or
pixel tags), in connection with our Website to, among other things, track the
activities of Website visitors, help us manage content, and compile statistics
about Website usage. We and our third party service providers also use clear
GIFs in HTML e-mails to our customers, to help us track e-mail response rates,
identify when our e-mails are viewed, and track whether our e-mails are
forwarded. 

 10. If You Use Klarity By DemandScience

This section provides additional information about how DS Intelligence LLC may
collect, use, and disclose information about individuals who use Klarity.  For
purposes of this section, “we,” “us,” and “our” refers to DS Intelligence LLC,
and individuals who use Klarity as “Klarity Users.” This section describes how
we may collect, use, and disclose information about Klarity Users only when they
are using Klarity. Other sections of this Privacy Policy describe how Klarity
Users’ information may be collected, used, or disclosed when visiting the
Website or using other Products or Services, or if your BCI may be collected for
inclusion in our B2B databases. 

How and Why We May Collect Personal Data About Klarity Users

We collect the following categories of personal data about Klarity Users, for
the purposes stated in the chart.  We may have done this in the past 12 months. 
Klarity Users’ BCI is included in our database, and our use and disclosure of
that BCI is described above in Sections 4, “What Personal Data Do We Collect
About You”; 5, “How We Use Personal Data”; and 6, “How We Disclose Your Personal
Data”. 

Category of personal dataExamplesPurpose of collection and useIdentifiersName,
username and password, mailing address, physical address, email address,
telephone number, device ID, company, IP address ·      Communicate with you 
·      Provide and enhance Klarity 
·      Detect and prevent fraud 
·      Update our database of business contact information 
·      Market, advertise, or promote Klarity or our other products and services 
·      Comply with legal and regulatory obligations California Consumer Records
Law informationName, username and password, mailing address, physical address,
email address, telephone number, employment·      Communicate with you 
·      Provide and enhance Klarity 
·      Detect and prevent fraud 
·      Update our database of business contact information 
·      Market, advertise, or promote Klarity or our other products and services 
Comply with legal and regulatory obligations Commercial informationUse of
Klarity by DemandScience, interest in using or purchasing other products and
service we may offer·      Communicate with you 
·      Provide and enhance Klarity 
·      Detect and prevent fraud 
·      Market, advertise, or promote Klarity or our other products and services 
Comply with legal and regulatory obligations Internet or other electronic
network activityBrowsing history, clickstream data, browser and operating system
type, navigation paths, data/time stamps, cookie identifiers, and other
information about device characteristics and how you interact with Klarity by
DemandScience·      Communicate with you 
·      Provide and enhance Klarity 
·      Detect and prevent fraud 
·      Market, advertise, or promote Klarity or our other products and services 
Comply with legal and regulatory obligations Geolocation dataDevice location,
geolocation, IP address·      Provide and enhance Klarity 
·      Detect and prevent fraud 
Comply with legal and regulatory obligations Professional or employment-related
informationOccupation, title, employer, business mailing address, business email
address, business telephone number·      Communicate with you
·      Provide and enhance Klarity by DemandScience
·      Detect and prevent fraud
·      Update our database of business contact information
·      Market, advertise, or promote Klarity by DemandScience or our other
products and services
Comply with legal and regulatory obligationsMailbox informationEmails you have
sent or received·      Provide and enhance Klarity 
Comply with legal and regulatory obligations 

Additional Information for Klarity Users Located in Europe

We are required to identify the basis for Klarity to process your personal data,
if you are located in the European Economic Area or the United Kingdom. 

Generally, we process your personal data based upon our legitimate interest in
doing so, for example to manage Klarity or to detect and prevent fraud.  If you
submit your personal data to make an inquiry or to communicate with us, our
basis for processing your personal data is consent.  When you submit your
personal data to sign up to use Klarity, our basis for processing your personal
data is necessity to contract.  See Section 7, “Lawful Bases for Processing
Personal Data,” for more information about our basis for adding your personal
data that is BCI to our database. 

If you have questions, please contact us using the information in Section 20,
“Contact Us”.

