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PRIVACY POLICY



Mathew Greenwald & Associates, Inc. (hereinafter referred to as “Greenwald
Research”, “us,” “we,” “our,” or “Company”) has created this Privacy Policy to
apply to all users of this website https://greenwaldresearch.com/, including all
digital assets contained, or offered therein (collectively, our “Services”). 
This Privacy Policy describes, among other things, the types of information we
collect from users when you use our Services, how we use it, and how you can
access your information.

This Privacy Policy is integrated into our Terms & Conditions of Use (“Terms &
Conditions”).

By using the Services and providing us with your personal Information (defined
below), you agree to the practices described in this Privacy Policy and Terms &
Conditions referenced below and to the updates to these policies posted here
from time to time.

If you are a resident of California, Virginia, or the European Union (EU),
European Economic Area (“EEA”), and United Kingdom (“UK”), you may be entitled
to certain individual rights under the California Consumer Privacy Act of 2018
[as amended by the California Privacy Rights Act of 2020 (“CPRA”)]
(collectively, “CCPA”), Virginia Consumer Data Protection Act (“VCDPA”), or the
General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018
respectively.  Please see the Notice to Certain Residents of Data Subject Rights
Section of our Privacy Policy for your rights and how to exercise them for users
located in California, Virginia, and the EEA and UK only.


I.  INFORMATION WE COLLECT ABOUT YOU

We may collect the following categories of information about you which are
described in more detail below:  (A) information you provide to us, (B)
sensitive information, (C) information we may automatically collect, and (E)
information we may receive from third parties.  All of the information listed in
(A)-(C), (E) above, is detailed below, and hereinafter referred to as
“Information.”


A. INFORMATION YOU PROVIDE TO US

In using our Services, you may provide us with Information, including, without
limitation:

 * Individual identifiers such as name, contact information such as mailing
   address, phone number, and email address;
 * Demographic information such as gender, age, job titles, benefits as well as
   any responses to surveys;
 * Communications with us, preferences, and other Information you provide to us
   such as any messages (including via online chat feature), opinions and
   feedback that you provide to us, your user preferences (such as in receiving
   updates or marketing information), and other Information that you share with
   us when you contact us directly (such as for customer support services); and
 * Additional Information as otherwise described to you at the point of
   collection or pursuant to your consent.


B.  SENSITIVE INFORMATION

We may process the following categories of sensitive personal Information when
you use our Services:

 * Geolocation data;
 * Racial or ethnic origin, religious or philosophical beliefs, or union
   membership;
 * Information concerning health
 * Sex life and sexual orientation information;
 * Any information you provide to us voluntarily when responding to research or
   through email.


C. INFORMATION WE MAY AUTOMATICALLY COLLECT ABOUT YOU

Our Services may automatically collect the following categories of usage and
technical Information about you.  This Information is used by Greenwald Research
for the operation of the Services, to maintain quality of the Services, and to
provide general statistics regarding use of the Services.  This Information may
include:

 * IP address, which is the number associated with the service through which you
   access the Internet, like your ISP (internet service provider);
 * Date and time of your visit or use of our Services;
 * Domain server from which you are using our Services;
 * Type of computer, web browsers, search engine used, operating system, or
   platform you use;
 * Data identifying the web pages you visited prior to and after visiting our
   website or use of our Services;
 * Your movement and activity within the website, which is aggregated with other
   Information; and
 * Mobile device Information, including the type of device you use, operating
   system version, and the device identifier (or “UDID”).


D. COOKIES & TECHNOLOGIES USED TO COLLECT INFORMATION ABOUT YOU

We and/or certain service providers operating on our behalf may collect
information about your activity, or activity on devices associated with you over
time, on our sites and applications, and across non-affiliated websites or
online applications.  We may collect this Information by using certain
technologies, such as cookies, web beacons, pixels, software developer kits,
third party libraries, and other similar technologies.   Third-party service
providers, advertisers, and/or partners may also view, edit, or set their own
cookies or place web beacons.

