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PRIVACY POLICY

Effective Date:  3/22/23

‍

Welcome to Emporia, a platform connecting Respondents to Clients seeking their
insight. The Emporia website and interactive properties through which the
service is delivered (collectively, the “Service”) are owned, operated, and
distributed by Emporia Learning Inc., a Delaware corporation (referred to in
this Privacy Policy as “Emporia” or in possessive use, such as through “we,”
“us,” “our,” etc.). At Emporia, we respect and value the privacy of our others.
This Privacy Policy describes how personal information is collected, used,
shared and safeguarded when you access the Service. Please read this Privacy
Policy carefully. By using the Service, you consent to the collection and use of
your information by us as set out in this Privacy Policy. IF YOU DO NOT AGREE
WITH THE TERMS OF THIS PRIVACY POLICY, YOU ARE NOT PERMITTED TO USE OR ACCESS
THE SERVICE.

‍

PERSONAL INFORMATION WE COLLECT

When you create an account or make a purchase on or through the Service, we may
ask you for certain personal information about you, which may include your name,
telephone number, postal address and email address. When you visit the Service,
we may automatically collect certain information about your device, including
information about your web browser, IP address, time zone, and some of the
cookies that are installed on your device. Additionally, as you browse the
Service, we may collect information about the individual pages or features that
you view, what websites or search terms referred you to the Service, and
information about how you interact with the Service. We refer to this
automatically-collected information as "Device Information."

‍

We may collect Device Information using the following technologies:

 * "Cookies" are data files that are placed on your device or computer and often
   include an anonymous unique identifier. For more information about cookies,
   and how to disable cookies, visit http://www.allaboutcookies.org.
 * "Log files" track actions occurring on the Service, and collect data
   including your IP address, browser type, Internet service provider,
   referring/exit pages, and date/time stamps.
 * "Web beacons", "tags", and "pixels" are electronic files used to record
   information about how you browse the Service.

You are under no obligation to provide us with personal information of any kind,
however your refusal to do so may prevent you from using certain features of the
Service. You may not send us any sensitive personal information (e.g., social
security number, information related to racial or ethnic origin, political
opinions, religion or other beliefs, health, biometrics or genetic
characteristics, criminal background or trade union membership) on or through
the Service or otherwise.

‍

HOW DO WE USE YOUR PERSONAL INFORMATION?

We and our service providers use personal information for our legitimate
business purposes, including those specifically described below. We engage in
these activities to manage our contractual relationship with you (including
providing products and services to you), to comply with a legal obligation
and/or because we have a legitimate business interest. We use the Device
Information that we collect to help us screen for potential risk and fraud (in
particular, your IP address), and more generally to improve and optimize the
Service (for example, by generating analytics about how our visitors browse and
interact with the Service).

‍

SHARING YOUR PERSONAL INFORMATION

We may share your personal information with third parties to help us use your
personal information, as described above. With your consent, we may share your
personal information with third parties for marketing purposes, as permitted by
law. We may share your personal information with our affiliates, in which case
we will require those affiliates to honor this Privacy Policy. Affiliates may
include a parent company and any subsidiaries, joint venture partners or other
companies that we control or that are under common control with us. We may share
your personal information with advertisers and actual and potential investors
for the purpose of conducting general business analysis. If we reorganize or
sell all or a portion of our assets, undergo a merger or are acquired by another
entity, we may transfer your personal information to the successor entity. If we
go out of business or enter bankruptcy, your personal information would be an
asset transferred or acquired by a third party. You acknowledge that such
transfers may occur and that the transferee may decline to honor commitments we
made in this Privacy Policy. Finally, we may also share your personal
information to comply with applicable laws and regulations, to respond to a
subpoena, search warrant or other lawful request for information we receive, or
to otherwise protect our rights.

‍

DO NOT TRACK

Most web browsers and some mobile operating systems include a Do-Not-Track
("DNT") feature or setting you can activate to signal your privacy preference
not to have data about your online browsing activities monitored and collected.
No uniform technology standard for recognizing and implementing DNT signals has
been finalized. As such, we do not currently respond to DNT browser signals or
any other mechanism that automatically communicates your choice not to be
tracked online. If a standard for online tracking is adopted that we must follow
in the future, we will revise this Privacy Policy accordingly.

