Acceptd – U.S. Supplemental Privacy Notice

Effective Date: January 1, 2023

This U.S. Supplemental Privacy Notice (“U.S. Supplement”) describes how GetAcceptd, LLC and its affiliates and subsidiaries (“Company,” “we,” “us” and “our”) collects and processes personal information, including through your visits to all of the websites and mobile applications we operate (collectively, the “Site”), and certain rights you may have under state privacy laws relating to your personal information. This U.S. Supplement supplements our Website Privacy Policy, located at https://cms.getacceptd.com/privacy-policy (“Website Privacy Policy”) and applies to our processing of personal information of individuals in California, Colorado, Connecticut, Utah and Virginia.

Please note that we also act as service providers for our customers and maintain and store the personal information of our customer’s constituents and clients on our customers’ behalf when our customers use our products. Such information is not subject to this U.S. Supplement and is instead subject to the privacy policies of our customers.

1. How we collect, use, disclose, sell and share personal information 

We have collected the following categories of personal information and used, disclosed, sold or shared for purposes of cross-contextual behavioral advertising such information in the twelve (12) months prior to the effective date of this U.S. Supplement:

We collect the personal information described above from or through the following categories of sources:

• From you directly and indirectly, including when you access/visit the Site, purchase our products, use our products, request a demo of our products or sign up for a free trial, create an account with us, sign up to receive our newsletters and/or marketing communications, sign up for our webinars/events/forums or contact us; and

• From third parties, including our service providers who provide analytics services to help us understand the activity on the Site.

We collect and disclose the personal information described above for a variety of business purposes including:

• to provide the Site to you and to improve the Site;

• to provide, operate, improve, and personalize the products and services we offer, and to give each user a more consistent and personalized experience when interacting with us;

• to register your account;

• to determine trends in consumption of our products and determine where our products may be in demand;

• to provide you with information about products and services that we may provide that we think may be of interest to you;

• to help deliver advertisements that are relevant to you and your interests and measure the effectiveness of our advertising campaigns;

• to provide you with updates about our products and services and with transactional information;

• for customer service and/or support, security (including for authentication purposes), to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site;

• for analytics purposes;

• to fulfill your requests, such as those related to ordering and payment;

• to communicate with you, including through any chat function on the Site;

• to enforce our Website Privacy Policy, this U.S. Supplement or other applicable policies;

• to comply with applicable laws or respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process;

• to enforce our rights, protect our property or protect the rights, property or safety of others;

• as needed to support external auditing, compliance and corporate governance functions.

We will retain the personal information described above for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.

2. Specific Information for California Residents

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CPRA”) provides California residents with specific rights regarding their personal information. The below describes such rights and how you may exercise such rights, and our information practices, including the categories of personal information we collect, use, retain, disclose, sell or share, and how and why we collect, disclose, sell or share such information.

Your Rights

Right to Know

You have the right to request that we disclose what personal information we collect, use, disclose, sell or share. Specifically, you may request that we disclose to you the following:

1. The categories of personal information we have collected about you.

2. The categories of sources from which the personal information is collected.

3. The business or commercial purpose for collecting, selling or sharing personal information.

4. The categories of third parties with whom we disclose personal information.

5. The specific pieces of personal information we have collected about you.

You may also request that we disclose to you:

1. The categories of personal information that we have sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each third party to whom the personal information was sold or shared.

2. The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

Right to Request Deletion

You have the right to request that we delete any personal information about you which we have collected from you. If it is necessary for us to maintain your personal information for certain purposes, we are not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it.

Right to Opt-Out of Sale or Sharing of Personal Information

We do not sell your personal information for monetary consideration. However, we may use third-party cookies for analytics and/or targeted advertising purposes. The collection of data through certain third-party cookies for our analytics or targeting advertising purposes may be considered a “sale” and is considered “sharing” under the CPRA. To opt-out of having your information sold and shared with third-party website analytics and digital advertising service providers for this purpose, please contact our Support Team at support@getacceptd.com.

Right to Correct Inaccurate Personal Information

You have the right to request a business that maintains inaccurate personal information about you to correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not collect your sensitive personal information.

No Discrimination

You have the right not to be discriminated against because you exercised any of your aforementioned rights.

How to Submit a Request

To exercise the rights described above, you must submit a verifiable request to us. You can do so by calling us at (888) 554-6634 or by visiting www.togetherwork.com.

If you maintain an online account with us, we will verify your identity for a request through the normal account authentication process, meaning you will need to sign on with your username and password.

To submit a verifiable request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity and value of the personal information that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors.

You may make a verifiable request on behalf of your minor child. You may also designate an authorized agent to make a request on your behalf by providing the agent with signed written permission to do so.

If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.

If you are a constituent or client of one of our customers, please submit your requests to exercise your rights directly to such customer.

Personal Information of Minors

We do not have actual knowledge that we sell or share personal information about minors under the age of 16.

3. Colorado, Connecticut, Virginia and Utah Residents

The Colorado, Connecticut, Virginia and Utah privacy laws provide the following rights to “consumers” (i.e., state residents who act in an individual or household context and exclude individuals acting in a commercial context):

• Confirm whether or not an entity is processing your personal information and access such personal information;

• For Virginia, Colorado and Connecticut residents, correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information;

• Delete personal information provided by, or, for Virginia, Colorado and Connecticut residents obtained about, you;

• Obtain a copy of your personal information that an entity processes, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance, where the processing is carried out by automated means; and

• Opt out of the processing of personal information for purposes of:

• Targeted advertising;

• The sale of personal information; or

• For Virginia, Colorado and Connecticut residents, profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Under the Colorado, Connecticut, Virginia and Utah privacy laws, we generally act as a “processor” for our customers and maintain and store the personal information of consumers on our customers’ behalf when our customers use our products. Accordingly, if you are a consumer of one of our customers, please submit your requests to exercise your rights directly to such customer.

4. Contact Information; Questions

If you have any questions regarding this U.S. Supplement, please contact us at legal@togetherwork.com.

5. Notification of Changes to this U.S. Supplement

Any changes to this U.S. Supplement will be posted to this page so users are always aware of the information we collect and how we use it. Accordingly, please refer back to this U.S. Supplement frequently as it may change.