 * Cookies (or browser cookies). A cookie is a small file placed on the hard
   drive of your computer.  You may refuse to accept browser cookies by
   activating the appropriate setting on your browser.  However, if you select
   this setting, you may be unable to access certain parts of our Services. 
   Unless you have adjusted your browser setting so that it will refuse cookies,
   our system will issue cookies when you direct your browser to our website.
 * Web Beacons. Website pages may contain small electronic files known as web
   beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs)
   that permit us, for example, to count users who have visited those pages and
   for other related statistics (for example, recording the popularity of
   certain content and verifying system and server integrity).  We also use
   these technical methods to analyze the traffic patterns, such as the
   frequency with which our users visit various parts of the Services.  These
   technical methods may involve the transmission of Information either directly
   to us or to a third party authorized by us to collect Information on our
   behalf.  Our Services use retargeting pixels from Google, Facebook, and other
   ad networks.  We also use web beacons in HTML emails that we send to
   determine whether the recipients have opened those emails and/or clicked on
   links in those emails.
 * Analytics and Fraud Detection. Analytics are tools we may use, such as Google
   Analytics, to help provide us with information about traffic to our website
   and use of our Services, which Google may share with other services and
   websites who use the collected data to contextualize and personalize the ads
   of its own advertising network.  We may also use reCAPTCHA, a tool which
   utilizes advanced risk analysis techniques to distinguish humans and bots in
   order to help us protect our websites from fraud, spam, and abuse.  You can
   view Google’s Privacy Practices here: Privacy Policy – Privacy & Terms –
   Google

Our use of online tracking technologies may be considered a “sale” or “sharing”
under certain laws.  To the extent that these online tracking technologies are
deemed to be a “sale” or “sharing” under certain laws, you can opt out of these
online tracking technologies by submitting a request via
https://greenwaldresearch.com/do-not-sell-or-share/ or by broadcasting an
opt-out preference signal, such as the Global Privacy Control (GPC).  Please
note that some features of our website may not be available to you as a result
of these choices.


E. INFORMATION WE MAY RECEIVE FROM THIRD PARTIES

We may collect additional Information about you from third-party websites,
social media platforms and/or sources providing publicly available information
(e.g., from the U.S. postal service) to help us provide services to you, help
prevent fraud, and for marketing and advertising purposes.

This Privacy Policy only applies to Information collected by our Services.  We
are not responsible for the privacy and security practices of those other
websites or Social Media Platforms or the Information they may collect (which
may include IP address).  You should contact such third parties directly to
determine their respective privacy policies.  Links to any other websites or
content do not constitute or imply an endorsement or recommendation by us of the
linked website, Social Media Platform, and/or content.


II. HOW WE USE YOUR INFORMATION


A. USE AND PURPOSE OF PROCESSING YOUR INFORMATION

We use and process your Information for things that may include, but are not
limited to, the following:

 * To provide you with the Services and Information you request;
 * To respond to your inquiries and questions and provide customer service;
 * For general or targeted marketing and advertising purposes, including sending
   you promotional material or special offers on our behalf and other third
   parties, provided that you have not already opted-out of receiving such
   communications;
 * To fulfill contracts we have with you;
 * To manage, improve, and foster relationships with third-party service
   providers, including vendors, suppliers, and parents, affiliates,
   subsidiaries, and business partners;
 * Maintain, improve, customize, or administer the Services, perform business
   analyses, or other internal purposes to improve the quality of our business,
   the Services, resolve technical problems, or improve security or develop
   other products and services;
 * Comply with our Terms & Conditions;
 * Analytics for business purposes and business intelligence;
 * Comply with any applicable laws and regulations and respond to lawful
   requests; and/or
 * For any other purposes disclosed to you at the time we collect your
   Information and/or pursuant to your consent.

We may also use Information that has been de-identified and/or aggregated for
purposes not otherwise listed above.