Where We May Collect Personal Data About Klarity Users From

We may have collected personal data about Klarity Users from the following
sources: 

Category of sourcesCategory of personal dataFrom you
We may collect personal data from you when you sign up to use Klarity by
DemandScience, when you provide your information in a web form on Klarity by
DemandScience, or when you otherwise communicate with us.·      Identifiers
·      California Consumer Records Law information
·      Internet or other electronic network activity
·      Geolocation data
Professional or employment-related informationAutomatically
We may collect personal data from you automatically.  See Section 9, “Our Use of
Cookies and Other Tracking Technologies” for more information.·      Internet or
other electronic network activity
Geolocation data

Why We May Disclose Personal Data About Klarity Users And To Whom

e disclose personal data of Klarity Users as follows, and we may have done so in
the past 12 months:

Category of Third Party Recipient and Purpose of DisclosureCategory of personal
dataService providers
We may engage third parties to perform certain functions on our behalf.  To do
so, we may disclose personal data to our third-party business partners and
service providers in order to maintain and operate Klarity and provide, improve,
and personalize Klarity, including to fulfill requests for Klarity, and for
other technical and processing functions, such as sending e-mails on our behalf
and technical support.  We may also disclose personal data to service providers
or other third parties to detect, protect against, and respond to security
incidents or other malicious, deceptive, illegal, or fraudulent activity or
other threats and for legal compliance purposes or pursuant to legal
process.·      Identifiers 
·      California Consumer Records Law information 
·      Commercial information 
·      Internet or other electronic network activity 
Professional or employment-related information Professional Services Firms
We may disclose personal data about Klarity Users to professional services firms
that help us comply with our legal and regulatory obligations and establish,
enforce, and otherwise exercise our rights and defend against claims, including,
for example, auditors, law firms, and consultants.·      Identifiers
·      California Consumer Records Law information
·      Commercial information
·      Internet or other electronic network activity
·      Geolocation data
Professional or employment-related informationParents, Affiliates, and
Subsidiaries
DSG is the ultimate parent entity of DS Intelligence LLC and other companies
that make up the DemandScience family.  We may disclose personal data about
Klarity Users to other companies within the DemandScience family, in order to
provide Klarity or our other products and services.  When we disclose personal
data about Klarity Users to other companies within the DemandScience family,
their collection, use, and disclosure of that personal data is subject to this
Privacy Statement.  When we disclose business contact information about Klarity
Users to include in our database as B2B Participants, the collection, use, and
disclosure of that personal data is as described in Sections 4, “What Personal
Data Do We Collect About You”; 5, “How We Use Personal Data”; and 6, “How We
Disclose Your Personal Data”.·      Identifiers
·      California Consumer Records Law information
·      Commercial information
·      Internet or other electronic network activity
·      Geolocation data
Professional or employment-related informationGovernment Entities
We may disclose personal data about Klarity Users to Government Entities and law
enforcement officials, for various reasons, including as required by law or
regulation.·      Identifiers 
·      California Consumer Records Law information 
·      Commercial information 
·      Internet or other electronic network activity 
·      Geolocation data 
Professional or employment-related information Merger and Acquisition Activity
We may disclose personal data about Klarity Users to third parties in connection
with the proposed or actual financing, insuring, sale, securitization,
assignment, or other disposal of all or part of our business or assets
(including accounts) for the purposes of evaluating and performing the proposed
transaction.·      Identifiers
·      California Consumer Records Law information
·      Commercial information
·      Internet or other electronic network activity
·      Geolocation data
Professional or employment-related information

To opt out of Klarity please email privacy@klarity.com.


 11. User Generated Content

We invite you to post content on our Website and provide responses to our blog,
including your comments, pictures, and any other information that you would like
to be available on our Website. If you post content to our Website, all of the
information that you post will be available to all visitors to our Website. If
you post your own content on our Website, your posting may become public and we
cannot prevent such information from being used in a manner that may violate
this Policy, the law, or your personal privacy. 



 12. Third Party Links

Our Website may contain links to third-party websites and social media. Any
access to and use of such linked websites is not governed by this Policy, but
instead is governed by the privacy policies of those third-party websites. We
are not responsible for the information practices of such third-party websites. 

 13. Security of My Personal Data

We have implemented technical and organizational measures to protect the
information we collect from loss, misuse, and unauthorized access, disclosure,
alteration, and destruction. Please be aware that despite our efforts, no data
security measures can guarantee 100% security. 

