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Menu
 * Who We Serve
   *  * * Organizations
          * Professional Associations
          * Trade Associations
          * Chambers of Commerce
          * Association Management Companies
 * Solutions
    * * Association Management Software
        * MC Trade – Trade associations and chambers of commerce can simplify
          and configure staff workflows to manage financials and complex member
          relationships.
        * MC Professional – Growing professional associations can boost staff
          productivity, membership and revenue with this empowering, intuitive
          solution.
    * * Event Management Software
        * Conference App – Designed for member-based organizations to host
          virtual events, conferences, and trade shows.
    * * Member Engagement Software
        * Classroom – The go-to learning management system to develop your
          members, complete with certificates and structured learning paths.
        * Job Board – Add value to, and generate revenue from, employers with a
          targeted destination for job seekers.
        * CommUnity – Designed for member-based organizations to host virtual
          events, conferences, and trade shows.

 * Support
    * * Training and Support
        * Training
        * Support
    * * Client Access
        * MC Trade Help Desk
        * MC Professional Help Desk
        * MemberClicks University – Client Training Portal
        * The Loop – a community for Personify clients

 * Resources
    * * Blogs
        * See all Blogs
        * Membership Engagement
        * Member Retention
        * Membership Management
        * Association Management
    * * Guides & eBooks
        * See all Guides & eBooks
        * Membership
        * Organization Management
        * Events
        * Marketing
    * * Case Studies
        * See all Case Studies
    * * Webinars & Events
        * See all Webinars & Events
        * Hosted by MemberClicks
        * Industry Events
   
    * --------------------------------------------------------------------------------
   
    * See all Resources →

 * Company
   
    * * MemberClicks is part of the Personify technology platform.
        
        About Personify
    * * Contact Us
        
        Sales: (888) 592-0599
        Support: (855) 466-4312
        hello@memberclicks.com
        
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PERSONIFY INC. PRIVACY POLICY

Effective: August 13, 2021
Last Updated: August 13, 2021

Your privacy is important to Personify and its affiliates (collectively
referenced within this Privacy Policy as “Personify,” “we,” “us,” or “our”). We
developed this Privacy Policy to provide you with information concerning our
personal data collection and usage, as well as our privacy and security
practices when you visit our sites or use apps (collectively, “Site” or “Sites”)
or otherwise provide us with personal data.

We cannot and do not control the privacy and security practices of our clients
who collect personal data from their contacts through our Sites. If you are
interested in information concerning privacy and security practices any of the
clients that use our Sites, please directly review such client’s privacy policy.

“Personal data” is information that identifies, relates to, describes, is
reasonably capable of being associated with, or could reasonably be linked,
directly or indirectly, with a particular consumer or household. “You” and
“your” refer to specifically refers to the person reading this Privacy Policy,
which may include Personify clients and other individuals visiting our Sites.

To jump to a specific section of this Privacy Policy, please click on a link
below:

 * PERSONAL DATA COLLECTED, PROCESSED, AND DISCLOSED BY PERSONIFY
 * COOKIES & SIMILAR TECHNOLOGIES
 * THIRD-PARTY PRIVACY PRACTICES
 * CHILDREN’S PRIVACY
 * RETENTION OF PERSONAL DATA
 * PROTECTING YOUR PERSONAL DATA
 * CALIFORNIA PRIVACY RIGHTS
 * EUROPEAN PERSONAL DATA RIGHTS
 * CROSS-BORDER TRANSFERS OF PERSONAL DATA
 * DATA CONTROLLER
 * PRIVACY POLICY UPDATES
 * HOW TO CONTACT US


I. PERSONAL DATA COLLECTED, PROCESSED, AND DISCLOSED BY PERSONIFY (INCLUDING
SOURCES, PURPOSES AND THIRD-PARTY RECIPIENTS)

The table below includes the categories of personal data that Personify has
collected within the last twelve (12) months, as well as categories of personal
data Personify currently collects or reasonably anticipates collecting moving
forward.  For each category of personal data, the table also identifies: (1) the
sources from which such categories of personal data have been or may be
collected; (2) the business or commercial purposes for which such categories of
personal data have been or may be collected; and (3) the categories of third
parties with which Personify has shared or may share such categories of personal
data.

