Information We May Collect

In the preceding 12 months, we may have collected information that could directly or indirectly identify you as an individual from you, your devices, your interactions with our Services, and/or from third party sources and may include the following (together, “personal data”), depending on the circumstances:

Data We May Collect Directly From You

1. Identifiers:

• Customer Account Information, including (i) your first and last name, email addresses, mailing addresses, telephone numbers, professional title and business name; (ii) those of your trusted recipient(s) who are designated to receive your Customer Content stored in your account (“Trusted Recipient”); and (iii) those of other individuals designated by you through account registration to facilitate access of your Customer Content (“Recovery Contact”). Members of a family bundled plan may also provide emails and names of other authorized users.
  
  
  • Important Information regarding Your Mobile Phone Number. You may provide us with your mobile phone number if you set up two-factor authentication and/or opt-in to our SMS account recovery feature. By opting in to SMS account recovery, you consent to receiving autodialed text messages, including SMS messages, that may be sent by or on our behalf at the mobile phone number you provide us. Message and data rates may apply as provided in the Terms of Service.
  
  
  • Trusted Recipient and Recovery Contact: You represent that you are authorized to share personal data of your Trusted Recipient, Recovery Contact, or other designated individuals listed in your account.


• Communications Data, such as information you provide through online web forms, when you contact us (or our representatives) with questions, feedback, surveys, or otherwise choose to provide when you correspond with us online.


• Customer Content. Usernames, passwords, passkeys, secure notes, files, documents, or similar data that we maintain on your behalf, as well as any other information you may choose to upload or input (e.g., manually such as images, audio, or other information that you choose to store in your account) to your account in connection with your use of the Services as described in the Terms of Service.

2. Consumer Records, including Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

3. Demographic Information, including your age, gender, ethnicity, citizenship, religion or creed, marital status.

4. Commercial Information:

• Transaction Data, such as information about payments to and from you and other details of your interaction with the Services, including payment methods, billing details, among others. We use a third party payment processor so that we do not have access to your payment method details or otherwise receiv


• Marketing Data, such as your preferences for receiving communications about our activities, services, among others, and details about how you engage with our communications.

1. Internet or other similar activity; Inferences

• Usage Data, such as the date and time of your access, your location, your Internet Protocol (IP) address or unique device identifier, your device type, your operating system, your browser type, and information about what pages you visit.


• Your data collected via Cookies, as described below.

• Social Media Integration. Our websites have optional social networking features and connections, including "share" buttons for Meta or Google. These features may gather your IP addresses or information about which page you are visiting on our site, and they may also set a Cookie to make sure the feature works properly. If you use these services, integrations, and features from social media websites to prove who you are or fill out our sign-up or feedback forms, you authorize these social media websites to provide us certain personal data, including your name and email address.


• Third-Party Sources. Sometimes, we work with third-party partners and service providers who share us information about you. We also get information about you from various third-party sources that is publicly available. This information could include personal data, such as names, addresses, phone numbers, and email addresses, as well as business contact information, internet activity information, social media accounts, LinkedIn URLs, and custom profiles. We may use this data from a third party along with the personal data you give us to draw inferences about how we can best adapt our Services to meet your needs.

How We May Use Or Share Your Information

1. How do we use the information: To the extent permitted by applicable law, we may use the information described above in connection with certain business or commercial purposes in the preceding 12 months, including:

a. Provision and Improvement of Services and Products
• Provide you with our services, products, content, and customer support.
• Improve, develop, and evaluate existing and new services, products, features, and functionality.
• Operate, maintain, and manage our applications, databases, and systems, including communication records and back-ups.

b. Business Operations and Administration
• Support our business operations, including maintaining accounting records, analyzing financial results, complying with audit requirements, obtaining or maintaining insurance coverage, managing risks, and obtaining professional advice.
• Administer promotional programs and marketing initiatives.
• Manage our business relationships with you, including enforcing our terms of use and other agreements.

c. Communication and Customer Engagement
• Communicate with you and respond to your feedback, requests, questions, or inquiries.
• Solicit your feedback and inform you about our products, services, and promotional offers.

d. Marketing and Analytics
• Assess the effectiveness of our marketing campaigns and enhance our marketing efforts.
• Analyze the use of our services and applications, including preparing aggregate and anonymized traffic and usage information.
• Share aggregate or de-identified data with affiliates, business partners, and other third parties for lawful purposes.

e. Personalization and User Experience
• Recognize your devices and remember your preferences and interactions to personalize your experience.

f. Privacy, Security, and Risk Management
• Mitigate risks to the privacy and security of our services, including fraud and phishing detection.
• Protect the rights, property, or safety of our company, users, or others.

g. Legal, Regulatory, and Compliance
• Comply with applicable laws, regulations, court orders, or requests from government or law enforcement authorities.
• Exercise or defend legal rights or claims.

h. Corporate Transactions
• Facilitate business transactions such as mergers, acquisitions, reorganizations, or sales of assets, where your information may be part of the transferred assets.

i. Payment Processing
• Process your authorized payments through secure third-party service providers.

j. Other Purposes
• Accomplish any other purpose described to you at the time your information is collected, for which you have provided consent, or for which we have a legal basis.
• Accomplish any other purpose related or ancillary to the purposes described in this policy.

1. How we may disclose or share the information:

Where permitted by applicable law, we may disclose your personal data described above for business purposes in the following contexts:

• Third-Party Vendors or Channel Partners: We may share your personal data with other parties who perform functions on our behalf such as customer services, or who offer products and services specifically requested by you through e-commerce solutions, etc.


• Our Client(s): In performing services to our Client, we may collect certain personal data for and on behalf of our Client and may share such personal data with our Client in accordance with terms of our engagement letter with such Client. In that case, our use and disclosure of such personal data may be subject to our Client’s Privacy Policy, or engagement letter with such Client, who may use it for their own purposes.


