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Confidentiality in Filegrant.

PRIVACY

 

Cyber Grant Privacy Notice

Last Updated and Effective on 06/22/2023

Introduction Cyber Grant ("Company" or "We") respects your privacy and is committed to protecting it through our compliance with this Privacy Notice. This Privacy Notice describes the types of information we collect from you or that you may provide when you use the service through www.filegrant.com (our "Website"), a web or desktop application, or our mobile application, and our practices for collecting, using, maintaining, protecting, and disclosing that information. Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. This Privacy Notice may change from time to time. We will notify you pursuant to the Changes to Our Privacy Notice” section of this Privacy Notice if we make any material updates to it. Otherwise, please check this Privacy Notice periodically for updates. Your continued use of this service after we make changes is deemed to be acknowledgement of those changes. Please note that this Privacy Notice is not a contract and does not create any contractual rights or obligations.


1. PERSONS UNDER THE AGE OF 18 We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or through any of its features, register on the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use.

2. INFORMATION WE COLLECT ABOUT AND HOW WE COLLECT IT We collect the following types of information about you: - Contact information, such as name, email address, and telephone number; - Billing information, such as payment card number and expiration date; and - Any other information that you provide to us through your use of the service. We collect this information: - Directly from you when you provide it to us. - Automatically as you navigate through the site or use our applications or the service. - From third parties, such as other users of the service, our service providers and our business partners.

Information We Collect Through Automatic Data Collection Technologies As you navigate through and interact with our Website, applications, or service otherwise, we use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: - Details of your visits to our Website and use of our applications and service, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website. - Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically may include personal information, which helps us to improve our Website and applications and to deliver a better and more personalized service, including by enabling us to: - Estimate our audience size and usage patterns. - Store information about your preferences, allowing us to customize our Website, applications and service according to your individual interests. - Recognize you when you return to our Website, the application or service.

Some content or applications, including advertisements, on the Website or our applications are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see "Choices About How We Use and Disclose Your Information."

The technologies we use for this automatic data collection may include: - Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

- Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see "Choices About How We Use and Disclose Your Information."

Our use of tracking technologies includes cookies used for Google Analytics, which collect information on how users use our Website. For more information on Google Analytics, please visit "How Google uses information from sites or apps that use our services." For more information about our use of cookies, please see our Cookie Policy.


3. HOW WE USE YOUR INFORMATION We use information that we collect about you or that you provide to us, including any personal information: · To present our Website, applications, services and their contents to you. · To provide you with information, products, or services that you request from us. · To fulfill any other purpose for which you provide it. · To provide you with notices about your subscription, including expiration and renewal notices. · To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection. · To notify you about changes to our Website, applications, or services or any products or services we offer or provide therein. · To allow you to participate in interactive features on our Website or applications. · In any other way we may describe when you provide the information. · For any other purpose with your consent. We may also use your information to contact you about our own and third parties' goods and services that may be of interest to you. For more information, see "Choices About How We Use and Disclose Your Information."


4. DISCLOSURE OF YOUR INFORMATION We disclose personal information that we collect or you provide as described in this Privacy Notice: · To our subsidiaries and affiliates. · To contractors, service providers, including data analytics providers, and other third parties we use to support our business. · To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website, application and service users is among the assets transferred. · To third parties to market their products or services to you if you have these disclosures. For more information, see "Choices About How We Use and Disclose Your Information." For any other purpose disclosed by us when you provide the information. · With your consent.

We may also disclose your personal information: · To comply with any court order, law, or legal process, including to respond to any government or regulatory request. · To enforce or apply our Terms of use and other agreements, including for billing and collection purposes. · If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

Additionally, we may disclose deidentified or aggregated information about our users that does not identify any individual.


5. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: · Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. For more information about cookies, including how to manage preferences and provide or withdraw consent, please see our Cookie Policy. · Promotional Offers from the Company. If you do not wish to have your email address or contact information used by the Company to promote our own or third parties' products or services, you can opt-out by following the instructions provided in the email.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website. If you are accessing this Privacy Notice from a mobile application, you may find more information on opting out on mobile devices here. Residents of certain states, such as California, may have additional personal information rights and choices. Please see "Your State Privacy Rights" for more information.


6. ACCESSING AND CORRECTING TOUR INFORMATION If you have an account, you can review and change your personal information by logging into your account and updating your information. Residents of certain states, such as California, may have additional personal information rights and choices. Please see the California Consumer Privacy Notice Addendum and "Your State Privacy Rights" for more information.


7. CALIFORNIA CONSUMER PRIVACY NOTICE ADDENDUM" If you are a California consumer, the following provisions apply to our processing of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household ("California Personal Information"). For California consumers, the provisions of this Addendum prevail over any conflicting provisions in other sections of this notice.

California Personal Information We Collect About You and How We Collect It  We collect, and in the last 12 months have collected, the following categories of California Personal Information: (a) Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, and other similar identifiers. (b) Personal information described in subdivision (e) of Section 1798.80 (California customer records statute), such as the identifiers listed in item (a) above, telephone number, bank account number, credit card number, and debit card number, or any other financial information. (c) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement. (d) Geolocation data. (e) Audio, electronic, visual, or similar information. (f) Professional or employment-related information. (g) Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. (h) The following categories of sensitive personal information: personal information that reveals account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.

