1. WHAT INFORMATION DOES PERSONATECH COLLECT ABOUT ME AND WHY?
We collect information that identifies, describes, or is reasonably capable of being associated with you (“personal information”). The following discusses the categories of personal information we collect and have collected in the preceding 12 months, the sources we collect information from, and the business or commercial purposes use of your personal information.

• To provide you with the Services that you have requested – To administer our relationship with you, provide you with Services, and to carry out our obligations arising from the relationship between you and us, including internal accounting and administration purposes, and to create and manage your account.
  To provide you with Services we may collect:
  • Identifiers Such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers.
  • Your opinions or other information. For example, if you review the Services you have purchased from us or provide information about services, and the brands and products you use.
  • Protected classification characteristics and sensitive personal information, For example, age (40 years or older), ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression), sexual orientation, and veteran or military status. For information on your rights with respect to sensitive personal information please review the section titled – “What are My Data Protection Choices and Rights?”
  • Professional or employment-related information. Such as current or past job title, employer, role, business contact information, or job history.
  • Commercial information. Records of Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Geolocation Data. Such as precise physical location or movements. We collect your IP address and infer location such as city or postcode therefrom.
  • Internet or other similar network activity. Such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
• In connection with our use of artificial intelligence – We may use artificial intelligence, machine learning and automated decision-making processes (collectively “Artificial Intelligence Technology”) to process personal information about you in connection with the performance of our Services (including Meeting Program Services). This may include the use of personal information to train, retrain, tune, validate, modify, update or otherwise improve any such Artificial Intelligence Technology. The Artificial Intelligence Technology we use is built on a proprietary, private model architecture that is not publicly shared, open-sourced, or made available for external training or inference.
  In connection with our use of Artificial Intelligence Technology we may collect and process:
  • Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers.
  • Professional or employment-related information such as current or past job title, employer, role, business contact information, or job history.
  • Commercial information including records of Services (including Meeting Program Services) purchased, accessed, attended, obtained, or considered or other purchasing, attendance or consuming histories or tendencies.
• To process your payments – After you place an order on our website you will need to make payment for the Services you have ordered. Your payment may be processed by our third-party payment processors, such as Braintree, Stripe, and PayPal (the “Payment Processors”). The Payment Processors collect, use and process your information, including payment information, in accordance with their privacy policies. Information you provide to the Payment Processors may be used for payment transaction processing and fraud prevention.
  • You can access Braintree’s privacy policy via the following link: https://www.braintreepayments.com/legal/braintree-privacy-policy
  • You can access Stripe’s privacy policy via the following link: https://stripe.com/privacy
  • You can access PayPal’s privacy policy via the following link: https://www.paypal.com/myaccount/privacy/privacyhub

  To process payments we may collect and process:

