Privacy Policy

Jurisdiction-Specific Notices: If you are a California or Virginia resident, see the Jurisdiction SpecificPrivacy Rights Statement for important information about your rights under California or Virginia lawand to see the categories of information we collect and the purposes for which the information is used,or to exercise your rights under the laws applicable in these states. If you are located in the EuropeanEconomic Area, UK, or Switzerland, please also see the Supplemental European Privacy Statement.

Protecting your privacy is fundamental to the way Intelliterran Inc. dba Comment Compass, including itssubsidiaries and affiliated entities under common ownership and control, (“Company”, “we”, “us”, or“our”) conduct business and provide our services. This Privacy Policy describes our collection, use anddisclosure of the information we may collect from you whenever you visit any of our digital properties,website(s), including www.commentcompass.com (hereinafter a “Site” and collectively the “Sites”), orotherwise interact with us or access any of our application, products, services, and content (hereinafterthe “Platform”). The Sites and the Platform are together referred to in this Privacy Policy as the“Services”.

This Privacy Policy applies to all visitors and customers accessing the Services. If you become an inactivecustomer, or if we close or suspend your account, we will continue to adhere to the Privacy Policy inplace when we collect your personal information as long as we retain it in our databases. We may deleteany or all of your information at any time without notice to you or for any reason or no reason unless weare otherwise required by law or retain it. You may have other privacy protections under state laws andwe encourage you to refer to the Jurisdiction Specific Privacy Rights Statement to review these. Unlessotherwise specifically noted, this Policy does not apply to your use of third-party sites linked to in theServices.

Updates and Supplemental Notices to this Privacy PolicyWe may provide additional or supplemental privacy notices for specific products or services that we offerat the time of collection. Unless otherwise noted, those supplemental notices should be read togetherwith this Privacy Policy.

This Privacy Policy may change from time to time. The “Effective Date” legend at the top of this pageindicates when this Privacy Policy was last revised. Any chances will become effective when we post therevised Privacy Policy and your continued access to the Services is deemed to be your acceptance ofthose changes, so we encourage you to check back periodically for updates.

Sections

This Privacy Policy is comprised of the following sections:

Personal Information We Collect and Purpose of Collection
Why We Collect Personal Information
Disclosure of Personal Information
Data Security
Retention of Personal Information
Other Important Information
Privacy Rights and Choices
Contact Information
Other Jurisdictions

1. Personal Information We Collect and Purpose of Collection

We collect personal information when you access and interact with our Services or provide informationby contacting us via our Services, through a website chat feature, or when you make a comment orrequest in relation to our products and services. In addition to the information that we collect from youdirectly, we may also receive information about you from other sources, including third parties, businesspartners, our affiliates, or publicly available sources. This information may be provided by you voluntarilyor automatically as part of your interaction with our Services. Detailed information about the personalinformation we collect, and why we collect it is provided in the chart below:

2. Why We Collect Personal Information

We may collect the categories of personal information listed below. We use this information for one ormore of the following “business purposes”

Customer Service and Support - to provide customer service and support, maintain, and serviceproducts and accounts, provide training for quality assurance purposes, and perform similaractivities.
Respond to Inquiries – to respond to your inquiries and provide you with requested services orresolve any issues you may have with our Services.
Administration of Our Services – to send you details about our Services, update you aboutchanges to our terms and policies, and other similar information
Advertising & Marketing – to send advertisements and marketing material via physical andelectronic mail relating to product specials and other promotional events or offers, performmarketing research and data analytics, and perform similar activities.
Counting Ad Impressions & Website Interactions – to audit interactions with our websites,applications, or advertisements, count ad impressions to unique visitors, verify position andquality of ad impressions, and perform similar activities to determine how to provide marketingand promotional campaigns that are most relevant to our customers.
Identify Usage Trends – to better understand how our Services are being used so we canimprove them.
Request Feedback – to contact you and get your feedback about your use of the Services.
User-to-User Communication – if you choose, to allow for communications with another use ofour Services.
Fraud Prevention – to help ensure security and integrity, such as necessary to detect securityincidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to prosecutethose responsible for that activity.
Processing Transactions – to process or fulfill orders and transactions, verify customerinformation, process payments.
Protect Individual Interests – to save or protect an individual’s vital interest, such as to preventharm.
Compliance with Legal Obligations – To comply with our legal and contractual obligations and toprotect our legal interests, such as in the event of a complaint or dispute.