IDENTIFIERS

(e.g., information regarding your name, unique personal identifier, online
identifier, Internet Protocol (IP) address, postal address, phone number, and
email address)

and

PERSONAL INFORMATION CATEGORIES IN CALIFORNIA CUSTOMER RECORDS STATUTE

(Cal. Civ. Code § 1798.80(e))
(e.g., information regarding your name, address, phone number, bank account
number, credit or debit card number, education, employment history, and medical
information, health information, and health insurance information if such
information is collected by our clients)

SOURCES
(i.e., categories of sources from which such personal data was or may be
collected)

 * Our affiliates
 * Individuals (i.e., visitors on our Sites; attendees and organizers of
   conferences, seminars, and tradeshows)
 * Potential and actual clients
 * Content syndication vendors
 * Marketing list providers
 * Trade show sponsors
 * Website analytics service providers
 * Portal service providers (e.g., career portal)
 * Social media providers
 * Other service providers
 * Third parties that interact with us in connection with the services we
   perform
 * Governmental entities

PURPOSES 
(i.e., business or commercial purposes for which such personal data was or may
be collected)

 * Providing requested information and services (e.g., pertinent to a product,
   service, or event), and otherwise communicating with clients, potential
   clients, and users of our Sites
 * Enabling users to communicate with others through our forums
 * Performing services on behalf of our clients
 * Monitoring and enhancing the quality of services provided
 * Marketing our products and services
 * Undertaking internal research for technological development and demonstration
 * Undertaking activities to verify or maintain the quality and safety of our
   services, and to improve, upgrade, or enhance the services
 * Sharing files through secure sites
 * Managing Site administration, account access, and identify authentication
 * Meeting our regulatory reporting requirements
 * Customizing and improving Site content, user experience, and Site
   functionality
 * Diagnosing, debugging, and repairing Site issues that impair intended
   functionality
 * Troubleshooting technology issues
 * Protecting against malicious, deceptive, fraudulent, or illegal activity and
   prosecuting those responsible for that activity
 * Detecting security incidents, ad responding to reports of security or
   technical issues with our Sites
 * Protecting our legal interests and meeting our legal obligations
 * Providing requested career or contracting information
 * Considering applicants for potential positions or opportunities
 * Providing information pertinent to an actual or potential merger,
   acquisition, or other reorganization
 * Payment processing
 * Analyzing Site usage

THIRD-PARTY RECIPIENTS
(i.e., categories of third parties with which Personify has shared or may share
such personal data for a business or commercial reason)

 * Our affiliates
 * Our clients
 * Website analytics service providers
 * Portal service providers (e.g., career portal)
 * Third-party authentication providers
 * Third-party electronic payment providers
 * Digital publishing partners
 * Website content management system providers
 * Other service providers
 * Third parties involved in an actual or potential merger, acquisition, or
   other reorganization
 * Our independent contractors
 * Governmental entities
 * Litigants, court personnel, and providers of litigation-related services

CHARACTERISTICS OF PROTECTED CLASSIFICATIONS UNDER CALIFORNIA OR FEDERAL LAW

(e.g., information regarding your race, gender, veteran or military status, and
disability or disabilities)

SOURCES

(i.e., categories of sources from which such personal data was or may be
collected)

 * Personify affiliates
 * Individuals (i.e., visitors on our Sites; attendees and organizers of
   conferences, seminars, and tradeshows)
 * Portal service providers (e.g., career portal)
 * Other service providers

PURPOSES

(i.e., business or commercial purposes for which such personal data was or may
be collected)

 * Providing requested career, contracting or other information
 * Providing information pertinent to an actual or potential merger,
   acquisition, or other reorganization
 * Considering applicants for potential positions or opportunities
 * Meeting our regulatory reporting requirements
 * Protecting our legal interests and meeting our legal obligations

THIRD-PARTY RECIPIENTS
(i.e., categories of third parties with which Personify has shared or may share
such personal data for a business or commercial reason)

 * Personify affiliates
 * Portal service providers (e.g., career portal)
 * Other service providers
 * Litigants, court personnel, and providers of litigation-related services
 * Governmental entities
 * Third parties involved in an actual or potential merger, acquisition, or
   other reorganization
 * Personify independent contractors

COMMERCIAL INFORMATION

(e.g., records of personal property; information regarding products or services
you have purchased or obtained from us)

SOURCES
(i.e., categories of sources from which such personal data was or may be
collected)

 * Our affiliates
 * Individuals (i.e., visitors on our Sites; attendees and organizers of
   conferences, seminars, and tradeshows)
 * Potential and actual clients
 * Governmental entities
 * Third parties that interact with us in connection with the services we
   perform
   Service providers

PURPOSES
(i.e., business or commercial purposes for which such personal data was or may
be collected)