  • Identifiers. Such as a real name, alias, postal address, unique personal identifier, online or device identifier, Internet Protocol address, email address, account name, or other similar identifiers.
  • Commercial information. Records of Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• For chat sessions – If you use the chat feature of the Services to chat with a customer service representative we will have access to a transcript of the chat session. We use information provided through the chat feature to provide you with customer assistance.
  We use third party vendor to provide the chat feature. The information you provide through the chat feature is collected by and stored on the third party vendor’s systems. We do not control and are not responsible for our vendor or its collection or use of your information.
  In connection with chat sessions we may collect and process:
  • Identifiers. Such as a real name, alias, postal address, telephone number, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
  • Commercial information. Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• For analytics purposes – For example, we may analyze your personal information including your location, Services requested, age, time zone, IP address and URL visited, against our wider customer base for internal business purposes, such as generating statistics and developing marketing plans, to improve our Services and the website. We may also aggregate and de-identify your information to create customer segments and share with our affiliates and partners.
  To perform analytics we may collect and process:
  • Internet and network information, as described in more detail in our Cookie Policy, if you use our Services, we automatically collect information about your browsing and search history, interaction with the features of our Services, and responses to advertisements.
• To provide you with marketing communications that you might be interested in – If you choose to receive marketing communications from us, we may use your personal information to keep you up to date with our latest Services, surveys, announcements, upcoming events, sweepstakes, contests and other promotions via our newsletters, emails, or other communications. If you no longer wish to receive these marketing communications, details of how to opt out are described in the section below marked “How do I stop receiving marketing communications?
  To provide marketing communications we may collect and process:
  • Identifiers. Such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
  • Commercial information. Records of Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• For non-marketing communications – We may use your personal information to communicate with you about important information in relation to your account, the service you have requested or other non-marketing communications. This includes: (i) to process and respond to your questions and/or inquiries; (ii) emailing you to verify your identity when you sign-up; (iii) emailing you where you have requested a password and/or username reset; (iv) notifying you that a particular service has been suspended for maintenance or terminated; (v) letting you know that we have updated this Notice or our Terms of Use; or (vi) letting you know about any Services that you have requested or purchased. We will never contact you to ask for your password, please be careful if you receive any communications from people requesting this information. To provide non-marketing communications we may collect and process:
  • Identifiers. Such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
• For Service optimization and management – For example we may use your personal information provided to us to:
  • administer the Services;
  • ensure the security of our networks and of your information;
  • customize your future visits to the website based on your interests to ensure the most user-friendly online navigation experience;
  • improve the Services and our other digital offerings (including to fix operational problems such as pages crashing and software bugs); and
  • provide services to our partners such as tools, analyses, data and insights to see how their website or mobile applications are used.

  To support site optimization and management we may collect and process:

  • Internet and network information, as described in more detail in our Cookie Policy, if you use our Services, we automatically collect information about your browsing and search history, interaction with the features of our Services, and responses to advertisements.
• For service development, service diagnostics, and business development purposes – For example, we will use information we collect from you to improve our Services and develop new Services.
• For fraud prevention and detection purposes and to protect and defend the rights and property of Personatech, our employees and business partners.
  • Identifiers. Such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
  • Internet or other electronic network activity information. Device and system information, connection information, usage information, diagnostic data (including system/app/service error information, usage information during an error).
• For employment application purposes – For example, if you contact us in relation to your employment prospects, we will use your personal information to consider you for current and future employment opportunities and to contact you with respect to employment opportunities at Personatech that you have expressed an interest in.
• To verify your identity – For example we may use your email address to determine if you already have an account with us.
• Information that we collect automatically. When you engage with Personatech we may use cookies and similar tracking technology to collect the following information about you automatically (for further information please see our Cookies Policy[KLG4] for more information):
  • Internet or other electronic network activity information. Such as browsing history, search history, information on your interaction with a website, application, or advertisement.
    • For example, when you visit the website, engage with Personatech content or with us digitally, we may collect certain information from your computer, tablet or mobile phone (“Device”) such as your IP address, Device type (i.e. make and model), unique device identification numbers, browser-type and time zone settings
    • We may also collect information about how your Device has interacted with us including: the pages accessed and links clicked; how you navigate to and from the website (such as how you scroll over the site, which parts you click and how long you spend on each page); your preferences, the Services that you have viewed or searched for; and crashes, download errors and response times.
  • Geolocation Data. Such as physical location or movements while onsite at an event. We collect your IP address and infer location such as city or postcode therefrom.
    • For example, when you visit the website, engage with Personatech content or with us digitally, we may collect your broad geographic location (e.g. country or city-level location) from your Device.
  • Inferences drawn from other personal information. Such as a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
    • For example, when you visit the website, we may use the personal information indicated above to provide you with tailored advertising, content and services that we think you may like. This is described in further detail in the section below marked “How does Personatech use My Personal Information?”.
• Information that we obtain from third party sources. From time to time, we may receive personal information about you from third party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us. The types of personal information we collect from third parties includes:
  • Customer Relationship Management Platforms (CRM). We may receive personal information from CRM platforms as designated by our customers. We use this information in connection with the services we provide pursuant to our customer agreements.
  • Retailers, distributors and third party brand partners. For example, where permitted by applicable data protection law and, if applicable, where you have specifically consented, our retailers, distributors and third party brand partners may pass information to us including your first name, last name, email address, postal address, phone number, gender, browsing patterns, geo-location and device identifiers, click through and other cookie data, demographic information including information about your appearance and information in relation to products or purchased at their stores and services requested using their websites and/or applications.
  • Technology partners and market research organizations. For example, where permitted by applicable data protection law and if applicable where you have specifically consented, our preferred technology partners may share information with us, including your browser patterns, geo-location and Device identifiers.

