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PRIVACY POLICY

LAST UPDATED: JULY 20, 2022

Our Policy:

This Privacy Policy (“Privacy Policy”) describes how MobileWorks, Inc. dba
LeadGenius and its subsidiaries and affiliates (collectively, “LeadGenius,”
“us,” “we,” or “our”) ,may collect, use, and share your personal information in
connection with the websites we own and operate that link to this Privacy Policy
(collectively, the “Site”) and our related services, events, social media pages,
and email and other electronic communications (collectively, and together with
the Site, the “Services”), and the choices you have with respect to your
personal information. 

We may update this Privacy Policy from time to time.  We will notify you of
changes by posting the new Privacy Policy on this page and changing the “Last
Updated” date at the top of this page.  In some cases, such as where required by
law, we may notify you about updates by sending you an email, posting a notice
on the Site about the update, or using other reasonable means to contact you. 
In all cases, your continued use of the Services following posting of any
changes constitutes your acceptance of such changes.  We encourage you to review
this Privacy Policy periodically for any updates.

COLLECTION OF PERSONAL INFORMATION

The table below describes the categories of personal information (with
non-exhaustive examples) that we may collect about you:

Categories Examples A. Individual Identifiers

Contact information, such as first and last name, email address, phone number,
and mailing address.

Online identifiers, such as Internet Protocol (IP) address, device ID, and other
identifiers.

B. Sensitive Personal Information  Financial information, such as debit or
credit card number or financial account details used for payments. We work with
a third party payment processor who handles debit or credit card payments on our
behalf. D. Audio, Electronic, Visual, or Similar Information Customer service
call recordings, which we may record for training and quality assurance
purposes. E. Commercial Information 

Account information, such as your log-in details, information that you store in
your account, and other details about your use of the Services.

Order history, such as records of services you have purchased from us.

Transaction and billing data, such as payment amounts and payment methods used
to complete transactions.

Preferences, such as any preferences you set in your account and any marketing
or communications preferences.

Survey responses, such as the information you provide in response to our surveys
and questionnaires.

Communications, such as the information associated with your requests or
inquiries, including for support, assistance, or order information, and any
feedback you provide when you communicate with us.

F. Internet or Network Activity

Online activity information, such as the website you visited before browsing to
the Service, pages or screens you viewed, how long you spent on a page or
screen, navigation paths between pages or screens, information about your
activity on a page or screen, access times, and duration of access.

Device information, such as your computer or mobile device operating system type
and version number, wireless carrier, manufacturer and model, browser type,
screen resolution, IP address, unique identifiers, and general location
information such as city, state, or geographic area.

G. Professional Information Professional information, such as company name, job
title, company location, and other details we may collect about your business or
profession.  H. Inferences Drawn from Personal Information Profiles reflecting
preferences, characteristics, predispositions, or behavior, such as the lead
insights we create as part of our Services.

We may obtain personal information about you from a variety of sources,
including the following sources.

Personal Information that You Provide.  We collect the personal information that
you provide to us, such as when you fill in forms on the Site, use the Services,
register for an account, subscribe to our emails, or communicate with us.

Personal Information Collected Automatically.  We, our service providers, and
our advertising partners may automatically log information about you, your
computer, or your mobile device, and your activity over time on our Services and
on other sites and online services, such as the online identifiers, online
activity information, and device information described in the table above.  Like
many online services, we use cookies and similar technologies to facilitate some
of the automatic data collection described above, such as:

 * Cookies, which are text files that websites store on a visitor‘s device to
   uniquely identify the visitor’s browser or to store information or settings
   in the browser for the purpose of helping you navigate between pages
   efficiently, remembering your preferences, remembering the items you place in
   your shopping cart, enabling functionality, helping us understand user
   activity and patterns, and facilitating online advertising. 
 * Web beacons, also known as pixel tags or clear GIFs, which are typically used
   to demonstrate that a webpage or email was accessed or opened, or that
   certain content was viewed or clicked, typically to compile statistics about
   usage of websites and the success of marketing campaigns.