B.  SHARING OR DISCLOSING YOUR INFORMATION

We may share and/or disclose your Information as set forth in the Privacy Policy
and in the following circumstances:

 * Third-Party Service Providers.  We may share your Information with
   third-party service providers that perform certain functions or services on
   our behalf (such as to host the Services, manage databases, perform analyses,
   process credit card payments, provide customer service, or send
   communications for us). These third-party service providers are authorized to
   use your Information only as necessary to provide these services to us.  In
   some instances, we may aggregate Information we collect so third parties do
   not have access to your identifiable Information to identify you
   individually.
 * Disclosure of Information for Legal and Administrative Reasons.  We may
   disclose your Information without notice: (i) when required by law or to
   comply with a court order, subpoena, search warrant, or other legal process;
   (ii) to cooperate or undertake an internal or external investigation or
   audit; (iii) to comply with legal, regulatory, or administrative requirements
   of governmental authorities (including, without limitation, requests from the
   governmental agency authorities to view your Information); (iv) to protect
   and defend the rights, property, or safety of us, our subsidiaries and
   affiliates, and any of their officers, directors, employees, attorneys,
   agents, contractors, and partners, and the website Service users; (v) to
   enforce or apply our Terms & Conditions; and (vi) to verify the identity of
   the user of our Services.
 * Business Transfers. Your Information may be transferred, sold, or otherwise
   conveyed (“Conveyed”) to a third party where we:  (i) merge with or are
   acquired by another business entity; (ii) sell all or substantially all of
   our assets; (iii) are adjudicated bankrupt; or (iv) are liquidated or
   otherwise reorganize.
 * Information Shared with our Subsidiaries and Affiliates. We may share your
   Information with our subsidiaries and affiliates.
 * De-Identified or Aggregated Data. We may share your Information on an
   aggregated basis for any purpose in which your specific personal Information
   is blinded, masked, or otherwise not identifiable.
 * With Your Consent. We may share Information consistent with this Privacy
   Policy with your

 1. Categories of Information Sold

We may sell the below categories of personal Information.  For purposes of this
Privacy Policy, “sell”, “sold” or “sale” means the disclosure of personal
Information for monetary or other valuable consideration but does not include,
for example, the transfer of personal Information as an asset that is part of a
merger, bankruptcy, or other disposition of all or any portion of our business.

Category of Information Examples of Information Disclosed Usage and Technical
Information Information about your interaction with our website and content on
third-party sites or platforms, such as social networking sites (e.g., IP
address; browsing history; search history; device information; information about
user’s interaction with website, such as scrolling, clicks, timestamps and
mouse-overs via cookies, pixel tags, web beacons, transparent GIFs; browser
information; operating system and platform; geolocation information.





III. LINKS TO OTHER WEBSITES

Our Services may contain links to other websites or services that are not owned
or controlled by us, including links to Social Media Platforms such as Facebook,
Instagram, LinkedIn, or YouTube, or may redirect you off our website away from
our Services.

This Privacy Policy only applies to Information collected by our Services.  We
are not responsible for the privacy and security practices of those other
websites or Social Media Platforms or the Information they may collect (which
may include IP address).  You should contact such third parties directly to
determine their respective privacy policies.  Links to any other websites or
content do not constitute or imply an endorsement or recommendation by us of the
linked website, Social Media Platform, and/or content.


IV. INFORMATION SECURITY

We use commercially reasonable and appropriate administrative, physical, and
technical security measures to provide our Services and safeguard your
information.  However, no data transmitted over the Internet or stored or
maintained by us or our third-party service providers can be 100% secure. 
Therefore, we do not promise or guarantee, and you should not expect, that your
Information or private communications will always remain private or secure.  We
do not guarantee that your Information will not be misused by third parties.  We
are not responsible for the circumvention of any privacy settings or security
features.  You agree that we will not have any liability for misuse, access,
acquisition, deletion, or disclosure of your Information.

If you believe that your Information has been accessed or acquired by an
unauthorized person, you should promptly Contact Us so that necessary measures
can quickly be taken.