 * Providing requested information and services
 * Performing services on behalf of our clients
 * Marketing Personify services and products
 * Monitoring and enhancing the quality of services provided
 * Diagnosing, debugging, and repairing Site issues that impair intended
   functionality
 * Protecting our legal interests and meeting our legal obligations
 * Providing information pertinent to an actual or potential merger,
   acquisition, or reorganization

THIRD-PARTY RECIPIENTS
(i.e., categories of third parties with which Personify has shared or may share
such personal data for a business or commercial reason)

 * Personify affiliates
 * Governmental entities
 * Litigants, court personnel, and providers of litigation-related services
   Personify independent contractors
 * Service providers
 * Third parties involved in an actual or potential merger, acquisition, or
   other reorganization

INTERNET OR OTHER SIMILAR NETWORK ACTIVITY

(e.g., information regarding your browsing history and interaction with our
Sites)

SOURCES
(i.e., categories of sources from which such personal data was or may be
collected)

 * Personify affiliates
 * Individuals (i.e., visitors on our Sites)
 * Website analytics service providers
 * Other service providers
 * Cookies and similar technologies (see the Cookies & Similar Technologies
   section below for additional information)

PURPOSES
(i.e., business or commercial purposes for which such personal data was or may
be collected)

 * Analyzing Site usage and improving Site content
 * Managing Site administration
 * Protecting our legal interests and meeting our legal obligations
 * Diagnosing and repairing Site issues
 * Customizing and improving user experience and Site functionality
 * Providing information pertinent to an actual or potential merger,
   acquisition, or other reorganization

THIRD-PARTY RECIPIENTS
(i.e., categories of third parties with which Personify has shared or may share
such personal data for a business or commercial reason)

 * Personify affiliates
 * Personify independent contractors
 * Website analytics service providers
 * Website content management system provider(s)
 * Other service providers
 * Governmental entities
 * Third parties involved in an actual or potential merger, acquisition, or
   other reorganization
 * Litigants, court personnel, and providers of litigation-related services

GEOLOCATION DATA

(e.g., information regarding the geographic location of the device you use to
connect to our Sites)

SOURCES
(i.e., categories of sources from which such personal data was or may be
collected)

 * Personify affiliates
 * Individuals (i.e., visitors on our Sites)
 * Website analytics service providers
 * Other service providers

PURPOSES
(i.e., business or commercial purposes for which such personal data was or may
be collected)

 * Analyzing Site usage and improving Site content
 * Managing Site administration
 * Protecting our legal interests and meeting our legal obligations
 * Diagnosing and repairing Site issues
 * Customizing and improving user experience and Site functionality
 * Providing information pertinent to an actual or potential merger,
   acquisition, or other reorganization

THIRD-PARTY RECIPIENTS
(i.e., categories of third parties with which Personify has shared or may share
such personal data for a business or commercial reason)

 * Personify affiliates
 * Website analytics service providers
 * Other service providers
 * Governmental entities
 * Litigants, court personnel, and providers of litigation-related services
 * Website content management system providers
 * Personify independent contractors
 * Third parties involved in an actual or potential merger, acquisition, or
   other reorganization

SENSORY DATA

(e.g., audio, electronic, or similar information)

SOURCES
(i.e., categories of sources from which such personal data was or may be
collected)

 * Personify affiliates
 * Individuals (i.e., visitors on our Sites; individuals who interact with us
   via video conferencing or telephone)
 * Potential and actual Personify clients
 * Service providers

PURPOSES
(i.e., business or commercial purposes for which such personal data was or may
be collected)

 * Communicating with potential and actual Personify clients
 * Providing requested information and services
 * Improving client services
 * Information security purposes
 * Protecting our legal interests and meeting our legal obligations
 * Providing information pertinent to an actual or potential merger,
   acquisition, or other reorganization

THIRD-PARTY RECIPIENTS
(i.e., categories of third parties with which Personify has shared or may share
such personal data for a business or commercial reason)

 * Personify affiliates
 * Personify independent contractors
 * Governmental entities
 * Providers of videoconferencing services
 * Other service providers
 * Third parties involved in an actual or potential merger, acquisition, or
   other reorganization
 * Litigants, court personnel, and providers of litigation-related services

PROFESSIONAL OR EMPLOYMENT-RELATED INFORMATION
(e.g., information regarding your career interests, current job title and
business name, salary requirements, education, experience, skills, work history,
and resume)

SOURCES

(i.e., categories of sources from which such personal data was or may be
collected)