Personal Information from Third Parties.  We may also collect personal
information from third parties, such as our customers and business partners,
service providers, social media networks, advertising partners, publicly
available sources, third-party platforms that our users connect to the Services,
and companies that provide us with personal information to supplement what we
already know about our contacts, customers, and clients or to help us identify
new contacts, customers, or clients.  For example, in order to provide our
Services, we collect business contact information from publicly available online
sources such as business websites, public “yellow pages,” blogs, social media
sites, search engine results, and other locations. We may merge or combine such
personal information with the other types of personal information we collect
about you, including to supplement or update our records, to improve and provide
our Services, and for the other purposes described in this Privacy Policy.  

Referrals.  Users of the Services may have the opportunity to refer colleagues,
friends, or other contacts to us and share their contact information with us. 
Please do not refer someone to us or share their contact information with us
unless you have their permission to do so.

USE OF PERSONAL INFORMATION

We may use personal information for the purposes set forth below and as
otherwise described in this Privacy Policy or at the time of collection.

To Provide Our Products and Services.  We use personal information to provide
our products and services.  For example, we use personal information to:

 * provide and operate the Services and our business;
 * enrich, improve, and supplement our lead generation databases;
 * create, manage, monitor, and maintain your account on the Services;
 * provide you with the products and services you request;
 * monitor and improve your experience on the Site;
 * review and respond to your inquiries and requests;
 * send you updates about your order and store your information for future
   orders;
 * contact you by phone, email, or other form of communication; and
 * process your transactions and monitor your orders.

Research and Development.  We use personal information for research and
development purposes, including to study and improve the Services and our
business, understand and analyze the usage trends and preferences of our users,
and develop new features, functionality, products, and services.  As part of
these activities, we may create aggregated, de-identified, or other anonymous
data from personal information we collect.  We make personal information into
anonymous data by removing information that makes the data personally
identifiable to you.  We may use this anonymous data and share it with third
parties for our lawful business purposes.

Direct Marketing.  We may send you LeadGenius-related or other direct marketing
communications as permitted by law.  You may opt-out of our marketing
communications as described in the “Your Choices” section below. 

Interest-Based Advertising.  We work with third-party advertising companies and
social media companies to help us advertise our business and to display ads for
our products and services.  These companies may use cookies and similar
technologies to collect information about you (including the online activity
information and device information described above in the section called
“Personal Information Collected Automatically”) over time across our Services
and other sites and services or your interaction with our emails, and use that
information to serve ads that they think will interest you.  In addition, some
of these companies may use hashed customer lists that we share with them to
deliver ads to you and to similar users on their platforms.  You can learn more
about your choices for limiting interest-based advertising in the “Your Choices”
section below. 

To Comply with Laws and Regulations.  We will use personal information as we
believe necessary or appropriate to comply with applicable laws, lawful
requests, and legal process, such as to respond to subpoenas or requests from
government authorities.

For Compliance, Fraud Prevention, and Safety.  We may use personal information
and disclose it to law enforcement, government authorities, and private parties
as we believe necessary or appropriate to: (a) maintain the safety, security,
and integrity of the Services and our products and services, business,
databases, and other technology assets; (b) protect our, your, or others’
rights, privacy, safety or property (including by making and defending legal
claims); (c) audit our internal processes for compliance with legal and
contractual requirements and internal policies; (d) enforce the terms and
conditions that govern the Services; and (e) prevent, identify, investigate and
deter fraudulent, harmful, unauthorized, unethical or illegal activity,
including cyberattacks and identity theft.

With Your Consent.  In some cases we may specifically ask you for your consent
to collect, use, or share your personal information, such as when required by
law. 

SHARING OF PERSONAL INFORMATION

We may share personal information with the entities and individuals listed below
or as otherwise described in this Privacy Policy or at the point of collection.

Related Companies.  We may share personal information with our affiliates,
subsidiaries, and other related companies.  