V.  DATA RETENTION

We will retain your Information for as long as needed to provide you Services,
and as necessary to comply with our legal obligations, resolve disputes, and
enforce our policies.  We will retain and use your Information as necessary to
comply with our legal obligations, resolve disputes, and enforce our
agreements.  In accordance with our routine record keeping, we may delete
certain records that contain Information you have submitted to us.  We are under
no obligation to store such Information indefinitely and disclaim any liability
arising out of, or related to, the destruction of such Information.


VI. YOUR CHOICES

 1. Marketing Communications. If you do not want to receive marketing and
    promotional emails from us, you may click on the “unsubscribe” link in the
    email to unsubscribe and opt-out of marketing email communications or see
    How to Contact Us below for more information.
 2. Opting Out of Direct Marketing by Third Parties. To exercise choices
    regarding the marketing information you receive, you may also review the
    following links:

 * You may opt-out of tracking and receiving tailored advertisements on your
   mobile device by some mobile advertising companies and other similar entities
   by downloading the App Choices app at aboutads.info/appchoices
 * You may opt-out of receiving permissible targeted advertisements by using
   the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1
   or visiting About Ads at http://optout.aboutads.info
 * You can opt-out of having your activity on our Services made available to
   Google Analytics by installing the Google Analytics opt-out add-on for your
   web browser by visiting: https://tools.google.com/dlpage/gaoptout for your
   web browser.


VII. NOTICE TO CERTAIN RESIDENTS OF DATA SUBJECT RIGHTS


A. NOTICE TO CALIFORNIA RESIDENTS

To the extent any California data privacy law applies to the collection of your
Information, this supplemental section of our Privacy Policy outlines the rights
that California residents may have, and how they can exercise those rights.
 This notice applies solely to California residents.  We provide the
supplemental section below to comply with the California Consumer Privacy Act
[as amended by the California Privacy Rights Act (referred to collectively
hereinafter as CCPA)] and any terms defined in the CCPA have the same meaning
when used below.

1.  YOUR RIGHTS UNDER CCPA

 * Right to Know and Access Specific Information. You have the right to request
   that we disclose certain information to you about our collection and use of
   your Information over the past twelve (12) months.  Once we receive and
   confirm a verifiable consumer request from you, we will disclose to you, to
   the extent permitted by law:
 * The categories of Information we collected about you, and whether we sell or
   share your information to third parties.
 * The specific pieces of Information we hold about you.
 * The categories of personal information sold within the last 12 (twelve)
   months.
 * The categories of sources from which Information about you is collected.
 * Our business or commercial purpose for collecting, selling, or sharing your
   Information.
 * The categories of third parties with whom your Information is sold, shared,
   or disclosed for a business purpose.

You have the right to request that the Information described above be provided
to you in a portable and readily useable format, to the extent technically
feasible (“data portability”).

 * Deletion Request Rights. You have the right to request that we delete the
   Information that we collected from you, subject to certain exceptions.  To
   the extent that we can delete your Information, once we receive and confirm
   your verifiable consumer request, we will delete (and direct our service
   providers to delete) your Information, unless an exception applies.
 * Right to Correct Inaccurate Information. To the extent that we may maintain
   inaccurate personal Information, you have the right to request that we
   correct such inaccurate personal information taking into account the nature
   of the personal Information and the purposes of the processing of the
   personal Information.  Once we receive and verify your verifiable consumer
   request, we will use commercially reasonable efforts to correct your personal
   Information.
 * Sale and Sharing of Personal Information and the Right to Opt Out. You have
   the right to opt out of the processing of your Information for the following
   purposes:
 * Sale of your Information.
 * Sharing of your Information for cross-context behavioral advertising.

The use of online tracking technologies may be considered a “sale” or “sharing”
under California law.  To the extent that these online tracking technologies are
deemed to be a “sale” or “sharing” under California law, you may opt out of
these online tracking technologies by submitting a request via
https://greenwaldresearch.com/do-not-sell-or-share/ or by broadcasting an
opt-out preference signal, such as the Global Privacy Control (GPC).