‍

JURISDICTION AND CROSS-BORDER TRANSFER

Your personal information may be stored and processed in any country where we
have facilities or in which we engage service providers, and by using the
Service you consent to the transfer of information to countries outside of your
country of residence, including the United States, which may have data
protection rules that are different from those of your country. In certain
circumstances, courts, law enforcement agencies, regulatory agencies or security
authorities in those other countries may be entitled to access your personal
information.

‍

OPTIONS REGARDING YOUR PERSONAL INFORMATION

If you have an account on the Service, you may at any time review or change the
information in your account or terminate your account by emailing us at
support@emporiaapp.com or by updating your account information directly in the
Service. Upon your request to terminate your account, we will deactivate or
delete your account and personal information from our active databases. However,
some information may be retained in our files to prevent fraud, troubleshoot
problems, assist with any investigations, enforce our Terms of Service and/or
comply with legal requirements.

‍

EMAILS AND OTHER COMMUNICATIONS

If you no longer wish to receive correspondence, emails or other communications
from us, you may opt-out by emailing us at support@emporiaapp.com or by updating
your account settings page, or deleting your account, on the Service. If you no
longer wish to receive correspondence, emails or other communications from a
third party, you are responsible for contacting the third party directly.

‍

DATA RETENTION

We will retain your personal information for as long as needed or permitted in
light of the purpose(s) for which it was obtained. The criteria used to
determine our retention periods include the length of time we have an ongoing
relationship with you, when we have a legal obligation to which we are subject
or as advisable in light of legal requirements.

‍

THIRD PARTY WEBSITES

The Service may contain links to third party websites and applications of
interest, including advertisements and external services, that are not
affiliated with us. Once you have used these links to leave the Service, any
information you provide to these third parties is not covered by this Privacy
Policy, and we cannot protect the safety and privacy of information that you
provide to a third party outside of the Service. Before visiting and providing
any information to any third party websites or applications, you should inform
yourself of the privacy policies and practices (if any) of the third party
responsible for that website or application, and should take those steps
necessary, in your discretion, to protect the privacy of your information. We
are not responsible for the content or privacy and security practices and
policies of any third parties, including other sites, services or applications
that may be linked to or from the Service.

‍

SECURITY OF YOUR INFORMATION

We use administrative, technical and physical security measures to help protect
your personal information. While we have taken reasonable steps to secure the
personal information you provide to us, please be aware that despite our efforts
no security measures are perfect or impenetrable and no method of data
transmission can be guaranteed against any interception or other type of misuse.
Any information disclosed online is vulnerable to interception and misuse by
unauthorized parties. Therefore, we cannot guarantee complete security if you
provide personal information to us.

‍

CHANGES

We reserve the right to make changes to this Privacy Policy at any time and for
any reason. We will alert you about any changes by updating the "Effective Date"
at the top of this Privacy Policy. Any changes or modifications will be
effective immediately upon posting the updated Privacy Policy on the Service,
and you waive the right to receive specific notice of each such change or
modification. You are encouraged to periodically review this Privacy Policy to
stay informed of updates. You will be deemed to have been made aware of, will be
subject to, and will be deemed to have accepted the changes in any revised
Privacy Policy by your continued use of the Service after the date such revised
Privacy Policy is posted.

‍

MINORS

The Service is not intended for individuals under 18 years of age. We do not
knowingly collect information from or market to individuals under 18 years of
age. If you become aware of any data we have collected from individuals under 18
years of age, please contact us using the contact information provided below.

‍

‍

CONTACT US

For more information about our privacy practices, if you have questions, or if
you would like to make a complaint, please contact us by e-mail at

support@emporiaapp.com or by mail at Emporia Learning Inc., 40 W. 25th St. Floor
9, New York, NY 10010

‍

‍

‍

Collectible Data

Emporia collects information by asking directly and by collecting information
from and about the equipment you use when you access the Service. We also
collect information about the selections and choices you make by examining the
way a user interacts with Emporia.

‍

Your Acknowledgments

By using our Services, you agree to the terms and conditions of this Privacy
Policy and our Terms of Service. You also agree that you assume all risks
regarding your use of the Services, transmissions made over the Internet
generally, and your sharing of your Personal or Other Information.

