Guidebook Privacy Policy

1. Purpose

This Privacy Policy is designed to help you understand how Guidebook collects, uses and shares your Personal Information and to assist you in exercising the privacy rights available to you. The terms “Guidebook,” “we,” “us,” and “our” include Guidebook Inc. and our affiliates and subsidiaries. All other terms not defined in the “Definitions” section below or otherwise herein will have the meanings set forth in the Guidebook Terms of Service.

2. Scope

Guidebook provides a platform to enable location and event hosts and organizers (“Guidebook Customers”) to develop and manage mobile guides to events and places (each a “Guide”), as well as to allow end-users who attend or seek information about such locations and/or events (“End Users”) to download and/or view one or more Guides within our application (“Guidebook App”). This Privacy Policy applies to Personal Information that is Processed by Guidebook in the course of our business, including on Guidebook websites (each a “Site”), the Guidebook App, forums, blogs, and our related online and offline offerings (collectively, the “Services”).

3. Personal Information We Collect

Guidebook Customers

  • If you are a Guidebook Customer, you may provide Personal Information when you register with us through the Services to create and manage Guides, such as your name, company name, email address, and payment information such as billing address and credit card information.

End Users

  • When you download or use the Guidebook App, any Guide published there or elsewhere, and/or use a Guide through the Services, you may choose to provide Personal Information for your registration and/or profile as follows:
    • Name, email, photo/profile image, company, position/title, gender, phone number, and/or website (“Profile Information”).
    • Linked social media accounts such as Facebook, Twitter, Google+ and LinkedIn (“Social Information”).
  • When you create an account with us, you may choose to login using certain social media accounts (e.g., Facebook, LinkedIn, Twitter, etc.). If you choose to login using your social media account, we will collect the login identifier and other information you have made available via your social media account’s privacy settings (“Social Logins”).
  • We collect your Mobile ID when you download the Guidebook App or a branded Guide app.
  • If you enable location services on your device for the Guidebook App, we will collect information about your location when you use the Guidebook App.
  • You may send messages to other End Users or connect with them, in which case we will collect records and data reflecting your interactions with the other users.
  • You may be asked, but not required, to complete surveys about your use of the Services. Note that this information is treated like Profile Information for purposes of this Policy.

Visitors

  • This Section describes the information that we may collect from visitors. To the extent you are a Guidebook Customer or an End User and visit or use the Services, this Section will apply to you as well:
    • If you contact us by email or by filling-out a registration form, we may keep a record of information you provide, such as contact information and correspondence.
    • We will collect Usage Information reflecting your behavior on the Services.
    • We may use session and persistent cookies, both first-party and third-party, to collect information about your visits to the Services.

Interactive Features. We may offer interactive features such as review forums, blogs, commenting functionality, chat and messaging services, and social media pages. We and others who use our Services may collect the information you submit or make available through these interactive features. Any content you provide on the public sections of these features will be considered “public” and is not subject to the privacy protections referenced herein. By using these interactive features, you assume the risk that the Personal Information provided by you may be viewed and used by third parties for their own purposes.

Conferences, Trade Shows, and Other Events. We may attend conferences, trade shows, and other events where we collect Personal Information from individuals who interact with or express an interest in Guidebook and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.

Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, Technologies including cookie identifiers, mobile advertising and other unique identifiers, mobile carrier, details about your browser, operating system or device, location information (including inferred location based off of your IP address), Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.

Cookies and Pixel Tags/Web Beacons. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your device that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

  • Cookies. Cookies are small text files placed in device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about engagement on the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access our Services through a Third-Party application, such as an App Store or SNS, we may collect information about you from that Third-Party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, sex, birth date, email, profile picture, and your contacts on the SNS. This supplemental information allows us to verify information that you have provided to Guidebook and to enhance our ability to provide you with information about our business, products, and Services.

4. How Guidebook Uses Your Information

We use your Personal Information for a variety of business purposes, including:

Guidebook Customers

  • We use your Personal Information to provide and improve the Services, process payments, complete your transactions, administer your inquiries, and contact you regarding account activities, new version and product offerings, or other communications relevant to the Services.
  • If you interact with End Users through a Guide, for example by sending notifications or other information to them, we keep records of such messaging on our servers and use it in the operation of the Services.
  • Your Guide may be accessible via search engines or similar services. You can keep your Guide private by adjusting your privacy settings.
  • You Content will be visible to any End Users who download the applicable Guide, and Guidebook does not control the use or dissemination of Content in such cases by End Users, Visitors, or any third party. You are solely responsible for obtaining the consent of any data subjects whose Personal Information might be reflected in a Guide you create using the Services.