• Corporate Affiliates: We may share your personal data with our subsidiaries or affiliates, and with their respective officers, directors, employees.


• Controlling Entities following M&A or Similar Transactions: If we sell, transfer, or otherwise share some or all of our assets in connection with a merger, reorganization, liquidation, dissolution, bankruptcy, or sale of assets, we may transfer your personal data as a part of the assets transferred as a result of the transaction without your consent.


• In Response to Legal Process or Defending Legal Claims: We may disclose personal data as required by law, court orders, subpoena, or other legal process or if we reasonably believe such action is necessary to comply with the laws.


• Professional Advisors: We may share your personal data with our attorneys, accountants, and/or other fiduciaries and consultants that need access to your information to provide operational or other support on our behalf.


• With Your Consent or at Your Direction: We may ask, from time to time, if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Policy. We may disclose your information in this context with your permission or upon your direction.

Data Retention

We retain and use your information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to enforce our agreements.

We take reasonable steps to delete the personal data we collect when (1) we have a legal obligation to do so; (2) we no longer have a purpose for retaining the information; or (3) if you ask us to delete your personal data, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations.

Data Security

We recognize the importance of safeguarding your personal data and we endeavor to maintain reasonable and appropriate physical, technical, and organizational safeguards, such as the implementation of reasonable security measures or protocols, designed to protect your personal data against accidental loss and unauthorized access, use, alteration, or disclosure, and to detect fraudulent identity verification activity and mitigate risks concerning your personal data.

While our security measures seek to protect your information in our possession, no security system is perfect, and no data transmission is 100% secure. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information transmitted to or from the Services. Please keep your password confidential. Do not share your password with anyone.

Your Rights and Choices Regarding Personal Information

Email Opt-Out. If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link at the bottom of our emails, or by contacting us via the “Contact Us” details at the end of this Policy and providing your name and email address so that we may identify you in the opt-out process.

Accuracy and Updating Your Information. If any of the information you have provided to us changes, please let us know via the “Contact Us” details at the end of this Policy. If you become aware of inaccurate personal data about you, you may want to update your information. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient, or incomplete Personal Data that you provide to us.

Complaints. If you believe your rights relating to your personal information have been violated, please contact us via the “Contact Us” details provided at the end of this Policy.

Cookies and Similar Technologies

We (and where applicable, in conjunction with third parties) use cookies, pixel tags, scripts and similar technologies (collectively referred to as "Cookies ") to automatically collect and record information about your browsing activities, and use of the Services. We may combine this “Usage Information” with other personal data that we collect about you.

a. Types of Cookies and Similar Technologies:

• Session vs. Persistent Cookies: Session Cookies are stored temporarily and deleted when you close your browser. Persistent Cookies remain on your device until they expire or you delete them.


• First-Party vs. Third-Party Cookies: First-party Cookies are set by our website, while third-party Cookies are set by others. Blocking Cookies may affect some Service features.


• Other Technologies: We also use web beacons, pixel tags, server logs, HTML Local Storage, Social Widgets, and UTM Codes to collect data as you interact with our website or emails. These may transmit personal data.

b. Purpose of Cookies

• Essential Cookies, which enable core site functions and process your transactions.


• Functionality Cookies, which remember your preferences and choices to enhance your experience.


• Performance Cookies, which collects aggregated, anonymous data on how you use the Services to help us improve functionality. Third parties may help us analyze this data.

c. Choices About Cookies

Children's Privacy

The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet. Our Services are not directed to children aged 18 or younger, nor is information knowingly collected from children under the age of 18. No one under the age of 18 may access, browse, or use the Services or provide any information to or on the Services. If you are under 18, please do not use or provide any information on the Services (including, for example, your name, telephone number, or email address). If we learn that we have collected or received personal information from a child under the age of 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child under the age of 18, please contact us via the “Contact Us” details provided at the end of this Policy.

For more information about COPPA, please visit the Federal Trade Commission's website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

Consumer Rights

• Right to Access. Subject to certain conditions set forth in the applicable U.S. state privacy laws, you have the right to know and see what personal data we have collected about you and receive a copy of such information in a portable format, purposes for which we collect your personal data, recipients of your personal data to whom we disclose or share, which in some states may include categories of personal data collected, categories of sources of collection, business or commercial purposes for data processing, and categories of 3rd parties with whom we disclose that information.


• Right to Correct. Subject to certain exceptions set forth in the applicable U.S. state privacy laws, you have the right to request that we correct any inaccurate personal data that we have collected about you.


• Right to Delete. Subject to certain exceptions set forth in the applicable U.S. state privacy laws, you have the right to request that we delete the personal data we have collected about you.


• Right to Opt-Out. Subject to certain conditions set forth in the applicable state privacy laws, you have the right to opt out of targeted advertising, profiling, the sale or sharing of your personal data, to the extent such instances occur (as defined under applicable state laws). We do not have actual knowledge that we sell personal data of minors under 16 years of age.


• Right to Non-Discrimination. You have the right not to be discriminated against for exercising any of your rights under the state privacy laws.


• Right to Appeal. To the extent the applicable state privacy laws provide such rights, you may appeal our denial to act on your consumer rights under the applicable state privacy laws within a reasonable time. We will respond within designated period for responding to U.S. data subject requests and may exercise the right to extend this response period (to the extent authorized by applicable state privacy laws).


• Right to Limit Use and Disclosure of Sensitive Personal Information. If any state privacy laws classify your information we collect as "sensitive personal information," we use such data reasonably necessary to perform services. While this right is not applicable to how we collect or use your sensitive personal information, we provide this information as this is one of consumer rights provided under certain state privacy laws.

Other Important Information

Contact Us