‍

By using our Services, you grant us and all other persons or entities involved
in the operation of our Services the right to receive, transmit, monitor,
retrieve, store and use your Personal or Other Information, including
information that may be privileged or confidential under applicable laws, in
connection with the operation of our Services and our maintenance of your
Personal or Other Information, as described in this Privacy Policy.

‍

Types of Data

 * Contact Information

Emporia collects your name and email address (including but not limited to a
hashed email address, Facebook identifier, Apple identifier) when you register
for an account, update or change information for your account and when you sign
up for email updates.

 * Location

Emporia collects the approximate geographic location information (lower
resolution than a latitude and longitude with three or more decimal places). We
gather this information to give you more information about class or attendee
locations. We may ask you to provide the information or we may use GPS or IP
addresses. Location information is not only convenient for you, it may also be a
security feature if, for example, it flags a sign in from a country in which you
did not originally register your account.

 * Identifiers

In addition to the information that you provide when you register, Emporia
collects certain information automatically. Emporia collects user identification
information such as your mobile device’s unique device ID, screen names,
handles, account IDs, assigned user IDs, customer numbers, your mobile device’s
IP address, your mobile device operating system, or other user-or account-level
or device information that can be used to identify a particular user or account
or device.

‍

Data Use

Emporia may use gathered data through partnering with third parties to collect
and analyze, which may be used in a variety of manners.

‍

Sensitive Information

Personal or Other Information related to your racial or ethnic origin, political
opinions, religion or other beliefs, health or sex life, criminal background or
trade union membership, and other similar information may be considered
“Sensitive Information” under certain applicable law. We sometimes collect
Sensitive Information when you create an account in the Services. For example,
if you are a Participant, we may request that you provide information about your
ethnicity. By entering such information, you consent and agree that we may use
such information in accordance with this Policy.

‍

If you are a Participant, please do not submit Sensitive Information to or
through the Services in response to any question or request from a Researcher.

‍

If you are a Researcher-Affiliated Participant, your applicable Researcher may
ask you screener questions that involve Sensitive Information. The applicable
Researcher is the controller of that information and we do not use it for our
own purposes other than to provide the Services to the applicable Researcher as
described in this Policy.

‍

Future Data Access

 * Financial Information: at present we use a payment service which means that
   we do not currently collect, process or access your payment information. In
   the future we may choose to process payment information and if so we may
   collect data such as the form of payment, payment card information or bank
   account information;
 * Precise Location Data: in the future we may collect information that more
   precisely describes the location of a user or device with more precision
   (such as a latitude and longitude with three or more decimal places.);
 * *Browsing History-** in the future we may collect information about content
   you view when you are not using the Service to personalize your experience,
   expand our product offerings or for third-party ads for products and
   services;
 * *Other Identifiers-** in the future we may use information concerning your
   device, such as the device’s advertising identifier or other device-level
   identifications for marketing purposes such as third party ads;
 * Purchase History-* in the future we may collect information about your
   purchase history or purchase tendencies to refine our product offerings or to
   display third party ads in our Service or to share data with third party
   entities that display third-party ads; or
 * Provide Our Advertising, Promotional or Marketing Information; by displaying
   our own (first-party) ads, sending marketing communications directly to you,
   or by sharing data with trusted entities (second party ads) that will cause
   our ads to be displayed in the Service.

Data Usage

 * Emporia may disclose your data with trusted third parties such as AWS
   analytics tools, service vendors and maintenance contractors to improve our
   product and service. Access to your personal data is limited to the
   information reasonably necessary to perform work for Emporia and all such
   service providers must also utilize sound privacy policies.
 * Emporia may disclose your data to third parties where: a)- a state, federal,
   local or international law or regulation requires such disclosure; b)- the
   disclosure is required by a subpoena court order or legal process; c)-the
   disclosure is reasonably needed to prevent a crime or actual or threatened
   injury to the safety, property or privacy interests of Emporia or its users;
   d)-the disclosure is pursuant to the Emporia Terms of Use.
 * Emporia may provide access to your data to a third party for purposes of a
   sale, merger, capital infusion, loan, or reorganization of the business or
   assets of Emporia.
 * Emporia may disclose your name and email with community creators of
   communities you have joined for purposes of contact outside of Emporia.