 * Right to Limit Use and Disclosure of Sensitive Personal Information. You have
   the right to request that we limit the ways we use and disclose your
   sensitive personal Information (as defined by CCPA) to uses which are
   necessary for us to perform the Services, or deliver the goods reasonably
   expected by you, or and as authorized by law.
 * Right to Non-Discrimination. You have a right to not be discriminated against
   in the Services or quality of Services you receive from us for exercising
   your rights.  We may not, and will not, treat you differently because of your
   data subject request activity.  As a result of your data subject request
   activity, we may not and will not deny goods or Services to you, charge
   different rates for goods or Services, provide a different level quality of
   goods or Services, or suggest that we would treat you differently because of
   your data subject request activity. 
 * Right to Disclosure of Direct Marketers. You have a right to the categories
   and names/addresses of third parties that have received personal Information
   for their direct marketing purposes upon simple request, and free of charge.

You may make an authenticated consumer request exercising your Right to Know and
Access Specific Information including Right to Know what Personal Information is
being Sold or Shared or under the CCPA twice within a twelve (12) month period. 
To exercise the rights described above, see the Exercising Your Rights section
below.

2.  AUTHORIZED AGENT

You may use an authorized agent to submit verifiable consumer requests on your
behalf provided that the authorized agent is a natural person or a business
entity that you have authorized to act on your behalf.  If you use an authorized
agent, we will require:  (1) proof of written permission for the authorized
agent to make requests on your behalf, and identity verification from you; or
(2) proof of power of attorney pursuant to California Probate Code sections 4000
to 4665.  We may deny a request from an authorized agent that does not submit
proper verification proof.

3.  NOTICE OF FINANCIAL INCENTIVE

Occasionally as an incentive for providing us with your Information, you may
receive a financial benefit in the form of gift cards, e-gift cards, drawings
for prizes, research summaries, and checks or other similar rewards that will be
sent to you.  These benefits may constitute a financial incentive under the
California Consumer Privacy Act (“Financial Incentive”).  The categories of
personal Information required for us to provide the Financial Incentives include
personal identifiers such as full name and contact information including email
address.

You have the right to decline these Financial Incentives at any time during the
research activities.  Please note that if you request deletion of part or all
your personal Information, that could affect your ability to qualify for the
research incentives.

4.  ADDITIONAL INFORMATION

To the extent permitted by applicable law, we may charge a reasonable fee to
comply with your request.


B.  NOTICE TO VIRGINIA RESIDENTS

To the extent any Virginia data privacy law applies to the collection of your
Information, this supplemental section of our Privacy Policy outlines the
individual rights guaranteed to Virginia residents and how to exercise those
rights and applies solely to Virginia residents.  We provide the supplemental
section below to comply with the Virginia Consumer Data Protection Act (“VCDPA”)
and any terms defined in the VCDPA have the same meaning when used below.

1.  YOUR RIGHTS UNDER VCDPA

Subject to certain exceptions you may be entitled to the following rights:

 * Right to Access & Data Portability. You have the right to request that we
   disclose certain information to you about our collection and use of your
   Information at any time.  Once we receive and confirm an authenticated
   consumer request from you, we will, subject to certain exceptions:
 * Disclose whether we are processing your Information.
 * Provide you with access to your Information.

Where the processing is carried out by automated means, and subject to certain
exceptions, you have the right to request and obtain a copy of your Information
that you previously provided to us in a portable and, to the extent technically
feasible, readily usable format that allows you to transmit the Information to
another data controller without hindrance.