3. Disclosure of Personal Information

In addition to the specific situations discussed elsewhere in this policy, we may disclose personalinformation we collect from you:

if we believe disclosure is necessary or appropriate to protect the rights, property or safety of us,our clients or others;
to our authorized service providers such as our contractors and other third parties we use tosupport our business and fulfill the purposes set forth above (including, in some cases chatfunctionality providers);
to fulfill the purpose for which you provide it;
to other Company-owned business entities for the purposes of coordinating our provision anddevelopment of products and services;
and a buyer or other successor in the event of a sale, merger, reorganization or transfer of someor all of our business or assets;
to our business and marketing partners, such as third parties with whom we may co-sponsorevents or promotions or with whom we jointly offer products and services, or whose productsand services may be of interest to you;
for any other purpose disclosed by us when you provide the information;
to comply with applicable law including in connection with any court order, law enforcementinvestigation, legal process, including responding to any government or regulatory request;
to professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in thecourse of the professional services they render to us, and subject to professional and contractualobligations of confidentiality;
to carry out our obligations and enforce our rights arising from any contracts entered intobetween you and us, including for billing and collections;
to courts and public authorities to protect you, Company, or third parties from harm; or
with your consent or as required to provide you with Services.

4. Data Security

We have organizational and technical measures and safeguards in place that are designed to secure andprotect your personal information. The use of, and access to, your personal information by us isrestricted to authorized individuals who need to know that information to provide services to you, andwho receive training about the importance of protecting personal information. Our service providers andbusiness partners are also contractually bound to maintain the confidentiality of personal informationand may not use the information for any unauthorized purposes.

Unfortunately, no method of transmission of information via the internet or electronic storage iscompletely secure. Although we use reasonable efforts to protect your personal information, we cannotguarantee the security of your personal information transmitted to us through our website or otherelectronic means. Any electronic transmission of personal information is at your own risk. In the eventthat we are required by law to inform you of a breach of your personal information we may notify youelectronically, in writing, or by telephone, if permitted to do so by law.

If you believe your information is not secure, please immediately notify us of the problem at the addressprovided in the “Contact Us” section below.

5. Retention of Personal Information

Generally, we will hold your personal information for as long as you remain a Customer of ours or as longas necessary to perform the activities described in this Privacy Policy, unless we have an ongoinglegitimate business need that requires a different retention period. We retain the information in order toprovide and maintain the quality of the Services you have requested, or if we are obliged to retain suchinformation for legal, regulatory, fraud prevention, accounting, or reporting requirements.

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 useand/or disclosure of your personal information, the purposes for which we process your personalinformation and whether we can achieve those purposes through other means, and the applicable legalrequirements. When our legitimate business need for retaining your personal information ceases toexist, we will either delete or anonymize your information so that it can no longer be attributed to you.

6. Other Important Information

Chat ModulesWe may collect certain categories of personal information from you when you use the interactive chatmodule available on our Services. In addition to the information you may enter into the chat box or livechat feature, the categories of personal information include, but are not limited to, name, phonenumber, email, mailing address, and other identifiers you may provide. Additionally, we may also storeany transcripts from such conversations and link those transcripts with your personal information. Wemay also collect information from you to perform data analytics and thereby enhance your experienceand help improve the functionality of our tools and digital advertising in an effort to present to you onlyrelevant products and services. Such information includes, but is not limited to, geolocation, IP address,pixel tags, browsing history, viewing behavior, clicks, online activity, and other analytics. By interactingwith the chat module, you understand and agree that we may use this data to communicate with youabout our products and services. You also consent to our collection and analysis of all personalinformation provided as part of the chat module and understand that we utilize a vendor to process,analyze, and store the content of the chat on our behalf. By using the chat module, you are consenting tous disclosing and sharing with the chat module vendor any personal information you provide.

Session Replay Tools.

We may collect certain categories of personal information from you when you interact with our Servicesthrough the use of session replay tools. Session replay is a visual tool that recreates your sessions fromour Services, giving us a better understanding of how you interact with our Services to help maximize thecustomer’s experience. Session replay tools that we may utilize include, but are not limited to, video-likeplayback, error tracking integration, application performance monitoring (APM) integration, real usermonitoring (RUM) session timeline, and speed controls. Depending on your interaction with our Services(e.g. when you complete a “Contact Us” form), the categories of personal information we may alsocapture include, but are not limited to, name, phone number, email, mailing address, and other identifiers that you may provide. By interacting with our Services, you are consenting to us capturing anyinteractions and any personal information you provide.