End Users

  • We use your Personal Information to provide and improve the Services.
  • We use Profile Information and Social information to populate a profile that is visible to other users of the Services. If you do not want other End Users to see this information, you should not input it into the Services. Guidebook cannot and does not control the actions taken by other End Users with information they can access through the Services.
  • When you use or interact with a Guide, your Personal Information, including Usage Information, may be disclosed to the Guidebook Customer who created the Guide (“Guide Creator”). This may occur through the Guidebook App or another branded app powered by Guidebook. In some cases, Guide Creators may also export the Personal Information you provide them off of the Guidebook App. Please note that once a Guide Creator has received your Personal Information, your Personal Information will also be subject to that Guide Creator’s privacy policy. Guide Creators may use your Personal Information for any number of purposes, including to provide online advertising on a Guide and to send you information that they believe may be useful, relevant, or otherwise of interest to you. Guidebook is not responsible for the privacy practices or policies of Guide Creators or the content of their advertisements. Guidebook does not restrict or control the use of Personal information about End Users by Guide Creators, who may share your Personal Information with, for example, event sponsors. You should contact the applicable Guide Creator if you have questions about how they use and share your Personal Information. Interacting with each Guide is at your own risk.
  • If you allow another End User to scan your QR Code, you will receive an “in-app connection” from that End User and your first and last name will be visible to them. If you accept the End User’s in-app connection request, they will be able to view the Personal Information you have made available in your Guidebook profile such as your email address, phone number, company, website, and social media profiles.
  • If you register for an event and/or have your QR code scanned or otherwise check-in using your Personal Information, Guidebook will share your Personal Information with the Guidebook Customer associated with the event.
  • We use your location, if available, to tailor the Services to you and offer you more relevant information about your Guide, event, location, or other nearby users.
  • We use information about your interactions with other End Users or Guide authors to operate and improve the services, deliver communications between you, and/or notify you that you have relevant information available to you to review within the Guide or Guidebook App.
  • We use your Personal Information to communicate relevant information to you about the Services, your Guide, or the Guidebook App via email, to authenticate your access to the account (including by using Social Logins to authenticate your login to our own Guidebook App).
  • It is possible that, because of the nature of the Guide you download using the Guidebook App or otherwise, certain potentially-sensitive information about you may be logged on our systems – for example: you download a guide relating to transgender advocacy or diabetes treatment.
  • End Users can send a request to privacy@guidebook.com to request that their Personal Information be deleted from our systems and not further shared with Guidebook Customers or other third parties. Note that this may require that you delete your Guidebook account and/or cease using one or more Guides.

Visitors

  • We may use information you input into a registration form or support contact to respond to your inquiries. In addition, we may use such details to send you information regarding the Site and/or the Services.
  • We use Usage Information so that we can improve the Site, optimize its performance, and learn which parts are most popular to Visitors.

Administrative Purposes for all Personal Information collected, such as:

  • Pursuing legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
  • Measuring interest and engagement in our Services;
  • Improving the Services;
  • Developing new products and services;
  • Ensuring internal quality control and safety;
  • Authenticating and verifying individual identities;
  • Carrying out audits;
  • Communicating with you about your account, activities on our Services and Privacy Policy changes;
  • Preventing and prosecuting potentially prohibited or illegal activities;
  • Enforcing our agreements; and
  • Complying with our legal obligations.

Payment Processing. Any payments made via the Services are processed by Stripe and we do not directly collect, store, or maintain any payment card information provided. You can read Stripe’s Privacy Policy at: https://stripe.com/privacy.

Marketing Guidebook Products and Services. We may use Personal Information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
If you have any questions about our marketing practices or if you would like to opt out of the use of your Personal Information for marketing purposes, you may contact us at any time as set forth below.

Consent. We may use Personal Information for other purposes that are clearly disclosed to you at the time you provide Personal Information or with your consent.

De-Identified and Aggregated Information Use. Guidebook may use Personal Information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access the Services, or other analyses we create. De-identified and/or aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. De-identified and/or aggregated information is not Personal Information, and Guidebook may use and share such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

Sharing Content with Friends or Colleagues. Guidebook’s Services may offer various tools and functionalities. For example, Guidebook allows you to provide information about your friends through our collaboration and invitation tools, which allow you to invite your friend or colleague to use our Services via email.