Data Retention

Emporia will retain your personal data only for so long as is necessary for the
purposes for which it was collected, unless: a)- a longer or shorter time is
required by applicable law; b)- you request that the data be deleted earlier.
Once we delete your data you will not be able to exercise the right to access,
the right to erasure, the right to rectification or the right to data
portability. In addition, Emporia may delete your personal information if you
have not used or accessed the app within twelve (12) months.

‍

Request to Delete User Data

Subject to certain exceptions set forth below, you may at any time contact our
customer support at support@emporiaapp.com to request that your personal data be
deleted.

‍

Please note that we may not be able to comply with a request to delete your
personal information if it is necessary to:

 * Provide the service to you;
 * Detect or prevent fraud, illegal, malicious or dangerous behavior or security
   incidents; or to preserve information necessary to prosecute fraudulent,
   illegal or malicious conduct;
 * Comply with the California Electronic Communications Privacy Act; or
 * Comply with an existing legal obligation.

California Law (Shine the Light; CCPA)

 * California law (Shine the Light) provides that California residents who
   provide personal information to obtain services or products for personal,
   family or household use may, once a year, request and obtain information from
   us about what customer information we shared with other businesses for their
   direct marketing uses during the immediate prior calendar year. If you are a
   California resident and you wish to obtain this information, you may contact
   support@emporiaapp.com.
 * The California Consumer Privacy Act (CCPA) provides that California residents
   have the right to know what personal data was collected, what their opt out
   rights are in connection with the collection and sale of their personal data
   and, subject to certain limitations and restrictions, they have the right to
   request that certain data that was collected be deleted. These rights may be
   exercised without fear of discrimination. If you are a California resident
   and you want to exercise your rights under the CCPA, you may contact
   support@emporiaapp.com.

‍

Virginia Law (Virginia Consumer Data Protection Act, CDPA)

‍

Virginia law provides that Virginia residents have the right to access, correct,
delete, and obtain a copy of their personal data, and to opt-out of the
processing of their personal data for direct marketing. If you are a Virginia
resident and you wish to exercise your rights under the CDPA, you may contact
support@emporiaresearch.com.

‍

Connecticut Law (Connecticut Data Protection Act, CTDPA)

‍
Connecticut law, under the Connecticut Data Protection Act, grants residents the
right to access their data or have it deleted. The law is designed to enforce
certain minimum transparency standards from businesses, among other mandates 1 .
If you are a Connecticut resident and you wish to exercise your rights under the
CTDPA, you may contact support@emporiaresearch.com.

‍

Colorado Law (Colorado Privacy Act, CPA)

‍
Colorado law, through the Colorado Privacy Act, allows residents to opt-out of
data collection on websites, and requires companies to clarify what data they
collect, its usage, and retention period. It grants rights to access, delete,
and correct personal data as well as to opt-out of the sale of personal data 2 .
If you are a Colorado resident and you wish to exercise your rights under the
CPA, you may contact support@emporiaresearch.com.

‍

Utah Law (Utah Consumer Privacy Act, UCPA)

‍
Utah law, under the Utah Consumer Privacy Act, stipulates that consumers should
have a reasonably accessible and clear privacy notice which includes categories
of personal data processed, the purposes for processing, and how consumers can
exercise the rights granted by the UCPA . If you are a Utah resident and you
wish to exercise your rights under the UCPA, you may contact
support@emporiaresearch.com.

‍

GDPR

For information on opting out of data collection or details on GDPR please
contact support@emporiaapp.com. For general information on GDPR please visit
https://gdpr-info.eu/

‍

Children’s Privacy (COPPA)

Emporia does not knowingly collect data or information from children under the
age of 13.  The Emporia Service is not intended to be used by anyone under the
age of 13. Use or access of the Service by anyone under the age of 13 is
strictly forbidden. If you are under the age of 13 do not use or access this
Service.

‍

Data Security

Emporia will take reasonable and appropriate measures to protect personal data
from loss, misuse and unauthorized access. Data is encrypted and secured using
AWS industry standards.

Emporia Learning Inc. reserves all rights not expressly granted herein.




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