Links to Third Party Services

Our Services may include links to third party services where you might be able to post comments,reviews, or view third party information. Please note, the inclusion of a link on our Services to a thirdparty’s service does not imply endorsement of the third party’s data handling practices, and does notimply that the third party’s practices are covered by this Privacy Policy. We are not responsible for theprivacy practices of these entities.

Children’s Information

We do not knowingly contact or collect personal information from children under 16. Our Services arenot intended to solicit information of any kind from children under 16. It is possible that by fraud ordeception we may receive information pertaining to children under 16. If we become aware of this, assoon as we verify the information, we will immediately comply with our legal obligations and delete theinformation from our servers. If you want to notify us of our receipt of information by children under 16,please do so by emailing us at info@commentcompass.com.

Conducting Data Analytics

We are an innovative business, which relies on developing sophisticated products and services bydrawing on our experience from prior engagements. We may create aggregated, de-identified and/oranonymized data from your personal information and other individuals whose personal information wecollect. We make personal information into de-identified and/or anonymized data by removinginformation that makes the data identifiable to you.

We are not concerned with an analysis of identifiable individuals, and we take steps to ensure that yourrights and the legitimacy of our activities are ensured through the use of aggregated or otherwisede-identified data. We may use this aggregated, de-identified and/or anonymized data and share it withthird parties for our lawful business purposes, including to analyze and improve our Services and topromote our business. We will not attempt to re-identify any such data, except as permitted by law.

Cookies and Other Technologies

Company and our partners (e.g., marketing partners, analytics, advertising, or service providers) may usevarious tracking technologies such as cookies, beacons, tags and scripts to analyze trends on ourServices, administer our Services, and to gather demographic information about our user base as awhole. We receive reports based on the use of these technologies by these companies on an individualas well as aggregated basis.

We have not implemented technology to respond to the Global Privacy Control signal for Californiaresidents.We may use chat technologies and similar technology providers that employ cookies and software codeto operate the chat features that you can use to communicate with us through the Services. Our onlinechat provider and other third parties may access and use information about webpages visited on ourSites, your IP address, your general geographic information (e.g., city, state), and other personalinformation you share through online chats for the purposes described in this Privacy Policy.

Targeted Advertising Practices

We rely on a third-party services provider to either display advertising on our Services or to manage ouradvertising on other sites. These service providers may use technologies such as cookies to gatherinformation about your activities on our Services in order to provide you with advertising based uponyour browsing activities and interests. If you wish to not have this information used for the purpose ofserving you interest-based ads, you may opt-out by clicking here (or if located in the European Unionclick here). Please note this does not opt you out of being served ads. You will continue to receivegeneric ads.

Non-Personal Information.

This Privacy Policy does not restrict our collection, use or disclosure of any aggregated information orinformation that does not identify, or cannot be reasonably linked to, any individual.

Accessibility.

If you have a disability and require an alternative format to this Policy, please email usat: info@commentcompass.com so that we may provide you with a more suitable format.

7. Privacy Rights and Choices

Depending on applicable law where you reside or are located, you may be able to assert certain rightsidentified below with respect to your personal information. Any rights you may have in relation to yourpersonal information are not absolute. We reserve the right to refuse to act on a request that ismanifestly unfounded or excessive (for example because it is repetitive) and/or to charge a fee that takesinto account the administrative costs for providing the information or taking the action requested.

A. Right to Know/Access. You may have the right to obtain a copy, or a list of categories of thepersonal information that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your personal information.

B. Right to Correct. You may have the right to correct any of your personal information in ourrecords and systems. You may request us to rectify, correct or update any of your personalinformation held by us that is inaccurate.

C. Right to Delete. Under certain circumstances, you may have the right to request that we deletethe personal information that we hold about you. This right is not absolute, and we may refusesuch a request if there are compelling legitimate grounds for keeping your personal information,for legitimate purposes, or as required by law. In addition, in the event your deletion request ishonored, we may retain a record of your deletion request as required under applicable law.

D. Right to Portability. You have the right to receive a copy of the personal information we havecollected about you in a structured, commonly used and machine-readable format.