Customers and Business Partners.  As part of our Services, we share personal
information we have collected with our customers and business partners for lead
generation, marketing, and sales purposes.  

Service Providers.  We share personal information with third parties and
individuals who perform functions on our behalf and help us run our business.
For example, we work with service providers that help us perform website
hosting, maintenance, database management, cloud storage, web analytics,
billing, email services, payment processing, marketing, advertising, and other
purposes. 

Advertising Partners.  We may also share personal information with third parties
who we partner with for advertising campaigns or that collect information about
your activity on the Services for the purposes described in the “Interest-Based
Advertising” section above.

Law Enforcement, Authorities, and Others.  Under certain circumstances,
LeadGenius may be required to disclose personal information to law enforcement,
government authorities, and other parties if required to do so by law or in
response to valid requests by public authorities (e.g. a court or a government
agency).  LeadGenius may also disclose personal information in the good faith
belief that such action is necessary to comply with a legal obligation or for
the purposes described above in the section titled “Compliance, Fraud
Prevention, and Safety.”

Professional Advisors.  We may share personal information with persons,
companies, or professional firms providing LeadGenius with advice and consulting
in accounting, administrative, legal, tax, financial, debt collection, and other
matters. 

Business Transaction Participants.  We may disclose personal information to
third parties in connection with any business transaction (or potential
transaction) involving a merger, acquisition, sale of shares or assets,
financing, acquisition, consolidation, reorganization, divestiture, or
dissolution of all or a portion of our business (including in connection with a
bankruptcy or similar proceedings).

TRANSFER OF PERSONAL INFORMATION

LeadGenius is headquartered in the United States and we have service providers
in the United States and other countries.  Your personal information may be
collected, used, and stored in these countries or other locations outside of
your home country.  Privacy laws in the locations where we handle your personal
information may not be as protective as the privacy laws in your home country. 
By providing your personal information, where applicable law permits, you hereby
specifically and expressly consent to such transfer and processing and the
collection, use, and disclosure set forth herein or in any applicable terms of
service.

Users in Europe can view more information about cross-border transfers in the
section below titled “Notice to European Users.”

SECURITY

The security of your personal information is important to us, but remember that
no method of transmission over the Internet, or method of electronic storage is
100% secure.  While we strive to use commercially acceptable means to protect
your information, we cannot guarantee its absolute security.

YOUR CHOICES

In this section, we describe the rights and choices available to individuals. 
California residents should review the section below titled “Your California
Privacy Rights” for additional information specific to  

Access, Modify, or Delete Your Account Information.  You may access, modify, or
remove certain information saved in your account by logging into your account
and updating or correcting your profile information.  You may also submit a
request by emailing us at privacy@leadgenius.com.

Opt-Out of Promotional Email Communications.  You may opt out of
marketing-related emails by following the opt-out or unsubscribe instructions at
the bottom of the email, or by contacting us using the contact information at
the bottom of this Privacy Policy.  You may continue to receive service-related
and other non-marketing emails. 

Opt-Out of Text Messages.  We may offer communications via SMS texts or similar
technology sent by LeadGenius or our service providers, such as when we send you
text messages for customer service, account-related, or marketing purposes. 
Message and data rates may apply for these services.  You can opt-out of texts
by following the instructions for the applicable texting program you enroll in
or by emailing us your request and mobile telephone number to
optout@leadgenius.com.

Third Party Platforms.  If you connect the Services with a third party service,
application, or other platform, you may have the ability to limit the
information that we obtain from the third party through your account settings
with the third party platform.  Please note, if you withdraw our ability to
access certain information from a third party platform, that choice will not
apply to information that we have already received from that third party.

Cookies.  Most browsers let you remove and/or stop accepting cookies from the
websites you visit. To do this, follow the instructions in your browser’s
settings.  Many browsers accept cookies by default until you change your
settings.  If you do not accept cookies, however, you may not be able to use all
functionality of the Services and our Site may not work properly.  For more
information about cookies, including how to see what cookies have been set on
your browser and how to manage and delete them, visit www.allaboutcookies.org. 