Use of Non-Personally Identifiable Information
We may use non-personally identifiable information, such as anonymized and/or aggregated Services usage data, in any manner that does not identify individual users for the purpose of improving the operation and management of the Services, including to develop new features, functionality, and services, to conduct internal research, to better understand usage patterns, to resolve disputes, to troubleshoot problems, to fulfill user requests, or for security and compliance purposes. Any non-personally identifiable information that is combined with personal information will be treated by us as personal information.

Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the business purpose which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

2. DO WE SELL OR SHARE PERSONAL INFORMATION?
We do not sell personal information. Certain Services offered by us in connection with events may enable you to share your personal information with third parties such as, event participants and sponsors. We may disclose personal information about you to a third party at your request in connection with the provision of such Services.

3. HOW LONG DOES PERSONATECH KEEP MY PERSONAL INFORMATION?
We retain personal information in identifiable form only for as long as necessary to fulfill the purposes for which the personal information was provided to us or, if longer, to comply with legal obligations, to resolve disputes, to enforce agreements and similar essential purposes. 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.

4. FOR WHAT BUSINESS PURPOSE CAN PERSONATECH USE MY PERSONAL INFORMATION IN THIS WAY?
We are required to satisfy one or more of the reasons set out by applicable data privacy law before we can collect and use your personal information.
Generally, our business purpose for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally rely on the following reasons to collect and use your personal information:

• Performance of a contract
  Using your information may be necessary for us to perform our obligations under a contract with you or with a view to entering into such a contract. For example, where you have: (i) purchased Services from us, we will need to use your information to provide those Services; or (ii) approached us in relation to employment opportunities, the collection and use of your personal information is necessary to enable us to offer you the job role, process your acceptance of the offer, on-board you as an employee and fulfil our obligations as an employer.
• Compliance with our legal obligations
  The collection and use of your personal information may be necessary to enable us to meet our legal obligations. For example, to verify your identity and undertake necessary due diligence checks.
• Pursuing our legitimate interests
  Where such processing is not overridden by your interests or fundamental rights, we are permitted to use your personal information where it is necessary in order to pursue our legitimate interests, for example to operate the website and our other digital offerings, to improve our Services, content and our other digital offerings or to undertake marketing. We may have other legitimate interests and if appropriate we will make this clear to you at the relevant time.
• Consent
  In some limited circumstances, we may rely on your consent to collect and use your personal information. For example, we may rely on consent: (i) where you have approached us in relation to employment opportunities and have provided us with sensitive personal information, such as information in relation to your racial and ethnic origin, sexual orientation, religion, physical and mental health, disabilities or trade union membership; or (ii) in relation to the sending of e-marketing or communications.
  • If we rely on consent, this will be made clear to you at the time we request your information. You can withdraw your consent at any point by using the mechanism provided at the time, or by contacting us using the contact details provided in the section “How do I contact Personatech?” of this Notice.
• Vital interests
  In some instances, we may need to use your personal information to protect your vital interests or those of another person.

You may not always be required to provide the personal information that we have requested. However, if you choose not to provide certain information, you may not be able to take advantage of some of our Services. Any information that is so required is clearly marked as mandatory. If you would prefer that we not collect certain personal information from you, please do not provide us with any such information, or opt out of providing this information where applicable.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), these interests will normally be as set out in this Notice; however, if this changes we will make clear to you at the relevant time what those legitimate interests are.

If you have any questions or need further information concerning the business purpose on which we collect and use your personal information, please contact us using the contact details provided in the section below marked “How do I contact Personatech?”