E. Right to Opt-Out of Automated Decision-making or Profiling. You may have the right not to besubject to a decision which significantly impact your rights that is based solely on automatedprocessing (where a decision is taken about you using an electronic system without humaninvolvement). No decision will be made by us about you solely on the basis of automateddecision making which has a significant impact on you.

F. Right to Appeal. In certain jurisdictions, you may have the right to appeal if we refuse to takeaction on your rights request. Instructions on how to appeal will be provided to you upon such adenial, but in any event, such instructions will be substantially similar to those provided belowfor submitting requests.

G. Right Against Discrimination. You may have the right not to be discriminated against forexercising any of the rights described in this section. We will not discriminate against you forexercising your rights.

H. We do not sell your personal information. We do not sell your personal information for targetedadvertising. We do not process any information that may be considered “sensitive personalinformation”, under certain laws, to infer characteristics about you.

To make a privacy rights request, please contact us by email at info@commentcompass.com. To confirmyour identity, we may ask you to verify personal information we already have on file for you. If we cannotverify your identity based on the information we have on file, we may request additional informationfrom you, which we will only use to verify your identity, and for security or fraud-prevention purposes.

In your request, please make clear what information you would like to have changed, whether you would like to have your personal information corrected, deleted, or other limitations you would like to put on our use of your personal information.

We may only implement requests with respect to personalinformation that is associated with the particular email address that you use to send your request.You may use an authorized agent to submit a rights request on your behalf. If you use an authorizedagent to submit requests on your behalf, we will require you to directly verify your identity with us, orhave you directly confirm with us that the authorized agent has been authorized to act on your behalf.

Depending upon the applicable law, access to your rights may be denied: (a) when denial of access isrequired or authorized by law; (b) when granting access would have a negative impact on another’sprivacy; (c) to protect our rights and properties; or (d) where the request is frivolous or vexatious, or forother reasons.

For individuals located in the European Economic Area, Switzerland or the United Kingdom during datacollection, please refer to Section 10 below for more information about your rights.

8. International Data Transfers

We are a global business, with a primary location in the US, but we may store, process and transmitpersonal information in locations around the world, including locations outside of the country or jurisdiction where you are located. Such countries or jurisdictions may have data protection laws that areless protective than the laws of the jurisdiction in which you reside. If you do not want your informationtransferred to or processed or maintained outside of the country or jurisdiction where you are located,you should not use our Services.

9. Contact Us

If you have any general questions or comments for Us, please contact us at:

Intelliterran Inc. dba Comment Compass

20200 West Dixie Highway Suite 902

Aventura, FL 33180Or via e-mail: info@commentcompass.com

‍

10. Jurisdiction Specific Privacy Rights Statements

Personal information that you submit through the Services may be transferred to other States orcountries other than where you live. The following provisions may apply to you depending on where youare located. If you choose to access services from somewhere other than your home country or state,you are responsible for compliance with local laws

Australia. If you are an Australian resident, and you are dissatisfied with our handling of anycomplaint you raise under this Privacy Notice, you may wish to contact the Office of theAustralian Information Commissioner.
Canada. Personal information maintained and processed by our affiliates and third-party serviceproviders in the U.S. and other foreign jurisdictions may be subject to disclosure pursuant to alawful access request by U.S. or foreign courts or government authorities. We will not provideyour information to third parties for marketing purposes without your prior consent. For moreinformation about our privacy practices; to access, update or correct inaccuracies in yourpersonal information; or if you have a question or complaint about the manner in which we orour service providers treat your personal information, please contact us as set forth in theContact Us section of this Privacy Notice.
European Economic Area (EEA) and the United Kingdom (UK). If you are located in the EEA, theUK we comply with applicable laws to provide an adequate level of data protection for thetransfer of your personal data to the US.
Transfers outside the EEA and UK. Where applicable law requires that a data transfer have legalmechanism, we use one or more of the following: Standard Contractual Clauses with a datarecipient outside the EEA or the UK (or additionally, in the case of the UK, the International DataTransfer Agreement (IDTA) or Addendum to the Standard Contractual Clauses issued by the ICO),verification that the recipient has implemented Binding Corporate Rules, or other legal methodavailable to us under applicable law. Complaints. If you are a resident of the EEA, and believe weprocess your information in scope of the General Data Protection Regulation (GDPR), you maydirect your questions or complaints to the Office of the Data Protection Commissioner. If you area resident of the UK, you may direct your questions or concerns to the UK InformationCommissioner’s Office. To exercise your privacy rights set forth in this Privacy Notice, you maycontact us as set forth in the Contact Us section

United States Privacy Laws

This Section describes our additional information practices related to your Personal Information underapplicable state laws. This Section DOES NOT cover information that is exempted, including informationthat is protected by the Gramm-Leach-Bliley Act (GLBA) and the Health Insurance Portability andAccountability Act (HIPAA).