Analytics.  The Site uses Google Analytics to help us analyze how the Site is
being accessed and used. You can learn more about Google Analytics cookies by
clicking here and about how Google protects your data by clicking here.  To
opt-out of Google Analytics, you can download and install the Google Analytics
Opt-out Browser Add-on, available here. 

Advertising Choices.  You can limit the use of your information for
interest-based advertising by blocking third-party cookies in your browser
settings, using browser plug-ins/extensions, and/or using your mobile device
settings to limit the use of the advertising ID associated with your mobile
device.  You can also opt out of interest-based ads from companies participating
in the following industry opt-out programs by visiting the linked websites: the
Network Advertising Initiative
(http://www.networkadvertising.org/managing/opt_out.asp) and the Digital
Advertising Alliance (optout.aboutads.info).  Some of the companies we work with
may offer their own opt-out mechanisms, such as Facebook and Google.  You can
learn more about how Google uses cookies for advertising purposes by clicking
here and opt-out of ad personalization by Google by clicking here.  You can
learn more about Facebook’s privacy practices and manage your Facebook ad
preferences by clicking here.

Many of the opt-out preferences described in this section must be set on each
device and/or browser for which you want them to apply.  Please note that some
of the advertising companies we work with may not participate in the opt-out
mechanisms described above, so even after opting-out, you may still receive
interest-based ads from other companies.  If you opt-out of interest-based
advertisements, you will still see advertisements online but they may be less
relevant to you.

Do Not Track.  Some browsers may be configured to send “Do Not Track” signals to
the online services that you visit. We currently do not respond to “Do Not
Track” or similar signals.  To find out more about “Do Not Track,” please visit
http://www.allaboutdnt.com.

Declining to Provide Information.  We need to collect personal information to
provide certain services. If you do not provide the information requested, we
may not be able to provide those services.

CHILDREN

The Services are not intended for use by anyone under the age of 16, and we do
not knowingly collect personal information from children.  If you are a parent
or guardian and you are aware that your child has provided us with personal
information online, please contact us.  If we become aware that we have
collected personal information from children without verification of parental
consent as required by law, we take steps to remove that information from our
servers.

LINKS TO OTHER WEBSITES AND SERVICES

The Services may contain links to other websites and online services that are
not operated by us.  These links are not an endorsement of, or representation
that we are affiliated with, any third party.  If you click on a third party
link, you will be directed to that third party’s site or service.  In addition,
our content may be included on web pages or online services that are not
associated with us.  We have no control over and assume no responsibility for
the content, privacy policies or practices of any third party sites or
services.  Other websites and services follow different rules regarding the
collection, use and sharing of your personal information.  We encourage you to
review the privacy policies of other websites and other online services that you
visit or use.

NOTICE TO CALIFORNIA RESIDENTS: YOUR CALIFORNIA PRIVACY RIGHTS

This section applies only to California residents. It describes how we collect,
use, and share personal information of California residents when we act as a
“business” as defined under California privacy laws, and their rights with
respect to their personal information.  For purposes of this section, “personal
information” has the meaning given under California privacy laws but does not
include information exempted from the scope of such laws.  In some cases we may
provide a different privacy notice to certain categories of California
residents, in which case that notice will apply instead of this section.

Personal Information That We Collect, Use, and Disclose.  We describe:

 * the categories of personal information we may have collected about you in the
   preceding 12 months, and the categories of sources from which we collect such
   personal information, in the section above called “Collection of Personal
   Information;”
 * the business and commercial purposes for which we collect this information in
   the section above called “Use of Personal Information;” and
 * the categories of third parties to whom we disclose this information in the
   section above called “Sharing of Personal Information.”

Personal Information Disclosed for a “Business Purpose” or “Valuable
Consideration.”  LeadGenius must also disclose whether the following categories
of personal information are disclosed for a “business purpose” or “valuable
consideration” as those terms are defined under California privacy law.  This
latter category is also called a “sale” of personal information. 