 * Individuals (i.e., visitors on our Sites; attendees and organizers of
   conferences, seminars, tradeshows, and career fairs)
 * Personify affiliates
 * Career portal service providers
 * Social media providers
 * Other service providers
 * Third parties that interact with us in connection with the services we
   perform

PURPOSES
(i.e., business or commercial purposes for which such personal data was or may
be collected)

 * Providing requested career or contracting information
 * Considering applicants for potential positions or opportunities
 * Meeting our regulatory reporting requirements
 * Protecting our legal interests and meeting our legal obligations
 * Providing information pertinent to an actual or potential merger,
   acquisition, or other reorganization

THIRD-PARTY RECIPIENTS
(i.e., categories of third parties with which Personify has shared or may share
such personal data for a business or commercial reason)

 * Personify affiliates
 * Personify independent contractors
 * Third parties involved in an actual or potential merger, acquisition, or
   other reorganization
 * Portal service providers (e.g., career portal; supplier portal)
 * Litigants, court personnel, and providers of litigation-related services
 * Other service providers
 * Governmental entities

A. NO SALE OF PERSONAL DATA

Personify has not sold personal data for any business or commercial purpose at
any point in time during the twelve (12) months prior to the effective date of
this Privacy Policy. Personify similarly does not sell any personal data of
minors under 16 years of age under any circumstances, including with or without
affirmative authorization. Personify does not and will not sell personal data.

B. LEGAL GROUNDS FOR COLLECTING AND PROCESSING PERSONAL DATA

CONSENT. The legal ground for processing your personal data that we collect when
you provide us with specific permission to do so, is your consent, which you may
withdraw at any time by clicking on any unsubscribe link that we provide or by
emailing privacy@personifycorp.com.

CONTRACTUAL NECESSITY. We may process your personal data when it is necessary in
order to enter into a contract with you (e.g., if you request that we provide
you a quote for potential services) or when it is necessary for the performance
of a contract to which you are a party (e.g., processing credit card details in
order to effect payment).

COMPLIANCE WITH LEGAL OBLIGATIONS. We also may conduct certain personal data
processing activities for purposes of meeting our legal obligations in the EU
and in EU member states (e.g., our regulatory retention obligations).

VITAL INTERESTS. Under special circumstances (e.g., in connection with natural
disasters or emergency situations), we may need to process your personal data in
order to protect the vital interests of you or one or more persons.

LEGITIMATE INTERESTS. The last legal ground for processing the personal data
that we collect for other purposes identified in the table above are Personify’s
legitimate interests in providing client services; providing quality support to
clients, potential clients, and Site users; providing conference, seminar, or
tradeshow attendees with pertinent event information; providing clients and
potential clients with marketing materials to promote our services and products;
providing clients with secure sites for project collaboration and large file
sharing; identifying qualified candidates to fill our open positions or
available contracting opportunities; maintaining compliance with applicable
global laws and regulations; providing more relevant content for users of our
Sites; identifying and fixing problems with our Sites; understanding how our
clients interact with our products, services, apps and websites so we can
enhance the client experience and functionality of our products, services, apps
and websites; and improving the overall user experience on our Sites.


II. COOKIES & SIMILAR TECHNOLOGIES

As you interact with our Sites, we, with assistance from third-party analytics
service providers, collect personal data pertaining to your use of our Sites and
the devices and programs from which you access our Sites (“Usage Data”) using
cookies and similar technologies. Cookies are small computer files sent or
accessed from your browser on your computer’s, mobile device’s, or tablet’s hard
drive that contain information about your computer, such as user ID, user
settings, browsing history, and activities conducted while using websites.

If you do not want Usage Data collected through the use of cookies and similar
technologies, there is a simple procedure in most browsers that allows you to
automatically decline many of these technologies, or to be given the choice of
declining or accepting them. Cookies that are required to enable core site
functionality cannot be disabled.

If you are in the European Union or another country that requires your consent
before processing your Usage Data, we process your Usage Data based on the
consent you provide when you click the box noting that you “agree” to the
processing of your personal data obtained through cookies and other data
collection tools. You may withdraw your consent by contacting us via email at
privacy@personifycorp.com.


III. THIRD-PARTY PRIVACY PRACTICES

Our Sites may provide links to other third-party Internet sites as a service to
you. We are not responsible for the privacy practices of such other third-party
Internet sites. If you link to such a site through our Sites, you should always
review any privacy notice that is available for that site. For example, NextRoll
provides Personify with marketing and digital media services. You may review
NextRoll’s Privacy Notice at this link.