California See California Privacy Notice below
Connecticut (Effective July 1, 2023). Under the Connecticut Data Protection Act (“CTDPA”), ifapplicable to us, Connecticut residents have the right to receive certain disclosures regarding abusiness’ processing of “Personal Data,” as defined under the CTDPA, as well as certain rightswith respect to our processing of such Personal Data. To the extent you are a Connecticutresident, and we collect Personal Data subject to applicable Connecticut law, in addition to thoserights outlined in Your Choices section above, you also have the following rights:o Right to Opt-Out of Sale, Targeted Advertising, and Profiling: For purposes of the CTDPA,a “sale” includes disclosing Personal Data to a third party in exchange for monetarycompensation or other valuable consideration. We do not “sell” Personal Informationunder this definition. Connecticut residents have the right to opt out of the processing of your Personal Data by us for decisions that produce legal or similarly significant effectsconcerning you. We do not process Personal Data for such profiling. To opt out oftargeted marketing, where applicable, please click on the Opt-Out Link on the bottom ofthe website homepage
Right to Appeal: If we decline to take action regarding your request, you have the rightto appeal. We will notify you providing our reasons and instructions for how you canappeal the decision. If the appeal is denied, we will provide a way for you contact theAttorney General to submit a complaint.
Colorado (Effective July 1, 2023). Under the Colorado Privacy Act (“CPA”), if applicable to us,provides some Colorado residents with the right to receive certain disclosures regarding abusiness’ processing of “Personal Data” as defined under CPA. To the extent you are a Coloradoresident, and we collect Personal Data subject to applicable Colorado law, in addition to thoserights outlined in Your Choices section above, you also have the following rights:o Right to Know: You can request the following information about how we have collectedand used your Personal Data and to see what Personal Data we have collected about youin a portable format.o
Right to Correct: You can ask us to correct inaccurate personal information that we havecollected about you.
Right to Delete: You can ask us to delete the personal information that we havecollected from you.
Right to Opt-Out of Targeted Ads and Significant Profiling: You may have the right toopt out of the processing of your Personal Data by us for decisions that produce legal orsimilarly significant effects concerning you. We do not process Personal Data for suchprofiling. To opt out of targeted marketing, where applicable, please click on the Opt-OutLink on the bottom of the Site homepage.
Nevada. This notice is provided to you pursuant to state law. Nevada state privacy laws permit usto make marketing calls to existing customers, but if you prefer not to receive marketing calls,you may be placed on our internal opt-out list by emailing us at info@commentcompass.com oryou may also contact the Nevada Bureau of Consumer Protection, Office of the Nevada AttorneyGeneral, 555 E. Washington St., Ste 3900, Las Vegas, NV 89101; telephone 702-486-3132; email:AGCinfo@ag.nv.gov
Texas. If you have a complaint, first Contact Us by visiting our Site or emailing us atinfo@commentcompass.com.
Utah (Effective December 31, 2023). Under the Utah Consumer Privacy Act (“UCPA”), Utahresidents have the right to receive certain disclosures regarding a business’ processing of“Personal Data,” as defined under UCPA, as well as certain rights with respect to our processingof such Personal Data. To the extent you are a resident of Utah, and we collect Personal Datasubject to applicable Utah law, in addition to those rights outlined in Your Choices section above,you also have the following rights:
Right to Opt-Out of Sale, Targeted Advertising, and Profiling: For purposes of UCPA, a“sale” includes disclosing Personal Data to a third party in exchange for monetarycompensation. We do not “sell” Personal Information under this definition. Utahresidents have the right to opt out of the processing of your Personal Data by us fordecisions that produce legal or similarly significant effects concerning you. We do notprocess Personal Data for such profiling. To opt out of targeted marketing, whereapplicable, please click on the Opt-Out Link on the bottom of the Site homepage.
Vermont. In accordance with Vermont law, we will not share information we collect about youwith companies outside of our group companies, except as required or permitted by law. Forexample, we may share information to service your accounts, complete requested transactions,or to provide rewards or benefits to which you are entitled.
Virginia (Effective January 1, 2023). Under the Virginia Consumer Data Protection Act(“VCDPA”), Virginia residents have the right to receive certain disclosures regarding a business’processing of “Personal Data,” as defined under the VCDPA, as well as certain rights with respectto our processing of such Personal Data. To the extent you are a resident of Virginia and wecollect Personal Data subject to applicable Virginia law, in addition to those rights outlined inPrivacy Rights and Choices section above, you also have the following rights:
Right to Opt-Out of Sale: Under the VCDPA, a “sale” includes disclosing or makingavailable Personal Information to a third party in exchange for money. We do not “sell”Personal Information under this definition.o
Right to Opt-Out of Targeted Ads and Significant Profiling: You may have the right toopt out of the processing of your Personal Data by us for decisions that produce legal orsimilarly significant effects concerning you. We do not process Personal Data for suchprofiling. To opt out of targeted marketing, where applicable, please click on the Opt-OutLink on the bottom of the Site homepage.
Right to Appeal: If we decline to take action regarding your request, you have the rightto appeal. We will notify you providing our reasons and instructions for how you canappeal the decision. If the appeal is denied, we will provide a way for you contact theAttorney General to submit a complaint.
Supplemental European Privacy Rights Statement If you are a resident of the European Economic Area, we rely on our legitimate interest as described in this Privacy Policy to process your personal information. Additionally, subject to any exemptions asprovided by law, you may have certain rights regarding the personal information we maintain about you.We offer you certain choices about what personal information we collect from you, how we use thatinformation, and how we communicate with you. If at any time you wish to exercise your rights, pleasereach out to us in accordance with the “Contact Us” section.
Right to Rectification. If your personal information is inaccurate or incomplete, you may beentitled to ask that we correct or complete it.
Right to Erasure. You may ask us to erase your personal information in some circumstances, suchas where we no longer need it or you withdraw your consent (where applicable) and wherethere is no other legal basis for processing.
Right to Restrict Processing. You may ask us to restrict or ‘block’ the processing of your personalinformation in certain circumstances, such as if you contest its accuracy or object to usprocessing it.
Right to Data Portability. You may have the right to obtain your personal information from us that you consented to give us or that was provided to us as necessary in connection with ourcontract with you, and if the processing is carried out by automated means
Right to Object. You may ask us at any time to stop processing your personal information, andwe will do so: (a) if we are relying on a legitimate interest to process your personal information,unless we demonstrate compelling legitimate grounds for the processing or your data is neededto establish, exercise, or defend legal claims; or (b) we are processing your personal informationfor direct marketing and, in such case, we may keep minimum information about you (forexample, in a suppression list) as necessary for our and your legitimate interest to ensure youropt out choices are respected in the future and to comply with data protection laws.
Right to Withdraw Consent. If we rely on your consent to process your personal information,you may have the right to withdraw that consent at any time, but this will not affect anyprocessing of your data that has already taken place.
Right to lodge a Complaint. If you have a concern about our privacy practices, including the waywe handled your personal information, you can report it to the data protection authority that isauthorized to hear those concerns.