Please see "Information We Collect About You and How We Collect It" to learn more about the categories of personal information that we collect and the sources from which we collect it. We retain each category of California Personal Information as described in the "Data Retention" section of the Privacy Notice.

How We use Your California Personal Information |For each of the above categories, we use the California Personal Information for a variety of business purposes such as: (1) Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards. (2) Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes. (3) Debugging to identify and repair errors that impair existing intended functionality. (4) Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business. (5) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business. (6) Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer provided that, for the purpose of advertising and marketing, a service provider or contractor shall not combine the personal information of opted-out consumers that the service provider or contractor receives from, or on behalf of, the business with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with consumers. (7) Undertaking internal research for technological development and demonstration. (8) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. Please see "How We Use Your Information" for additional purposes for which we may use information. We may also use the information we collect for our own or our service providers’ other operational purposes, purposes for which we provide you additional notice, or for purposes compatible with the context in which the California Personal Information was collected. We do not use sensitive personal information for purposes that would give rise to a right to limit the use or disclosure of sensitive personal information for residents of California.

Disclosure of Your California Personal Information  Within the last 12 months, we have disclosed substantially all categories of California Personal Information for our business purposes. To learn more about the categories of third parties with whom we share such information, please see the "How We Disclose Your Information." We share, and in the past 12 months have shared, substantially all categories of California Personal Information with our marketing and advertising partners. Otherwise, we do not sell, and in the past 12 months we have not sold, California Personal Information. Additionally, we do not sell or share, and in the past 12 months we have not sold or shared, California Personal Information of individuals we know to be under 16 years of age.

Your California Privacy Rights If you are a California consumer, you have certain rights related to your California Personal Information, including: • The Right to know what California Personal Information we have collected about you, including the categories of California Personal Information, the categories of sources from which the California Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing California Personal Information, the categories of third parties to whom we disclose California Personal Information, and the specific pieces of California Personal Information we have collected about you. • The right to delete California Personal Information that we have collected from you. • The right to correct inaccurate California Personal Information that we maintain about you. • The right to opt out of the sale or the sharing of California Personal Information. • The right to limit the use or disclosure of your sensitive California Personal information. o We do not use or disclose sensitive personal information for purposes that, under applicable law, require us to support the right to limit the use or disclosure of sensitive personal information. • The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by applicable law, including the right not to be retaliated against for the exercise of your rights.

You may request to exercise these rights by: • Emailing us at privacy@cybergrant.net; • Calling us at +1 (650) 6225410; 

As required under applicable law, we will take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide your first name, last name, and email address to verify your identity in response to exercising requests of the above type. We may limit our response to your exercise of the above rights as permitted under applicable law. When you submit a request to exercise your rights above, we will use the information you provide to process your request and to maintain a record of your request and our response, as permitted under applicable law.

Under California law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. We will require the agent to provide proof of that written permission. To the extent permitted by law, we may require you to verify your own identity in response to a request, even if you choose to use an agent.

If you are an authorized agent submitting a request on behalf of a California consumer, please complete our privacy rights request form available here.

California Do Not Track California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings. We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. However, we process opt-out preference signals as required by applicable law.


8. YOUR STATE PRIVACY RIGHTS You may have the following rights, in each case to the extent set out in applicable law: • The right to confirm whether we process personal information about you and request access to such personal information (including, if applicable, in a portable and readily usable format).
• The right to correct inaccuracies in certain personal information we may hold about you; and • The right to request that we delete personal information collected about you. • The right to opt out of the processing of personal data for the purposes of (i) targeted advertising, (ii) the sale of personal information, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. • The right to appeal our decision regarding your rights request. • The right to not be discriminated against for the exercise of your state privacy rights.

You may request to exercise these rights by: • Emailing us at privacy@cybergrant.net; • Calling us at +1 (650) 6225410

If you are an authorized agent submitting a request on behalf of a consumer, please complete our privacy rights request form available here. Please note that we do not collect personal data revealing racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, or citizenship or citizenship status; genetic or biometric data; or personal data from consumers who we know are under 13 years of age.


9. DATA SECURITY We have implemented measures designed to reasonably secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our service. You should take reasonable steps to protect your information.


10. DATA RETENTION We retain personal information for the length of time necessary to carry out the processing purposes described in the Privacy Notice. We also retain information for related business purposes, security, legal compliance, and disputes, consistent with our retention policy and as permitted by applicable law.


11. CHANGES TO OUR PRIVACY NOTICE It is our policy to post any changes we make to our Privacy Notice. If we make material changes to how we treat our users' personal information, we will notify you by email to the email address specified in your account. The date the Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this Privacy Notice to check for any changes.


12. CONTACT INFORMATION To ask questions or comment about this Privacy Notice and our privacy practices, contact us at: privacy@cybergrant.net.