LeadGenius has disclosed each of the categories listed in the section above
titled “Collection of Personal Information” for the business purposes set forth
in this Privacy Policy.  LeadGenius has “sold” the following categories of
personal information: 

 * Individual Identifiers
 * Internet or Network Activity
 * Professional Information

Your Rights as a California Resident.  California privacy law provides
California residents with the rights listed below.  Please note, these rights
are not absolute and in some cases we may not be able to respond to your
request, such as when a legal exemption applies or if we are not able to verify
your identity.

 * Right to Access. You have the right to request that LeadGenius disclose
   certain information to you about our collection and use of your personal
   information over the past 12 months, including:
   * The categories of personal information we collected about you.
   * The categories of sources of the personal information we collected about
     you.
   * Our business or commercial purpose for collecting or selling that personal
     information.
   * The categories of third parties with whom we share that personal
     information.
   * The specific pieces of personal information we collected about you.
 * Right to Erase/Delete.  You have the right to request that LeadGenius delete
   any of your personal information that we have collected from you and
   retained, subject to certain exceptions.
 * Right to Opt-Out of Sales.  If we “sell” your personal information according
   to California law, you can opt-out.  In addition, if you direct us not to
   sell your personal information, we will consider it a request pursuant to
   California’s “Shine the Light” law to stop sharing your personal information
   covered by that law with third parties for their direct marketing purposes.
 * Right to Nondiscrimination.  You are entitled to exercise the rights
   described above free from discrimination in the form or legally prohibited
   increases in the price or decreases in the quality of our products and
   services.  

How to Exercise Your California Privacy Rights.  Requests to exercise your
California privacy rights may be submitted using the methods below:

 * Access or Deletion.  You can request the access or deletion rights described
   above by: 

 * Emailing us at optout@leadgenius.com, or
 * Sending us a request via mail at Mobileworks, dba Leadgenius, 548 Market
   Street, PMB 32809, San Francisco, CA 94104-5401.

 * Opt-Out of “Sales.”  You can opt-out of the “sale” of your personal
   information by: 
   * Emailing us at optout@leadgenius.com, or 
   * Clicking here: Do Not Sell My Personal Information.

When exercising your rights or otherwise assisting you, we may need to request
specific information from you to help us confirm your identity.  This is a
security measure to ensure we do not disclose personal information to any person
who is not entitled to receive it.  We may also contact you to ask you for
further information in relation to your request to speed up our response.  

You may also designate an authorized agent to make a request on your behalf.  If
you do so, we may require the requester’s proof of identification, the
authorized agent’s proof of identification, and any other information that we
may request in order to verify your request, including evidence of valid
permission for the authorized agent to act on your behalf.

You will not have to pay a fee to access your personal information (or to
exercise any of the other rights).  However, we may charge a reasonable fee or
decline to comply with your request if your request is clearly unfounded,
repetitive, or excessive.

We try to respond to all legitimate requests within 45 days of your request. 
Occasionally it may take us longer than 45 days to respond, for instance if your
request is particularly complex or you have made a number of requests.  In this
case, we will notify you of the delay, and may continue to update you regarding
the progress of our response.

NOTICE TO EUROPEAN USERS

The information provided in this section applies only to individuals in the
European Economic Area and the United Kingdom (collectively, “Europe”).  Except
as otherwise specified, references to “personal information” in this Privacy
Policy are equivalent to “personal data” governed by European data protection
legislation. 

Controller.  The controller of your personal information covered by this Privacy
Policy for purposes of European data protection legislation is MobileWorks, Inc.
dba LeadGenius, 548 Market Street, PMB 32809, San Francisco, CA 94104-5401, USA.

Legal Bases for Processing.  The legal bases of our processing of your personal
information as described in this Privacy Policy will depend on the type of
personal information and the specific context in which we process it.  However,
the legal bases we typically rely on are set out in the table below.  We rely on
our legitimate interests as our legal basis only where those interests are not
overridden by the impact on you (unless we have your consent or our processing
is otherwise required or permitted by law).  If you have questions about the
legal basis of how we process your personal information, contact us at
privacy@leadgenius.com.