5. DOES PERSONATECH SHARE MY PERSONAL INFORMATION WITH ANYONE?
In addition to the third parties identified under the “Do we Sell or Share Personal Information” section, during the past 12 months, we may have disclosed the categories of personal information listed in the section marked “what categories of personal information does Personatech collect about me?” to the following categories of recipients:

• With our affiliates – We may make your personal information available to Personatech affiliated companies to allow us to provide our Services to you, for the purposes described in this Notice, or as notified to you when we collect your personal information.
• With our service providers and business partners – We engage third party service providers and business partners to perform functions on our behalf (for example, to support the delivery of our Services, or the website). This includes but is not limited to sharing information with the following types of service providers or business partners:
  • providers of marketing and customer relationship management databases and data management platforms – that enable Personatech to manage your information in a safe and efficient manner;
  • data analysis firms – that provide insights and help us to analyze trends using the data that we and they hold;
  • customer support specialists -that provide customer support services on our behalf for Personatech Services;
  • application development and web-hosting companies – to enable us to manage and improve the website;
  • information technology and related infrastructure providers;
  • email delivery providers;
  • SMS communications platforms; and
  • audit and professional service providers.
• As part of a business transfer – Personatech may disclose your personal information to an actual or potential buyer (and its agents and advisers) in relation to any actual or proposed divestiture, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding.
• To comply with laws – Personatech may disclose your personal information to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person; and
• To any other person with your consent to the disclosure.

6. WHAT ARE MY DATA PROTECTION CHOICES AND RIGHTS?
State consumer privacy laws may provide their residents with additional rights regarding our use of personal information. The following Section applies to individuals who reside in specific jurisdictions that provide additional privacy rights, including California, Colorado, and Virginia.

• 6.1 Your Rights and Choices
  Right to Access Specific Information and Data Portability Right. You have the right to request that we disclose certain information to you about our collection and use of personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting 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 (also called a data portability request).
  • If we disclosed personal information for a business purpose, the business purpose for which personal information was disclosed, and the personal information categories that each category of recipient obtained.

  Right to Correct Information. You have the right to request we update personal information about you that is incorrect in our systems.

  Right to Delete. You have the right to request that we delete any personal information about you that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) the personal information from our records, unless an exception applies.

  Right to Opt-out of the sale or sharing of Personal Information for Cross-Contextual Behavioral Advertising. We do not sell personal information or share personal information for cross-contextual behavioral advertising purposes.

  Right to Limit Sensitive Personal Information Use. You have the right to limit the use of sensitive personal information regarding you.

  Non-Discrimination. We will not discriminate against you for exercising any of your rights.

• 6.2 How to Exercise these Rights
  To submit a request to exercise these rights you may use one of these three methods:
  • Email: dataprotection@personatech.com
  • Phone: +1-855-368-0829
  • Request Form

  For all requests, please clearly state that the request is related to “Your Privacy Rights,” indicate which type of request you are making, and provide your name, street address, city, state, zip code and an e-mail address or phone number where we may contact you. We are not responsible for notices that are not labeled or sent properly or that do not include complete information.

  To appeal a decision regarding a consumer rights request, please submit your appeal using one of the three methods above. Your appeal should include an explanation of the reason you disagree with our decision. Within 60 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

  Only you, or a person registered with an applicable Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to personal information about you. You may also make a verifiable consumer request on behalf of your minor child.

  You may only make such a request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

  We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

  We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide the personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

  We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

  California Shine the Light Law

  California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please contact us using the information above.

7. THE GENERAL DATA PROTECTION REGULATION (“GDPR”)
Where Personatech is providing Meeting Program Services, it is acting on behalf of an Event Organizer or other company with which you are engaged, Personatech is a processor and the Event Organizer or other company is the controller of the personal information we receive about you. Where Personatech is collecting and processing personal information we receive directly from you in connection with our business relationship with you, Personatech is the controller of such personal information. Any questions or concerns regarding Personatech’s privacy and data protection practices can be directed to our Data Protection Officer at dataprotection@personatech.com.