If you choose to log in to our career portal with your social media credentials
(e.g., Facebook, Google, LinkedIn, Microsoft), your social media provider may
provide our career portal service provider with your profile, picture,
experience, education, skills, recommendations, current city, email address,
phone number, work history, and other personal data. The specific information we
and our career portal service provider receive, and the handling of personal
data by your social media provider will be governed by your social media
provider’s privacy policy.


IV. CHILDREN’S PRIVACY

Our Sites are not directed to individuals under the age of 16, and we do not
collect and process such data for our own purposes. However, some of our clients
may collect the personal data of individuals under 16 years of age through or on
our Sites. Each of our clients is responsible for its own data collection and
privacy and security practices. If you or your child submit personal data to one
of our clients, you should review our client’s privacy policy to obtain
information about our client’s data collection and privacy practices, including
its parental or guardian consent practices. No personal data should be submitted
to our Sites directly by visitors under 16 years of age. If we learn that we
have collected personal data directly from someone under 16, we will take steps
to delete the personal data as soon as possible.


V. RETENTION OF PERSONAL DATA

Personify will retain your personal data for the time period necessary to
fulfill the purposes for which your personal data was originally collected or
received and to meet our legal obligations.


VI. PROTECTING YOUR PERSONAL DATA

We implement technical and organizational measures designed to assist in
maintaining the security and confidentiality of personal data; safeguarding
against anticipated threats to the confidentiality, integrity, and availability
of personal data; and protecting your personal data against accidental or
unlawful destruction, loss, alteration, and unauthorized access or disclosure.

However, whenever personal data is processed, there is a risk that such data
could be lost, misused, modified, hacked, breached, and/or otherwise accessed by
an unauthorized third party. No system or online transmission of data is
completely secure. In addition to the technical and organizational measures that
we have in place to protect your personal data, you should use appropriate
security measures to protect your personal data. If you believe that any
personal data you provided to us is no longer secure, please notify us
immediately at privacy@personifycorp.com.


VII. CALIFORNIA PRIVACY RIGHTS

California residents have certain rights under California privacy law, including
but not limited to the California Consumer Privacy Act (“CCPA”), which gives
California residents (“consumers” or “you”) certain rights and control over
their personal data. This section of our Privacy Policy applies solely to Site
visitors, users, and other persons whose personal data we collect and/or
maintain who reside in the State of California.

Terms used in this Section, but not otherwise defined, will have the same
meaning as those terms in the CCPA.

The following are the rights provided by the CCPA to California residents:
First, you have the right to request that we disclose information about the
personal information we collect, use, disclose and/or sell concerning you.
Second, you have the right to request the deletion of personal information we
have collected or maintain about you, subject to any exceptions set forth in the
CCPA or related regulations. Third, you have the right to direct any business
that sells your personal data not to sell your personal data. Fourth, you have
the right to not receive discriminatory treatment for exercising your rights
under the CCPA.

Additionally, under California’s “Privacy Rights for California Minors in the
Digital World” law, California residents under the age of 18 have the right to
request removal of certain content that such persons have publicly posted on our
Sites. There may be circumstances under which the law does not require or permit
removal even if requested. Additionally, complete or comprehensive removal of
content or information posted on the site or app cannot be ensured. If you are a
California resident under the age of 18 who seeks removal of any personal data
that you have posted on our Sites, please submit your request using one of the
methods set forth in Section X of this Privacy Policy.


VIII. EUROPEAN PRIVACY RIGHTS

A. GDPR AND U.K. PRIVACY RIGHTS
1. OVERVIEW OF GDPR and U.K. RIGHTS
If you reside in the European Union or the U.K., you have the right, subject to
the conditions set forth in by applicable data protection law (i.e., the General
Data Protection Regulation (GDPR) or the U.K. Data Protection Act 2018), to
request access to and correction (i.e., rectification) or erasure of your
personal data, to data portability, to restriction of processing of your
personal data, to object to the processing of your personal data under certain
circumstances, and to lodge a complaint with a supervisory authority. For more
information about these rights, please visit the European Commission’s “My
Rights” page relating to GDPR, which can be displayed in a number of languages.