You should take steps to protect against unauthorized access to your password,
phone, and computer by, among other things, signing off after using a shared
computer, choosing a robust password that nobody else knows or can easily guess,
and keeping your log-in and password private. We are not responsible for any
lost, stolen, or compromised passwords or for any activity on your account via
unauthorized password activity. 

 14. Access to My Personal Data

Consistent with applicable laws or regulations, we make good faith efforts to
provide you with access to your Personal Data and either to correct this data if
it is inaccurate or to delete such data at your request if it is not otherwise
required to be retained by law or for legitimate business purposes. 

Consistent with applicable laws or regulations, you may modify Personal Data
that you have submitted, or that we have obtained from other sources by
contacting us and requesting a copy of whatever identifiable information you
have provided to us. Please note that copies of information that you have
updated, modified or deleted may remain viewable in cached and archived pages of
the Website for a period of time 

 15. What Choices Do I Have Regarding Use of My Personal Data?

We may send periodic solicitations or informational emails to you. You may
opt-out of such communications by following the opt-out instructions contained
in the e-mail. Based on the requirements of data privacy laws (e.g., GDPR), it
can take up to 30 business days for us to process opt-out requests. If you
opt-out of receiving emails about recommendations or other information we think
may interest you, we may still send you e-mails about your account or any
services you have requested or received from us.

 16. Children’s Privacy

Our Website is not intended for children under the age of 16.

We do not knowingly collect information from children.  In the event that we
learn that we have collected personal on the Website from a child under age 16,
we will delete that information promptly. If you believe that we might have any
information from a child under 16, please contact us
at dataprivacy@demandscience.com.

 17. Visiting our Website from Outside the United States

If you are visiting our Website from outside the United States, please be aware
that your information will typically be transferred to, stored, and processed in
the United States, United Kingdom, Ireland, Philippines, New Zealand, Australia
and France where our servers are located and our central database is operated.
The data protection and other laws of the United States and other countries
might not be as comprehensive as those in your country. Please be assured that
we seek to take reasonable steps to ensure that your Personal Data is protected
regardless of where we hold it.

 18. Visiting to Our Website from the European Economic Area (EEA) and the
     United Kingdom (UK)

The Lawful Basis for Processing Personal Data of EEA and UK Residents

When we collect information about you through our Websites, our emails, surveys,
and so forth, the lawful basis on which we process your Personal Data is
performance of a contract between us, namely, to provide you with the content,
to help connect you with relevant vendors, and other information in response to
your request. 

To the extent that we transfer Personal Data from any legal entity we may have
in the EEA or UK to a jurisdiction outside the EEA or UK that has not been
adduced by the European Commission as providing adequate data protections, we
will ensure that such Personal Data is safeguarded through appropriate
contractual terms, and technical and organizational measures. 

Rights for EEA and UK Residents

In addition, if you are a resident of the EEA or the UK, you have the right to: 

Find out if we use your Personal Data, to access your Personal Data, and receive
copies of your Personal Data. 

Withdraw any express consent that you have provided to the processing of your
Personal Data at any time without penalty. 

Access your Personal Data and have it corrected or amended if it is inaccurate
or incomplete. 

Obtain a transferable copy of some of your Personal Data which can be
transferred to another provider when the Personal Data was processed based on
your consent. 

If you believe your Personal Data is inaccurate, no longer necessary for our
business purposes, or if you object to our processing of your Personal Data, you
also have the right to request that we restrict the processing of your Personal
Data pending our investigation and/or verification of your claim.  

Request your Personal Data be deleted or restricted under certain circumstances.
For example, if we are processing your Personal Data on the lawful basis of your
consent and have no other lawful basis to process such, you may request your
personal data be deleted when you withdraw your consent. 

If you wish to exercise any of these rights or raise a complaint on how we have
handled your Personal Data, please first contact us at the Contact Us details
below.  If you wish to make a complaint with a supervisory authority, their
contact information may be found at
https://edpb.europa.eu/about-edpb/about-edpb/members_en (if in the European
Union) or https://ico.org.uk/make-a-complaint/ (if in the UK). 