 * Right to Correct Inaccurate Information. To the extent that we may maintain
   inaccurate Information, you have the right to request that we correct such
   inaccurate Information taking into account the nature of the personal
   Information and the purposes of the processing of the personal Information.
    Once we receive and verify your authenticated consumer request, we will use
   commercially reasonable efforts to correct your Information.
 * Right to Delete. You have the right to request that we delete certain of your
   Information provided by or obtained about you.  To the extent that we can
   delete your Information, once we receive and confirm your authenticated
   consumer request, we will delete (and direct our service providers to delete)
   your Information, subject to certain exceptions.
 * Sale of Personal Information, Targeted Advertising, Profiling, and the Right
   to Opt You have the right to opt out of the processing of your Information
   for the following purposes:
 * Targeted advertising.
 * Sale of your Information.
 * Profiling in furtherance of decisions that produce legal or similarly
   significant effects concerning you.
 * Right to Appeal. You have the right to appeal our denial of any request you
   make under this section.  To exercise your right to appeal, please submit an
   appeals request via the information in the How To Contact Us section below.
    Within sixty (60) days of receipt of your appeal, we will inform you in
   writing of any action taken or not taken in response to your appeal,
   including a written explanation of the reasons for the decisions.  If we deny
   your appeal, you may contact the Virginia Office of the Attorney General by:
 * Contacting Online:
   https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint
 * Calling:
   * If calling from Virginia, call the Consumer Protection Hotline at
     1-800-552-9963.
   * If calling from the Richmond area or from outside Virginia, call the
     Consumer Protection Hotline at 1-804-786-2042.
 * Right to Non-Discrimination. You have a right to not be discriminated against
   in the Services or quality of Services you receive from us for exercising
   your rights.  We will not discriminate against you for exercising any of your
   rights in this section including denying goods or Services, charging
   different prices or rates for goods or Services, or providing a different
   level of quality of goods and Services.  However, we may offer a different
   price, rate, level, quality, or selection of goods or Services, including
   offering goods or Services for no fee, if you have exercised your right to
   opt out or the offer is related to your voluntary participation in a bona
   fide loyalty, rewards, premium features, discounts, or club card program.

You may make an authenticated consumer request under the VCDPA twice within a
twelve (12) month period.  To exercise the rights described above, see the
Exercising Your Rights section section below.

2.  ADDITIONAL INFORMATION

To the extent permitted by applicable law, we may charge a reasonable fee to
comply with your request.


C.  NOTICE TO INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA AND THE UK

This section applies only to individuals coming to our Services from within the
European Union (EU), the European Economic Area (EEA), and the UK, and only if
we collect through the Services any Information from you that is considered
“Personal Data,” as defined in the General Data Protection Regulation (GDPR) and
the UK Data Protection Act 2018.

Personal Data includes any information relating to an identified or identifiable
natural person, who could be identified either directly or indirectly by
reference to an identifier such as a name, an identification number, location
data, an online identifier, or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural, or social identity of that
natural person (which may include some or all your Information as defined in
this Privacy Policy).

1.  IDENTITY AND CONTACT DETAILS OF CONTROLLER AND EU REPRESENTATIVE

Unless otherwise stated, we are the Data Controller for the Information we
process.

Contact Details:

Email:             legal@greenwaldresearch.com

Call us:            800-458-4516

Write us:         4201 Connecticut Ave, NW Suite 620, Washington, DC 20008

2.  YOUR DATA PROTECTION RIGHTS

To the extent the GDPR and Data Protection Act 2018 apply, and we hold your
Information in our capacity as a Data Controller as defined under those laws,
you may request that we:

 * Restrict the way that we process and share your Information;
 * Transfer your Information to a third party;
 * Provide you with access to your Information;
 * Remove your Information if no longer necessary for the purposes collected;
 * Update your Information so it is correct and not out of date; and/or
 * Object to our processing of your Information.

You may also revoke your consent for processing of your Information.  If you
wish to object to the use and processing of your Information or withdraw consent
to this Privacy Policy, you can contact us in the following ways:

Email:             legal@greenwaldresearch.com

Call us:            800-458-4516

Write us:         4201 Connecticut Ave, NW Suite 620, Washington, DC 20008

The requests above will be considered and responded to in the time-period stated
by applicable law.  Note, certain Information may be exempt from such requests.
 We may require additional Information from you to confirm your identity in
responding to such requests.