How We Use Automatic Collection Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. Our uses of these Technologies fall into the following general categories:

  • Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security;
  • Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed a link, or to improve our website content, applications, services, or tools;
  • Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into our sites;
  • Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

If you would like to opt out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

Social Media Widgets: Our Website includes social media features such as the Facebook “Share” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.

Analytics. Guidebook uses third party analytics tools to review and analyze your behavior using a Guide, the Guidebook App, or the Site to help us operate, maintain and improve our products and services.

Google Analytics. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/.

User ID. In addition to our standard use of Google Analytics, Guidebook also uses the Google Analytics’ User-ID feature to create persistent IDs that are linked to Google Analytics’ cookie identifiers and may be synced with your email address and other information we have collected about you. To be clear, this will allow Guidebook to sync Google Analytics’ cookie identifiers and related Site navigation, Site event interaction, and other session information with Personal Information (i.e., your email address and related information). Note that you must be logged in to your Guidebook account in order for the User ID feature to work.

Guidebook may use this information to better understand your preferences, how you use the Services, and the products or services which you may be interested in.

In addition, Guidebook uses the User ID feature to enable the following Google Analytics Advertising Features: Remarketing with Google Analytics, Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting, and integrated services that require Google Analytics to collect data for advertising purposes, including via cookies and identifiers.

You can find more information on Google Analytics’ User-ID by going to: https://support.google.com/analytics/answer/3123662?hl=en&ref_topic=3123660. You may opt-out of Guidebook’s use of User-ID feature by following the instructions at: http://tools.google.com/dlpage/gaoptout.

If you have any questions about Guidebook’s use of User ID, please email us at privacy@guidebook.com.

5. How Guidebook Discloses Your Information

We may share your information as described in this Privacy Policy (e.g., with our Third-Party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission.

Service Providers. We may share Personal Information with our third party service providers, such as hosting companies, security auditors, or analytics providers, to help us provide, analyze and improve our Services.

Affiliates. We may share Personal Information with Guidebook’s affiliated entities.

Business Partners. We may provide Personal Information to business partners to provide you with a product or service you have requested. We may also provide Personal Information to business partners with whom we jointly offer products or services.

Privacy Shield. With respect to onward transfers to agents under Privacy Shield, Privacy Shield requires that Guidebook remain liable should its agents process Personal Information in a manner inconsistent with the Privacy Shield Principles.

Information Displayed to Other Users. Your profile and activities on the Services may be visible on the Services to other End Users and Guide Creators. We are not responsible for privacy practices of the other End Users and/or Guide Creators who view and use your Personal Information.

Advertising Partners. Through our Services, Guidebook may allow third-party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.

APIs and Software Development Kits. We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including advertising partners to collect your Personal Information in order to provide content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.

Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). Guidebook may share information in its possession with government and law enforcement officials and private parties to enforce and comply with the law. We will access, preserve and disclose any Personal Information collected from Guidebook Customers, End Users and Visitors to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Guidebook or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

Merger, Sale, or Other Asset Transfers. Guidebook may sell, transfer or otherwise share some or all of its assets, including your Personal Information collected from Guidebook Customers, End Users and Visitors, in connection with a capital financing, merger, acquisition, financing due diligence, reorganization, sale of assets, bankruptcy, receivership, or transition of service to another provider. The use of your Personal Information following any of the foregoing events should be governed by the provisions of this Privacy Policy in effect at the time such Personal Information was collected.

International Data Transfers

All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

Privacy Shield

Guidebook complies with the requirements of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively “Privacy Shield”), as set forth by the U.S. Department of Commerce and the Federal Trade Commission (“FTC”), regarding the collection, use, and retention of Personal Information transferred from the European Economic Area and Switzerland to the United States. Guidebook has certified to the Department of Commerce that it adheres to the Privacy Shield Principles and Supplemental Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Guidebook’s certification, please visit https:// www.privacyshield.gov. Additionally, Guidebook may protect information through other legally valid methods, including international data transfer agreements.

6. Your Choices

1. General

You may have the right to object to and opt out of certain uses and disclosures of your Personal Information.

2. Email and Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Guidebook and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

3. Mobile devices

Guidebook may occasionally send you push notifications through the Guidebook App. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. With your consent, Guidebook may also collect precise location information if you use the Guidebook App. You may opt out of this collection by changing the settings on your mobile device.