Residents of the EU and UK may be entitled to other rights under the GDPR. These rights are summarized below. We may require you to verify your identity before we respond to your requests to exercise your rights. If you are entitled to these rights, you may exercise these rights with respect to personal information about you that we collect and store:

• the right to withdraw your consent to data processing at any time (please note that this might prevent you from using certain aspects of the Services);
• the right of access;
• the right to request a copy of personal information about you;
• the right to correct any inaccuracies in personal information about you;
• the right to erase personal information about you;
• the right to data portability, meaning to request a transfer of personal information about you from us to any other person or entity as chosen by you;
• the right to request restriction of the processing of personal information about you; and
• the right to object to processing of personal information about you.
• the right to object to processing of personal information about you.

You may exercise these rights free of charge. These rights will be exercisable subject to limitations as provided for by the GDPR. Any requests to exercise the above listed rights may be made to: dataprotection@personatech.com. If you are an EU or UK resident, you have the right to lodge a complaint with a Data Protection Authority about how we process personal information about you at the following website: https://edpb.europa.eu/about-edpb/board/members_en or https://ico.org.uk/.

International Transfers of personal information

Whenever we transfer personal information about you out of the EU or UK, we ensure a similar degree of protection is afforded to it by using a solution that enables lawful transfer of personal data to a third country in accordance with Article 45 or 46 of the GDPR (including the Standard Contractual Clauses (EU) of the International Data Transfer Addendum (UK)).

For additional information on the mechanisms used to protect personal information about you, please contact us at dataprotection@personatech.com.

8. WHAT IF I ACCESS A THIRD PARTY SITE THROUGH THE WEBSITE?
The website may contain links to or from third party sites. Please be aware that we are not responsible for the privacy practices of such third parties. This Notice applies only to the personal information we collect as described above. We encourage you to read the privacy policies of third party sites you access from links on the website or otherwise visit.

9. WHAT IF I ACCESS OR USE A SOCIAL NETWORK OR PUBLIC FORUM THROUGH THE SERVICES?
Our website may facilitate easy access to certain social networking sites and other websites or services with user-generated content features, such as Facebook, LinkedIn, and Twitter (“Social Sites”). You understand that we do not control such services and are not liable for the manner in which they operate. Please review the Social Sites’ privacy policies if you would like more information about how they collect, use and share your personal information, your privacy rights and how to change your privacy settings.
Our website may enable you to:

• Access Social Sites: This may include: access to websites such as Facebook, LinkedIn, and Twitter; or activation of third party websites when you make a ‘comment’, ‘share’ or ‘like’ something on the Social Site using a third party social network plug-in. In each instance, such third party’s privacy policy will apply to your interaction with that website or service;
• Submit content to Social Sites: For reviews, discussion forums, message boards, photographs and other public features (“Public Forums”). We do not restrict the distribution of personal information that you voluntarily disclose in these Public Forums, so please be aware that any information you disclose there may be collected and used by us and others. For this reason, we encourage you to refrain from providing or sharing personal information about yourself in the Public Forums. We cannot prevent third parties from using such information in a way that may violate this Notice or applicable law;

Signing-in using a Social Site or other third-party account may allow us to access information that you have given the Social Site permission to share. The sign-in feature may also transfer information to the Social Site or third party, such as your username or social media handle, to authenticate you. The Social Site or third party may also automatically collect information such as your IP address, information about your browser and device, and the web page address of the site. The sign-in feature may also place and read cookies from that third party that may contain a unique identifier the Social Site or other third party assigns to you. The functionality of and your use of the sign-in is governed by the privacy policy and terms of the Social Site.

Our use of your personal information in relation to the Social Sites will be as set out in this Notice or as otherwise notified to you. Again, please note that third party sites (including the Social Sites) may be under the control of a third party and we encourage you to familiarize yourself with the privacy policies and terms of use of each third party site.

10. HOW DO I STOP RECEIVING MARKETING COMMUNICATIONS?
We will only send you marketing communications if you have agreed to this, or if we are otherwise permitted by law. If at any time you decide that you no longer wish to receive marketing communications from us, you may opt out by clicking on the relevant ‘unsubscribe’ link in the emails you receive, by texting STOP in response to any text message or by contacting us using the details found in the section “How do I contact Personatech.”