You have the right to lodge a complaint with the supervisory authorities
applicable to you and your situation, although we invite you to contact us with
any concern as we would be happy to try and resolve it directly.  Please contact
us at:

Email:             legal@greenwaldresearch.com

Call us:            800-458-4516

Write us:         4201 Connecticut Ave, NW Suite 620, Washington, DC 20008

3. LAWFUL BASIS FOR PROCESSING YOUR INFORMATION

The lawful basis for our processing of your Personal Data will depend on the
purposes of the processing.  For most Personal Data processing activities
covered by this Privacy Policy, the lawful basis is that the processing is
necessary for our legitimate business interests.  Where we process Personal Data
in relation to a contract, or a potential contract, with you, the lawful basis
is that the processing is necessary for the performance of our contract with you
or to take steps at your request prior to entering into a contract.  If we are
required to share Personal Data with law enforcement agencies or other
governmental bodies, we do so on the basis that we are under a legal obligation
to do so.  We will also use consent as the legal basis where we deem appropriate
or to the extent required by applicable law, for example, before we collect
precise location data from your mobile device.

Depending on what Personal Data we collect from you and how we collect it, we
may also rely on various grounds for processing your Personal Data, including
the following reasons:

 * Processing on the basis of legitimate business interests. When we process
   Personal Data on the basis that the processing is necessary for our
   legitimate business interests, such interests include:  (i)  providing,
   improving, and promoting our Services; (ii) communicating with current and
   potential customers, other business partners, and their individual points of
   contact; (iii) managing our relationships with our customers and other
   business partners, and their individual points of contact; (iv) other
   business development purposes; (v) sharing information within the Company, as
   well as with service providers and other third parties; and (vi) maintaining
   the safety and security of our products, Services, and employees, including
   fraud protection.
 * Processing on the basis of performance of a contract.  Examples of situations
   in which we process Personal Data as necessary for performance of a contract
   include e-commerce transactions in which you purchase a service from us.
 * Processing on the basis of consent. Examples of processing activities for
   which we may use consent as its legal basis include:  (i) collecting and
   processing precise location information from your mobile device; (ii) sending
   promotional emails when consent is required under applicable law; and (iii)
   processing Personal Data on Company Services through cookies and similar
   technologies when consent is required by applicable law.
 * Processing because we are under a legal obligation to do so.  Examples of
   situations in which we must processes Personal Data to comply with our legal
   obligations include:  (i) providing your Personal Data to law enforcement
   agencies and other governmental bodies when required by applicable laws; (ii)
   retaining business records required to be retained by applicable laws; and
   (iii) complying with court orders or other legal process.

If the processing of your Information is based on your consent, the GDPR and
Data Protection Act 2018 also allow users the right to access, revoke, or modify
your consent at any time.  Please see the How to Contact Us section, below, to
review or modify your consents.

4. CONSENT TO TRANSFER

We are operated in the United States, and we may use service providers based in
the United States to operate our business and our relationship with you.  Please
be aware that Information, including your Personal Data, that we collect will be
transferred to, stored, and processed in the United States, a jurisdiction in
which the privacy laws may not be as comprehensive as those in the country where
you reside and/or are a citizen.  We maintain measures to address the transfer
of your Personal Data between our group companies and between us and our
third-party providers in accordance with applicable data protection laws and
regulations.