Processing Purpose (as described above in the “Use of Personal Information”
section) Legal Basis To Provide our Products and Services Processing is
necessary to perform the contract governing our operation of the Services, or to
take steps that you request prior to engaging our services. Where we cannot
process your personal data as required to operate the Services on the grounds of
contractual necessity, we process your personal information for this purpose
based on our legitimate interests as further described in this Privacy Policy. 
Research and Development Processing is based on our legitimate interests in
performing research and development as described in this Privacy Policy. Direct
Marketing

Processing is based on your consent where that consent is required by applicable
law. Where we rely on your consent you have the right to withdraw it any time in
the manner indicated when you consented or in the Services. 

Where such consent is not required by applicable law, we process your personal
information for this purpose based on our legitimate interests in promoting our
business and providing you with tailored, relevant content.

Interest-Based Advertising To Comply with Laws and Regulations Processing is
necessary to comply with our legal obligations. For Compliance, Fraud
Prevention, and Safety Processing is necessary to comply with our legal
obligations or based on our legitimate interests in protecting our or others’
rights, privacy, safety, or property. With Your Consent Processing is based on
your consent. Where we rely on your consent you have the right to withdraw it
any time in the manner indicated when you consent or in the Services. 

Use for New Purposes. We may use your personal information for reasons not
described in this Privacy Policy where permitted by law and the reason is
compatible with the purpose for which we collected it. If we need to use your
personal information for an unrelated purpose, we will notify you and explain
the applicable legal basis. 

Retention. We will retain your personal information for as long as necessary to
fulfill the purpose of collection, including for the purposes of satisfying any
legal, accounting, or reporting requirements, to establish and defend legal
claims, for fraud prevention purposes, or as long as required to meet our legal
obligations. To determine the appropriate retention period for personal
information, we consider the amount, nature, and sensitivity of the personal
information, the potential risk of harm from unauthorized use or disclosure of
your personal information, the purposes for which we process your personal
information and whether we can achieve those purposes through other means, and
the applicable legal requirements.

Your Rights. European data protection laws may give you certain rights regarding
your personal information. You may ask us to take the following actions in
relation to your personal information that we hold:

 * Access. Provide you with information about our processing of your personal
   information and give you access to your personal information.
 * Correct. Update or correct inaccuracies in your personal information.
 * Delete. Delete your personal information.
 * Port. Transfer a machine-readable copy of your personal information to you or
   a third party of your choice.
 * Restrict. Restrict the processing of your personal information.
 * Object. Object to our reliance on our legitimate interests as the basis of
   our processing of your personal information that impacts your rights. 

You may submit these requests by contacting us at the contact information listed
below. We may request specific information from you to help us confirm your
identity and process your request. Applicable law may require or permit us to
decline your request. If we decline your request, we will tell you why, subject
to legal restrictions. If you would like to submit a complaint about our use of
your personal information or our response to your requests regarding your
personal information, you may contact us or submit a complaint to the data
protection regulator in your jurisdiction. In the European Economic Area, you
can find your data protection regulator here. In the United Kingdom, you can
find your data protection regulator here.

Cross-Border Data Transfer. If we transfer your personal information to a
country outside of Europe such that we are required to apply additional
safeguards to your personal information under European data protection laws, we
will do so. Please contact us using the information below for further
information about any such transfers or the specific safeguards applied.

CONTACT US

If you have any questions, comments, or concerns about this Privacy Policy or
our privacy practices, please contact us at privacy@leadgenius.com or write to
us at the address below:

MobileWorks, Inc. dba LeadGenius
Attn: Privacy Policy
548 Market Street, PMB 32809
San Francisco, CA 94104-5401



HAVE ANY QUESTIONS?

Please feel free to contact us if you have any questions about LeadGenius’s
Privacy Policy or the information practices of the Services.

Contact Us


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