 19. California Residents

California “Shine The Light” law

Pursuant to California’s “Shine The Light” law (California Civil Code §
1798.83), California residents are entitled to request, once a year and free of
charge, certain information regarding what types of their Personal Data may be
disclosed to third parties and, in some cases, affiliates, for those third
parties’ and affiliates’ own direct marketing purposes. Under this law, a
business is to either provide California customers certain information upon
request or permit California customers to opt-out of this type of disclosure. 
You may request this information by contacting us
at dataprivacy@demandscience.com and indicate in the e-mail subject line,
“California Shine The Light Request.”  Please include your mailing address,
state of residence and e-mail address with your request. 

The California Consumer Privacy Act (CCPA), as amended by the California Privacy
Rights Act, gives California residents enhanced rights with respect to their
Personal Data that is collected by businesses. 

First, California residents may opt-out of having their Personal Data sold to
other persons or parties. 

Second, California residents have a right to know:

What specific pieces of information a business has about the resident;

Categories of Personal Data it has collected about the resident;

Categories of sources from which the Personal Data is collected;

Categories of Personal Data that the business sold, shared, or disclosed for a
business purpose about the resident;

Categories of third parties to whom the Personal Data was sold, shared, or
disclosed for a business purpose; and

The business or commercial purpose for collecting, selling, or sharing Personal
Data. 

Third, California residents can request that the Personal Data a business has
collected from them be deleted from the business’s systems and records, subject
to certain exceptions. 

Fourth, California residents can request that inaccurate Personal Data a
business maintains about them be corrected.  

DSG is covered under the CCPA as we collect and process the Personal Data of
California residents.  This Policy provides the required notices to California
residents.  The CCPA also prohibits covered businesses from providing
discriminatory treatment to California residents if they exercise their rights
under the Act. 

DSG may sell or share Personal Data of California residents. You can request to
opt-out of the sale or sharing of your Personal Data at any time by completing
the online form (available at https://demandscience.com/ccpa/) or by sending us
an e-mail at dataprivacy@demandscience.com.  Under the CCPA, we have 15 days
after receipt to implement a request to opt-out. The CCPA requires us to state
that we do not have actual knowledge that we have sold or shared the Personal
Data of California residents under 16 years of age. 

To make a “request to know,” “request to delete,” or “request to correct” your
Personal Data, send us an e-mail at dataprivacy@demandscience.com . (Please put
“Request to Know,” “Request to Delete,” or “Request to Correct” in the subject
heading of your email.)  You may also submit these requests via  Do Not Sell My
Personal Information or by mailing your request to address in the United States
to: 

Demand Science Group, LLC 

Data Protection Officer 

222 Rosewood Drive 

Danvers, MA 01923 

We will honor these requests for individuals in the United States whether or not
you would qualify as a California resident under the CCPA. 

We will confirm receipt of your request to know, delete, or correct within 10
days along with a description of what steps we will take to verify and respond. 
We must provide the requested information or delete your Personal Data within 45
days of receipt of your request but can use an additional 45 days, but we will
let you know additional time is needed. 

When contacting us, we may ask you to provide certain, limited Personal Data,
such as your name, e-mail address and/or username to verify your request and to
match with our records and systems.  We will not retain this Personal Data or
use it for any other purpose.  Residents of other states may also have similar
rights to request information about or delete their Personal Data.  To inquire
about exercising these rights, please contact us
at dataprivacy@demandscience.com. 

Additional Information for Job Applicants and Employees About the CCPA 

This subsection contains information about how we may collect, use, and disclose
the Personal Data about California residents related to any job application or
employment with us. This subsection does not contain information about how we
may collect, use, and disclose Personal Data about California residents not
related to any job application or employment with us, which is described in the
remainder of this Policy.  This subsection does not apply to non-California
residents. 

For example, if you are a California resident and apply for a job with us
through the Careers page on our Website, the Policy outside of this subsection
explains how we may collect, use, or disclose the Personal Data we collect or
generate about you as you browse or navigate our website. This subsection
explains how we may collect, use, or disclose the Personal Data you submit by
clicking “Submit Application” on our Website to apply for a job. 