5. RETENTION

We will retain your Information for as long as needed for the purposes described
in this Privacy Policy.  More specifically, the time we maintain your
Information depends on the following factors:

 * Whether we need the Information to provide the Services. We will maintain any
   data needed to provide you with the Services, such as contact information and
   payment or transaction information, for as long as needed for us to provide
   you with the Services, respond to your questions and requests, and/or
   administer your account (if applicable).
 * Whether we need the Information to comply with our legal obligations. We may
   have legal obligations to maintain your Information where a legal or
   regulatory body may ask for it in the future, for example in response to a
   data subject request or complaint.  This information may include contact
   information and location information.
 * Whether we need the Information for a legitimate business interest. We may
   store Information like contact information, cookies, and location information
   in order to perform analytics, troubleshoot errors, or improve our Services. 
   In any event, we delete the Information when it is no longer needed for our
   legitimate interest.

Regardless of our reason for retaining your information, we delete all
Information in accordance with our routine record keeping policies.


VIII.  EXERCISING YOUR DATA SUBJECT RIGHTS

To exercise any of the rights described above, please submit a verifiable
consumer request to us via the methods described below.  The verifiable consumer
request must:

 * Provide sufficient information that allows us to reasonably verify you are
   the person about whom we collected Information, or an authorized
   representative; and
 * Describe your request with sufficient detail that allows us to properly
   understand, evaluate, and respond to it.

To help protect your privacy and maintain security, if you request access to or
deletion of your Information, we will take steps and may require you to provide
certain information to verify your identity before granting you access to your
Information or complying with your request.  In addition, if you ask us to
provide you with specific pieces of Information, we may require you to sign a
declaration under penalty of perjury that you are the consumer whose Information
is the subject of the request.  Only you or your authorized agent may make a
verifiable consumer request related to your Information.  If you designate an
authorized agent to make a request on your behalf, we may require you to provide
the authorized agent written permission to do so and to verify your own identity
directly with us (as described above).  You may also make a verifiable consumer
request on behalf of your minor child.

Email:             legal@greenwaldresearch.com

Call us:            800-458-4516

Write us:         4201 Connecticut Ave, NW Suite 620, Washington, DC 20008


IX. GEOGRAPHIC LOCATION OF DATA STORAGE AND PROCESSING

Our Services are targeted to individuals located in the United States.  As such,
the Services collect Information and process and store that Information in
databases located in the United States.  If you are visiting the Services from a
country outside the United States, you should be aware that you may transfer
personally identifiable Information about yourself to the United States, and
that the data protection laws of the United States may not be as comprehensive
as those in your own country.  By visiting the Services and submitting any
personally identifiable Information you consent to the transfer of such
personally identifiable Information to the United States.


X. CHILDREN’S INFORMATION

The Services are intended only for users over the age of sixteen (16).  If we
become aware that a user is under sixteen (16) (or a higher age threshold where
applicable) and has provided us with Information, we will take steps to comply
with any applicable legal requirement to remove such Information.  Contact us if
you believe that we have mistakenly or unintentionally collected Information
from a child under the age of sixteen (16).


XI. DIFFICULTY ACCESSING OUR PRIVACY POLICY

Individuals with disabilities who are unable to usefully access our Privacy
Policy online may contact us to inquire how they can obtain a copy of our policy
in another, more easily readable format.


XII. “DO NOT TRACK” SIGNALS

We do not support “Do Not Track.”  Do Not Track is a preference you can set in
your web browser to inform websites that you do not want to be tracked.  You can
enable or disable “Do Not Track” by visiting the “Preferences” or “Settings”
page of your web browser.  Do Not Track is different from Global Privacy
Controls (“GPC”), which may notify websites of consumers’ privacy preferences
regarding the sale or sharing of personal Information, or the use of sensitive
personal Information.


XIII. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change, modify or amend this Privacy Policy at any time
to reflect changes in our products and service offerings, accommodate new
technologies, regulatory requirements, or other purposes.  If we modify our
Privacy Policy, we will update the “Effective Date” and such changes will be
effective upon posting.  It is your obligation to check our current Privacy
Policy for any changes.


XIV. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Information we have
collected about you, please contact us at the following:

Email:             legal@greenwaldresearch.com

Call us:            800-458-4516

Write us:         4201 Connecticut Ave, NW Suite 620, Washington, DC 20008

Effective Date: May 7, 2023




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