2. RIGHT TO OBJECT TO PROCESSING OF PERSONAL DATA
• FOR DIRECT MARKETING PURPOSES: You have the absolute right to object to the
processing of your personal data for direct marketing purposes, including
profiling for purposes of direct marketing
• FOR PUBLIC INTEREST OR EXERCISE OF OFFICAL AUTHORITY: You have the right to
object if the processing of your personal data is necessary for the performance
of a task carried out in the public interest or in the exercise of official
authority vested in the controller
• FOR LEGITIMATE INTERESTS: You have the right to object if the processing of
your personal data is necessary for the purposes of the legitimate interests
pursued by the controller or by a third party, except where such interests are
overridden by the interests or fundamental rights and freedoms of the data
subject which require protection of personal data, in particular where the data
subject is a child

B. PRIVACY SHIELD RIGHTS
If you reside in the European Union or Switzerland and if Personify, Inc., and
its affiliates, a2z Personify, LLC and MemberClicks, LLC, collect or otherwise
process your personal data, you also have the right, under the Privacy Shield,
to access and to correct, amend or delete your personal data where it is
inaccurate or where it has been processed in violation of the Privacy Shield
Principles, except where the burden or expense of providing access would be
disproportionate to the risks to your privacy or where the rights of other
individuals would be violated.

If you reside in the European Union or Switzerland, your rights under the
Privacy Shield include the right to notice of the choices and means that
Personify, Inc. offers you for limiting the use and disclosure of your personal
data. Personify, Inc., and its affiliates, a2z Personify, LLC and MemberClicks,
LLC, provides you with the opportunity to choose how your personal data may be
used under certain circumstances. If your personal data is to be used for a new
purpose that is materially different from that for which your personal data was
originally collected or subsequently authorized, or if your personal data is to
be disclosed to a third-party controller, Personify, Inc., and its affiliates,
a2z Personify, LLC and MemberClicks, LLC, will provide you with an opportunity
to choose whether to have your personal data so used or disclosed. When sharing
your personal data with third-party processors that Personify, Inc., and its
affiliates, a2z Personify, LLC and MemberClicks, LLC, have retained to perform
services on its behalf and pursuant to its instructions, Personify, Inc., and
its affiliates, a2z Personify, LLC and MemberClicks, LLC, may disclose your
personal data without offering an opportunity to opt out.

Personify, Inc., and its affiliates, a2z Personify, LLC and MemberClicks, LLC,
also provides you with specific rights related to any Sensitive Data. “Sensitive
Data” under the EU-U.S. Privacy Shield Framework is defined as personal data
specifying medical or health conditions, racial or ethnic origin, political
opinions, religious or philosophical beliefs, trade union membership, or
information specifying the sex life of an individual. Under the Swiss-U.S.
Privacy Shield Framework, “Sensitive Data” means personal data specifying
medical or health conditions, personal sexuality, racial or ethnic origin,
political opinions, religious, ideological or trade union-related views or
activities, or information on social security measures or administrative or
criminal proceedings and sanctions, which are treated outside pending
proceedings. If your sensitive personal data is to be used for a new purpose
that is different from that for which your sensitive personal data was
originally collected or subsequently authorized, or is to be disclosed to a
third party, Personify, Inc., and its affiliates, a2z Personify, LLC and
MemberClicks, LLC, will obtain your affirmative express consent prior to such
use or such disclosure.

1. PRIVACY SHIELD RIGHT TO ACCESS, CORRECT, AMEND, OR DELETE
You may have the right to access and to correct, amend or delete your personal
data where it is inaccurate or where it has been processed in violation of the
Privacy Shield Principles, except where the burden or expense of providing
access would be disproportionate to the risks to your privacy or where the
rights of other individuals would be violated.

2. PRIVACY SHIELD RIGHT TO CHOOSE
You have the right to receive notice of the choices and means that Personify,
Inc., and its affiliates, a2z Personify, LLC and MemberClicks, LLC, offer you
for limiting the use and disclosure of your personal data. Personify, Inc., and
its affiliates, a2z Personify, LLC and MemberClicks, LLC, provides you with the
opportunity to choose how your personal data may be used under certain
circumstances. If your personal data is to be used for a new purpose that is
materially different from that for which your personal data was originally
collected or subsequently authorized, or if your personal data is to be
disclosed to a third-party controller, Personify, Inc. will provide you with an
opportunity to choose whether to have your personal data so used or disclosed.
When sharing your personal data with third-party processors that Personify, Inc.
has retained to perform services on its behalf and pursuant to its instructions,
Personify, Inc. may disclose your personal data without offering an opportunity
to opt out.