California Privacy Notice

This California Privacy Notice (the “CA Notice”) supplements the information contained in our PrivacyPolicy and applies solely to individual residents of the State of California ("consumers" or "you"). Thepurpose of this California Privacy Policy is to provide consumers with a comprehensive description ofCompany’s online and offline practices regarding the collecting, use, disclosure, and sale of personalinformation and of the rights of consumers regarding their personal information under the CaliforniaConsumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”)(collectively “CA Privacy Laws”). This section does not apply to our collection, use, and sharing ofpersonal information of our job applicants and employees.

Collection and Use of Personal Information

We collect personal information from and about consumers for a variety of purposes. To learn moreabout the types of personal information we collect and how we collect it, please refer to Section 1 in thePrivacy Policy above and our Cookie Policy. To see the purposes for which we use this information, pleaserefer to Sections 1 and 2 in the Privacy Policy.

The CCPA defines a “business purpose” as the use of personal information for the business’s operationalpurposes, or other notified purposes, provided the use of personal information is reasonably necessaryand proportionate to achieve the operational purpose for which the personal information was collectedor another operational purpose that is compatible with the context in which the personal informationwas collected.

Please note that because the categories of personal information collected and shared largely depends onhow you interact with our Services, not all of the items listed in the tables below will be relevant to you.