4. “Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

5. Cookies and Interest-Based Advertising

You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions here: https://www.networkadvertising.org/mobile-choice The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these websites and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. Please note you must separately opt out in each browser and on each device.

7. Your Privacy Rights

For purposes of the California Consumer Privacy Act, we do not “sell” your Personal Information. In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed Personal Information; (vi) withdraw your consent and (vii) request erasure of Personal Information held about you by us, subject to certain exceptions prescribed by law. Such requests should be sent by email to privacy@guidebook.com or by regular mail to:

Guidebook Inc.
Attn: Security Department
340 Bryant Street, Suite 400
San Francisco, CA 94107

Please include your full name, email address associated with your account, and a detailed description of your data request. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

If you are a California resident, you have the right not to receive discriminatory treatment by Guidebook for the exercise of your rights conferred by the California Consumer Privacy Act

8. Data Retention

Guidebook retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

9. Security of Your Information

Guidebook is very concerned with safeguarding your information. We employ commercially reasonable administrative, physical and electronic measures designed to protect Personal Information. Unfortunately, no transmission of information over the Internet can be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

We encrypt transmissions through our Services, including transmission of Personal Information, with Transport Layer Security (TLS), a cryptographic protocol recognized in the software industry as a reasonable secure method of internet transmission. In addition, our cloud service providers implement industry standard security measures to protect your Personal Information when in storage and/or at rest.

Your payment information, subject to any changes to our third-party payment processor’s operations, is secured according the Payment Card industry Data Security Standards, Level 1.

Our employees are provided with context-specific access to our systems and your Personal Information, and are subject to contractual obligations to access and use your Personal Information only as required to deliver Services to you.

Any changes to the security of Personal Information are reviewed and approved by Guidebook management.

By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services or sending an e-mail to you. You may have a legal right to receive this notice in writing.

10. Third Party Websites/Applications

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

11. Children’s Information

Our Services are not directed to children under 13 (or other age as required by local law). You are not permitted to use our Services if you do not meet the minimum age requirement applicable to our Services in your jurisdiction. We do not knowingly collect Personal Information from children. If you learn that your child has provided us with Personal Information without your consent, you may alert us at privacy@guidebook.com. If we learn that we have collected Personal Information of a child, we will take steps to delete such information from our files as soon as possible and terminate the child’s account.

12. Supervisory Authority and Privacy Shield Redress

Supervisory Authority. If you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your Personal Information violates applicable law.

Privacy Shield. If you are a citizen of the European Union and/or Switzerland and feel that Guidebook is not abiding by the terms of this Policy, or is not in compliance with the Privacy Shield principles, you may contact Guidebook using the information provided below. In addition, Guidebook has agreed to refer unresolved complaints related to Personal Information to JAMS Privacy Shield Program. For more information and to submit a complaint regarding Personal Information to JAMS, a dispute resolution provider which has locations in the United States, visit https://www.jamsadr.com/eu-us-privacy-shield. Such independent dispute resolution mechanisms are available to citizens free of charge. If any request remains unresolved, you may contact the national data protection authority for your EU Member State. You may also have a right, under certain conditions, to invoke binding arbitration under Privacy Shield; for additional information, see https://www.privacyshield.gov/article?id=ANNEX-I-introduction. The FTC has jurisdiction over Guidebook’s compliance with the Privacy Shield.

13. Changes to Our Privacy Policy

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

14. Contact Guidebook

If you have any questions about or suggestions for improving this Privacy Policy, please contact us at privacy@guidebook.com or by mail at: Guidebook Inc.
Attn: Security Department
340 Bryant Street, Suite 400
San Francisco, CA 94107

15. Revision History

Initial Posting: April 25, 2011
Effective Date: December 25, 2019
Last Updated Date: January 1, 2020

16. Definitions

The following capitalized terms shall have the meanings set forth below.

“Mobile ID” means a unique, proprietary alphanumeric tag we create specifically to reflect your mobile device on our systems as a part of operating the Services, which is not known to any third party and is generated by a proprietary method we keep confidential.

“Personal Information” is any information relating to an identified or identifiable natural person where such information is considered “personal data” and/or “personal information” under applicable data protection law. Personal Information does not included information that has been aggregated and/or de-identified.

“Usage Information” is information reflecting usage of our Services through a web browser or mobile application, such as browser type, operating system version, click behavior, connection speed.