3. PRIVACY SHIELD RIGHTS RELATED TO SENSITIVE DATA
Personify, Inc., and its affiliates, a2z Personify, LLC and MemberClicks, LLC,
also provides you with specific rights related to any Sensitive Data. If your
sensitive personal data is to be used for a new purpose that is different from
that for which your sensitive personal data was originally collected or
subsequently authorized, or is to be disclosed to a third party, Personify, Inc.
will obtain your affirmative express consent prior to such use or such
disclosure.
• “Sensitive Data” under the EU-U.S. Privacy Shield Framework is defined as
personal data specifying medical or health conditions, racial or ethnic origin,
political opinions, religious or philosophical beliefs, trade union membership,
or information specifying the sex life of an individual.
• “Sensitive Data” under the Swiss-U.S. Privacy Shield Framework, is defined as
personal data specifying medical or health conditions, personal sexuality,
racial or ethnic origin, political opinions, religious, ideological or trade
union-related views or activities, or information on social security measures or
administrative or criminal proceedings and sanctions, which are treated outside
pending proceedings.


IX. OTHER PRIVACY RIGHTS

If you are located outside California or the European Union, you may have
privacy rights under your local laws.


X. EXERCISING PRIVACY RIGHTS

In this section, we provide an explanation of our process for permitting
individuals to exercise any privacy rights to which they are entitled by law,
for designating an authorized agent, and for verifying the identity of
individuals who submit privacy right requests.
A. SUBMITTING REQUESTS TO EXERCISE PRIVACY RIGHTS
To exercise your rights described in this Privacy Policy, please submit a
verifiable consumer request to us through one of the following methods:

• SUBMISSION METHODS:
Emailing us at privacy@personifycorp.com;
Calling us at (877) 891-7681

• SPECIAL PROCESS FOR DELETION REQUESTS: To help ensure that none of your
information is inappropriately deleted, we utilize a two-step process for
requests to delete personal data. First, you must submit a clear request to
delete. Second, we contact you separately, and you must confirm to us that you
do, in fact, want your personal data deleted.

• SUBMISSION CONTENTS: Requests to exercise your privacy right(s) should include
the following information:
Your name;
The country in which you currently reside, and if in the United States, the
state in which you currently reside;
Which privacy right(s) you are exercising;
Details that will assist us in responding to your request, including:
If you are exercising access rights, the information to which you are requesting
access;
If you are exercising deletion rights, the information for which you are
requesting ‘deletion;
Any other relevant information about your personal data and/or the right you are
exercising; and
A phone number and/or email address at which we can reach you.

B. DESIGNATING AN AUTHORIZED AGENT TO MAKE A REQUEST
Only you or a person that you authorize to act on your behalf may make a
verifiable consumer request related to your personal data. If desired, you may
designate an authorized agent to make a verifiable consumer request on your
behalf by submitting such request to us via email at privacy@personifycorp.com
with “Request for Authorized Agent” in the subject line. Before taking action in
response to such a request, we will require your authorized agent to verify
his/her authority and identity.

C. VERIFICATION OF REQUESTS
Before responding to your request to exercise your rights, we will verify your
identity through reasonable verification measures.

Our verification processes may include requiring you to provide answers to
questions pertaining to the information we have on file for you (e.g., your
account number); requesting confirmation of the request using the your email
address on file; or calling the phone number we have on file for you to confirm
the request.
If we cannot verify your identity based on information we already have, we may
request additional information from you. If this is necessary, we will only use
the additional information for purposes of verifying your identity and for and
fraud-prevention. And if we are unable to reasonably verify your identity (and
thus unable to comply with your request), we will advise you why that is the
case.


XI. DISABILITY ASSISTANCE

We are committed to ensuring that this Privacy Policy is accessible to everyone.
Individuals with difficulty accessing information in this Privacy Policy are
encouraged to contact us by email at privacy@personifycorp.com or by calling us
at (877) 891-7681 to access the notice in another format.


XII. DO NOT TRACK

We do not track our Site users over time and across third-party websites and
online services (e.g., mobile apps), and therefore we do not respond to Do Not
Track signals. However, third parties may collect personal data relating to your
online activities over time and across different sites and apps when you use our
Sites in order to provide you with content that is likely to be of interest to
you.


XIII. THIRD-PARTY MARKETING

We do not disclose personal data received through our Sites to third parties for
their direct marketing use.


XIV. CROSS-BORDER TRANSFERS OF PERSONAL DATA

When you use our Site or Personify otherwise receives your personal data, your
personal data will be stored on servers in the United States. If you are a
member, customer, or employee of a Personify client, our client may transfer
your personal data to us in the United States.