The categories of other individuals or entities with whom we may share your Personal Information arelisted in Section 3 of the Privacy Policy above.

Selling or Sharing for Targeted Advertising.

We do not “sell” personal information as most people would typically understand that term. However,we do allow certain third-party partners and providers to collect information about consumers directlythrough our Services for purposes of providing, analyzing and optimizing our Services andadvertisements (ads), providing content and ads that are more relevant, measuring statistics and thesuccess of ad campaigns, and detecting and reporting fraud. To the extent this practice is interpreted toconstitute a “sale” under the CA Privacy Laws, please see our Cookie Policy for more informationincluding how to exercise your rights to opt-out of cookies, analytics and personalized advertising

Rights and choices for California Residents.

As a California resident, you may have privacy rights in addition to those described in “Your choices”, andwe list your rights below. However, these rights are not absolute, and in certain cases, we may declineyour request as permitted by law:

Right to Information. You can request the following information about how we have collectedand used your personal information during the past 12 months:
The categories of personal information that we have collected.o The categories of sources from which we collected personal information.
The business or commercial purpose for collecting and/or selling personal information.
The categories of third parties with which we share personal information.
The categories of personal information that we sold or disclosed for a business purpose.
The categories of third parties to whom the personal information was sold or disclosedfor a business purpose.
Right to Access. You can request a copy of the personal information that we have collectedabout you during the past 12 months.
Right to Correction. You can ask us to correct inaccurate personal information that we havecollected about you.
Right to Deletion. You can ask us to delete the personal information that we have collected fromyou.
Right to Opt-out. Your options:
Opt-out of certain processing of personal information for targeted advertising purposes.
Please note that we do not currently respond to web browser “do not track” signals orother mechanisms that may allow you to opt out of the collection of information acrossnetworks of websites and online services as there is no standard for how online servicesshould respond to such signalsOpt-out of profiling/automated decision making. You canopt-out of automated processing or profiling performed on personal information toevaluate, analyze, or predict personal aspects related to a person's economic situation,health, personal preferences, interests, reliability, behavior, location, or movements.
Opt-out of other sales of personal data. You can opt-out of other sales of your personalinformation. We do not sell your personal information, buy you also have the right to tellus not to sell your personal information.
Right to Nondiscrimination. You are entitled to exercise the rights described above free fromdiscrimination as prohibited by the CA Privacy Laws. Unless permitted by the CA Privacy Laws,we will not deny you access to our products or services, charge, or suggest we charge you different prices or rates, or provide different levels of quality for goods and Services based onyour exercise of these rights

How to Exercise Your Privacy Rights

To exercise your rights to please submit your request to info@commentcompass.com or at . Asmandated by CA Privacy Laws, we will acknowledge receipt of your request within 10 days and willrespond within 45 days of receipt of your request, but if we require more time (up to an additional 45days) we will let you know. In some cases, you may designate an authorized agent to submit requests toexercise certain privacy rights on your behalf. We will require verification that you provided theauthorized agent permission to make a request on your behalf. You must provide us with a copy of thesigned permission you have given to the authorized agent to submit the request on your behalf andverify your own identity directly with us. If you are an authorized agent submitting a request on behalf ofan individual, you must attach a copy of: (a) A completed written notice indicating that you haveauthorization to act on the consumer’s behalf signed by you and the consumer; and (b) if you are abusiness, proof that you are registered with the appropriate Secretary of State to conduct business inCalifornia. If we do not receive both pieces of information, the request will be denied.

Exercising your right to opt-out of the “sale” or “sharing” of your Personal Information. Like manycompanies, we use services that help deliver targeted ads to you as described above. California PrivacyLaws may classify our use of some of these services as “selling” or “sharing” your personal informationwith the advertising partners that provide the services. You can submit requests to opt-out of certainprocessing of personal information for targeted advertising purposes or other sales of PersonalInformation via emailing: info@commentcompass.com.

Verification of identity; authorized agents.

We will need to verify your identity in order to process your information/know, access, correction, ordeletion requests and reserve the right to confirm your residency. To verify your identity, we may requiregovernment identification, a declaration under penalty of perjury, or other information, where permittedby law.

Your authorized agent may make a request on your behalf upon our verification of the agent’s identityand our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power ofattorney, you must provide your agent with written and signed permission to exercise your CA PrivacyLaws rights on your behalf, provide the information we request to verify your identity, and provide uswith confirmation that you have given the authorized agent permission to submit the request.