In the proceeding 12 months, we may have collected the following categories of
information about job applicants and employees who are California residents: 

Category of Personal DataExamplesPurpose of Collection and UseIdentifiersName,
address, email address, phone number, social security number, online
identifier·      Communicate with job applicants and employees
·      Make employment and compensation decisions
Comply with applicable lawCalifornia Consumer Records law informationName,
social security number, address, telephone number, passport number, driver’s
license or state identification card number, education, employment, employment
history, bank account number, other financial information, medical information,
health insurance information·      Communicate with job applicants and employees
·      Make employment and compensation decisions
 
·     Provide employee benefits and compensation
Comply with applicable lawCharacteristics of protected classifications under
California or federal lawGender, race, ethnicity, veteran status, disability
status, sexual orientation, national origin, criminal records· Comply with
applicable lawFinancial informationBank account information· Provide employee
benefits and compensationInternet or other electronic network activityNetwork
activity, network connections, IP address· Detect and prevent fraud and
malicious activity
· Ensure network and information security and compliance with our IT and data
privacy and security policies
· Comply with applicable lawGeolocation informationIP geolocation· Detect and
prevent fraud and malicious activity
· Ensure network and information security and compliance with our IT and data
privacy security policies
· Comply with applicable lawAudiovisual informationRecording of calls or
meetings, headshots, sales presentations· Record keeping of meetings as business
records
· Make employment and compensation decisionsProfessional or employment-related
informationJob titles, compensation, professional experience, employment
history, references, education, degrees· Make employment and compensation
decisionsEducation informationEducational institutions attended, dates of
attendance, degrees granted· Make employment and compensation decisionsInference
informationInferences about a job applicant’s or employee’s preferences,
characteristics, psychological trends, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes· Make employment and compensation
decisions
· Comply with applicable lawSensitive personal information·      Social Security
number, driver’s license number, passport number, or state-issued identification
card number
·      Racial or ethnic origin
Health information for purposes of ADA reasonable accommodations· Comply with
applicable law

We may have collected Personal Data about job applicants or employees from the
following sources:

Category of SourcesCategory of Personal Data about Job Applicants and
EmployeesThrough job applications and the application and hiring process
We may collect Personal Data about job applicants and employees through job
applications and related application materials that they submit to us.·
Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Audiovisual information
· Professional or employment-related information · Education information
· Sensitive personal information (racial or ethnic origin, health
information)From employees
We may collect Personal Data from employees as part of the onboarding process
and continued employment process. We may also collect additional Personal Data
automatically from employees as they use our information and communication
systems.· Identifiers
· California Consumer Records Law information
· Financial information
· Information or other electronic network activity
· Geolocation information
· Audiovisual information
· Professional or employment-related information
· Inference information
· Sensitive personal information (Social Security number, driver’s license
number, passport number, or state-issued identification card number, health
information)Third party suppliers
We may collect Personal Data about job applicants or employees through
third-party suppliers, which may be Service Providers under the CCPA or not. We
use these third-party suppliers to conduct background checks, source application
information (such as when an individual applies for a position through
LinkedIn), or to identify potential candidates who may be a good fit to work
with us (such as outside recruitment agencies)· Identifiers
· California Consumer Records law information
· Professional or employment-related information
· Education information
· Inference informationOther third parties
We may collect Personal Data about job applicants or employees through other
third parties, such as through reference calls during the hiring process or
communicating with other entities to track and maintain appropriate records of
education, training, and development activities, or from healthcare providers,
as necessary to make hiring, employment, and promotion decisions.· Identifiers
· California Consumer Records law information
· Professional or employment-related information
· Education information
· Inference information



We have sold Personal Data of California residents within the past 12 months.
However, we do not sell or share the Personal Data related to and collected
through any job application or employment with us described in this section, and
we have not done so in the past 12 months. For more information about how we
sell Personal Data of California residents, please navigate in this Policy to
the section titled “California Consumer Privacy Act (CCPA)“. 

The CCPA requires us to state that we do not have actual knowledge that we have
sold or shared Personal Data of job applicants or employees under 16 years of
age. We do not have employees under 18 years of age. 