Please note, while we will honor your request to stop receiving marketing communications, we will continue to send you service-related communications such as emails confirming purchases through the website.

11. DOES PERSONATECH TRANSFER MY PERSONAL INFORMATION TO OTHER COUNTRIES?
In order to provide our Services, we may need to transfer and process your personal information internationally (including to destinations outside the country in which you are located).

As a result, your information may be transferred to and/or processed in countries which may not guarantee the same level of protection for personal information as the country in which you reside. However, we have taken appropriate safeguards to ensure that your personal information will remain protected in accordance with this Notice.

Further information can be provided on request: please contact us using the details found in the section “How do I contact Personatech?” We have also implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

12. IS MY PERSONAL INFORMATION SECURE?
We understand that you care how your personal information is used and/or shared with others, and we value your trust and seek to safeguard your personal information.

We implement appropriate technical and organizational security measures, including physical, administrative and technical safeguards to protect your personal information from unauthorized access, use and disclosure.

The measures we use to protect your personal information are designed to provide a level of security appropriate to the risk of processing your personal information. However, please be aware that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures that we have in place to safeguard personal information will never be defeated or fail, or that those measures will always be sufficient or effective.

13. I HAVE ENTERED A CONTEST, PROMOTION OR SURVEY – HOW DO I FIND OUT MORE ABOUT THAT?
Personatech and its preferred third party service providers or business partners may offer surveys (each, a “Promotion”).

Where we do this, we will use your personal information as set out in this Notice, or as otherwise notified to you. However, in certain cases, a third party’s privacy policy may apply to any personal information that you provide in connection with such Promotion. Before entering any Promotion, we encourage you to check who is operating the Promotion in question, and the terms, conditions, policies and rules that apply to it.

14. HOW OLD DO I HAVE TO BE TO USE THE PERSONATECH SITES OR OTHER DIGITAL OFFERINGS?
You must be aged 13 or over to use the Personatech sites and our other digital offerings.

We take your privacy very seriously and we understand the importance of taking extra precautions to protect the privacy and safety of children who use our Services. We do not solicit or knowingly collect personal information from children aged 13 and under. If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.

California Minors: If you are a California resident who is under age 18 and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at: dataprotection@personatech.com. When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information was entered, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the content or information. Removal of your personal information from the Services does not ensure complete or comprehensive removal of that content or information from our systems or the systems of our service providers. We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public.

15. SMS COMMUNICATIONS
We collect mobile phone numbers when users register for events on our platform. Mobile phone numbers are used solely to send service-related SMS messages, including reminders, deadlines, confirmations, and other updates necessary for participation in event programs.

Mobile phone numbers may be shared only with trusted service providers (such as messaging platforms) solely for the purpose of delivering these SMS communications. Users may opt out of SMS messages at any time by replying STOP.

We do not use mobile phone numbers collected from users registering for events on our platform for marketing or promotional messages. We do not sell, rent, or share mobile phone numbers with third parties for marketing purposes.

For the avoidance of doubt, Mobile phone numbers and SMS opt-in data are not shared with event participants, sponsors, affiliates, or third parties for marketing or promotional purposes.

16. DOES THIS NOTICE EVER CHANGE?
We may update or modify this Notice from time to time in response to changing legal, technical or business developments. We will obtain your consent to any material Notice changes if and where this is required by applicable data protection laws. The date of the most recent version of this Notice will appear at the top of the page.

When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. For example, we will notify you of any changes to this Notice by posting a new Notice and updating the “last modified” date at the top of this page or by sending the new Notice to you via email, where appropriate.

17. HOW DO I CONTACT PERSONATECH?
We have taken great measures to ensure that your visit to the website is an excellent one and that your privacy is respected. If you have any questions, comments, or concerns about our privacy practices and/or would like to submit a privacy request, please contact us either:

• Via email at dataprotection@personatech.com or
• Via postal mail at: Personatech, Inc., Attn: Privacy Inquiries, 800 Third Avenue #1156, New York, NY 10022 United States.