The data protection and privacy laws of the United States may not be as
comprehensive as the laws in your country. For example, personal data
transferred to the United States may be subject to lawful access requests by
federal and state authorities in the United States.

Personify, Inc. and its affiliates, a2z Personify, LLC and MemberClicks LLC
(collectively referred to in this section as “Personify, Inc.”), participate in
and comply with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy
Shield Framework as set forth by the U.S. Department of Commerce regarding the
collection, use, and retention of personal information transferred from the
European Union and Switzerland to the United States. Personify, Inc. has
certified to the Department of Commerce that it adheres to the Privacy Shield
Principles. If there is any conflict between the terms in this privacy policy
and the Privacy Shield Principles, the Privacy Shield Principles shall govern
with respect to data processing by Personify, Inc. To learn more about the
Privacy Shield program, and to view our certification, visit
https://www.privacyshield.gov/. Personify, Inc. and its affiliates, a2z
Personify, LLC and MemberClicks, LLCis subject to the investigatory and
enforcement powers of the U.S. Federal Trade Commission, which has jurisdiction
over Personify Inc.’s compliance with the Privacy Shield.

Personify, Inc. and its affiliates, a2z Personify, LLC and MemberClicks, LLCis
committed to subject to the Privacy Shield Principles all personal data received
from the European Union or Switzerland in reliance on the Privacy Shield.
Personify, Inc. and its affiliates, a2z Personify, LLC and MemberClicks, LLCwill
remain responsible and liable under Privacy Shield for any processing of
personal data in a manner inconsistent with the Privacy Shield Principles by
third party agents to which Personify, Inc. has transferred personal data unless
Personify, Inc. proves it is not in any way responsible for the event giving
rise to the damage.

In compliance with the Privacy Shield Principles, Personify, Inc. and its
affiliates, a2z Personify, LLC and MemberClicks, LLCis committed to resolving
complaints about our collection or use of your personal information. EU and
Swiss individuals with inquiries or complaints regarding our Privacy Shield
policy should first contact Personify, Inc. and its affiliates, a2z Personify,
LLC and MemberClicks, LLCby email at privacy@personifycorp.com. Personify, Inc.
and its affiliates, a2z Personify, LLC and MemberClicks, LLChas further
committed to refer unresolved Privacy Shield complaints to an independent
dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive
timely acknowledgment of your complaint, or if your complaint is not
satisfactorily addressed, please visit
https://bbbprograms.org/privacy-shield-complaints/ for more information and to
file a complaint. This service is provided free of charge to you. 

Additionally, you may, under certain conditions, invoke binding arbitration for
Privacy Shield complaints that are not resolved by any of the other Privacy
Shield dispute resolution mechanisms.


XV. DATA CONTROLLER

Personal data received directly from clients and used by Personify itself for
its business purposes, as well as personal data collected by us through our
Sites, is controlled by Personify, Inc., which is headquartered at 6500 River
Place Blvd, Bldg. III, Ste 125, Austin, TX 78730. If your personal data was
collected by or on behalf of Personify (e.g., through our website), then such
personal data is controlled by Personify, Inc., which is located at 6500 River
Place Blvd, Bldg. III, Ste 125, Austin, TX 78730 and which you can contact by
email at privacy@personifycorp.com. However, if your personal data was collected
by or on behalf of one of our clients, then such personal data collection and
usage is controlled by that client, with Personify assisting such client as a
service provider (i.e., processor).


XVI. PRIVACY POLICY UPDATES

We will update this Privacy Policy at least once every twelve (12) months. We
also may update this Privacy Policy from time to time as we add new services or
offerings; as we improve our current services and offerings; and as technologies
and laws change. It is our policy to post any changes we make to our Privacy
Policy on our Sites. Any changes will become effective upon our posting of the
revised Privacy Policy on the Sites. The date this Privacy Policy became
effective is identified at the top of the first page. If we make material
changes to how we treat the personal data that falls within the scope of this
Privacy Policy, we will notify you by email or through a prominent notice on the
homepage of our Site.


XVII. HOW TO CONTACT US

If you have any questions about this privacy policy or our privacy practices,
any complaints or any need for assistance relating to your personal data, you
may contact us via email at privacy@personifycorp.com or by writing us at the
following address: Personify, attention Security Officer, 6500 River Place Blvd,
Bldg. III, Ste 125, Austin, TX 78730.




EMAIL

info@personifycorp.com

SALES

+1 (888) 592-0599

SUPPORT

+1 (855) 466-4312

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