We disclose Personal Data of job applicants and employees as follows, and we may
have done so in the past 12 months: 

Category of Third Party Recipient And Purpose Of DisclosureCategory of Personal
Data about Job Applicants and EmployeesService providers
We engage third-party service providers to perform a variety of services on our
behalf, which may mean that we have to disclose Personal Data about job
applicants and employees to these third parties. For example, we may disclose
Personal Data to a payroll provider in order to process payroll, or to a SaaS
provider to provide software used by employees to fulfill their job duties and
discharge their responsibilities. When we disclose Personal Data in this way, we
put in place appropriate measures to make sure that our service providers keep
the Personal Data confidential and secure.· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Financial information
· Internet or other electronic network activity
· Audiovisual information
· Geolocation information
· Professional or employment-related information
· Education information
· Inference information
· Sensitive personal informationFinancial institutions
We may disclose Personal Data about employees to financial institutions in order
to pay employee compensation.· Identifiers
· Financial information
· Professional or employment-related informationBenefit plans
We may disclose Personal Data about employees or their dependents to our
benefits providers in order to provide benefits to our employees and their
dependents, such as health, dental, and disability insurance.· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Inference information
· Sensitive personal information (racial or ethnic origin)Professional Services
Firms
We may disclose Personal Data about job applicants or employees to professional
services firms that help us comply with our legal and regulatory obligations and
establish, enforce, and otherwise exercise our rights and defend against claims,
including, for example, auditors, law firms, and consultants.· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Financial information
· Internet or other electronic network activity
· Geolocation information
· Audiovisual information
· Professional or employment-related information
· Education information
· Inference information
· Sensitive personal informationParents, Affiliates, and Subsidiaries
Demand Science Group, LLC is the parent entity of our group of companies that
make up the DemandScience family. We may disclose Personal Data about job
applicants or employees to other companies within the DemandScience family, in
order to make employment or hiring decisions, to provide employ benefits and
compensation, or to otherwise manage and operate the DemandScience family of
companies. When we disclose Personal Data about job applicants or employees to
other companies within the DemandScience family, their collection, use, and
disclosure of that Personal Data is subject to this Policy.· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Financial information
· Internet or other electronic network activity
· Geolocation information
· Audiovisual information
· Professional or employment-related information
· Education information
· Inference information
· Sensitive personal informationGovernment Entities
We may disclose Personal Data about job applicants and employees to Government
Entities and law enforcement officials, for various reasons, including as
required by law or regulation or to confirm or verify a California resident’s
right to work in the United States.· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Financial information
· Internet or other electronic network activity
· Audiovisual information
· Geolocation information
· Professional or employment-related information
· Education information
· Inference information
· Sensitive personal informationMerger and Acquisition Activity
We may disclose Personal Data about job applicants or employees to third parties
in connection with the proposed or actual financing, insuring, sale,
securitization, assignment, or other disposal of all or part of our business or
assets (including accounts) for the purposes of evaluating and performing the
proposed transaction.· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Financial information
· Internet or other electronic network activity
· Geolocation information
· Audiovisual information
· Professional or employment-related information
· Education information
· Inference information
· Sensitive personal information

The CCPA requires us to state that we do not use or disclose sensitive personal
information about job applicants or employees for purposes other than to perform
the services reasonably expected by an average job applicant or employee who
applies for a job or is employed by us; to prevent, detect, and investigate
security incidents that compromise the availability, authenticity, integrity, or
confidentiality of stored or transmitted Personal Data; to resist malicious,
deceptive, fraudulent, or illegal actions directed at us and to prosecute those
reasonable for those actions; or to collect or process sensitive personal
information where such collection or processing is for the purpose of inferring
characteristics about a job applicant.

CCPA Consumer Request Rights Metric

During the previous calendar year (2023), DSG, received the following number of
requests from consumers who had stated they were a resident of California.   
                                                           

 RequestsRequests ActionedDeniedMean Number of Days to respondRequests to
know110<1Requests to delete29290<3Requests to opt-out81810<9Requests to
limit0000

 19. Contact Us

If you have questions regarding this Policy, or would like to report a potential
privacy or security incident or vulnerability or otherwise make a complaint,
please contact us:

Call us at 1-888-845-3020; or e-mail us at dataprivacy@demandscience.com; or
write us at:

Demand Science Group, LLC
Data Protection Officer
222 Rosewood Drive
Danvers, MA 01923

 20. Changes to This Policy

This Policy is current as of the Effective Date set forth above. We may change
this Policy from time to time, so please be sure to check back periodically. We
will post any changes to this Policy on our Website,
at https://demandscience.com/privacy-policy/





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