Privacy Policy
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Last updated

November 04, 2023

II. Our Collection and Use of Personal Information

We collect personal information in a variety of ways. For example, you may provide us your personal information when you register for an account or contact us.
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Personal Information Collected from You

We may collect the following categories personal information submitted to us by individuals through the Services:

• Contact Information, including first and last name, business email address, business postal address, employer, job title, your area of responsibility, company name, phone number, your country or region and communication preferences. We use this information to fulfill your request or transaction, to communicate with you directly and to enhance the services we offer to our users and to manage and grow our organization.
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• Account Information, including business email address, user ID and password. We use this information to provide access to our Webapp and administer your account, provide you with the relevant service and information, for customer support purposes and to diagnose or fix technology problems and to maintain the safety, security and integrity of our property and Services, technology assets and business.
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• Inquiry and Communications Information, including information provided in custom messages sent through our online forms or to our email address, such as to request a demo or submit a testimonial. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.
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• Feedback Information. We may also collect feedback and ratings you provide relating to our services or products. We use this information to communicate with you, to conduct market research, inform our marketing and advertising activities and improve and grow our business.
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• Business Representative Contact Information. If you are a business representative, we collect your information in connection with the performance of the agreement or potential agreement with us. This information may include your first name, last name, company contact information (e.g., email, phone, address), job title, and any other information related to the performance of the agreement with us.

Personal Information Automatically Collected

As is true of many digital properties, we and our third-party partners may automatically collect certain information from or in connection with your device when visiting or interacting with our Services, such data includes:

• Log Data, including internet protocol (IP) address, operating system, device type and version, browser type and version, browser id, the URL entered and the referring page/campaign, date/time of visit, other user agent string data, the time spent on our Services, and any errors that may occur during the visit to our Services. 
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• Analytics Data, including the electronic path you take to our Services, through our Services and when exiting our Services, UTM source, as well as your usage and activity on our Services, such as the time zone, activity information (first and last active date and time), usage history (flows created, campaigns scheduled, emails opened, total log-ins) as well as the pages, links, objects, products and benefits you view, click or otherwise interact with. We may also analyze the interaction between you and your customer using our Services.
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• Location Data, such as general geographic location that we or our third-party providers may derive from your IP address.

Personal Information from Third Parties

We also obtain personal information from third parties; which we often combine with personal information we collect either automatically or directly from an individual.We may receive the same categories of personal information as described above from the following third parties:

• Social Media: When an individual interacts with our Services through various social media networks, such as when someone “Likes” us on Facebook or follows us or shares our content on Google, Twitter, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as improve our products. 
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• Service Providers: Our service providers that perform services solely on our behalf, such as marketing providers, collect personal information and often share some or all of this information with us. The information may include contact information, demographic information, payment information, information about your communications and related activities, and information about your orders. We may use this information to administer and facilitate our services, your orders, and our marketing activities.
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• Information We Receive from Authentication Services You Connect to our Service: Some parts of our Service may allow you to login through a third party social network or authentication service such as Facebook or Google. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, email address, and information on log-in date and time. The data we receive is dependent on that third party’s policies and your privacy settings on that third-party site. We use this information to grant access to our Webapp. We may also send you service-related emails or messages (e.g., account verification, purchase confirmation, customer support, changes, or updates to features of the Site, technical and security notices).

Additional Uses of Personal Information

We may use personal information we collect to:

• Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested and to process transactions, including providing you an online product demonstration; 
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• Manage our organization and its day-to-day operations;
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• Communicate with individuals, including via email and social media;
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• Request individuals to complete surveys about our organization, organizations we partner with, and Services;
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• For marketing and updates on products or services we think that you may be interested in (where applicable, we may send you marketing messages if you have given us your consent to do so or where we have relied on the soft opt-in rule);
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• Administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Services;
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• Process payment for our Services;
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• Facilitate customer benefits and services, including customer support through our command center services;
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• Identify and analyze how individuals use our Services;
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• Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
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• Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
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• Help maintain the safety, security and integrity of our property and Services, technology assets and business;
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• Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
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• Comply with contractual and legal obligations and requirements;
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• To fulfill any other purpose for which you provide personal information; and
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• For any other lawful purpose, or other purpose that you consent to.
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III. Our Disclosure of Personal Information

We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:
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• Your Employer / Company: If you interact with our Services through your employer or company, we may disclose your information to your employer or company, including another representative of your employer or company. 
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• Marketing Providers: We coordinate and share personal information with our marketing providers in order to communicate with individuals about the Services we make available.
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• Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, website hosting, infrastructure provisioning, IT services, analytics services, employment application-related services, payment processing services, and administrative services.
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• Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other websites and services, and across other devices. These parties may collect information directly from a browser or device when an individual visits our Services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Please see the Third-Party Data Collection and Online Advertising section.
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• Business Partners: From time to time, we may share personal data with our business partners or we may allow our business partners to collect your personal information. Our business partners will use your information for their own business and commercial purposes, including to send you any information about their products or services that we believe will be of interest to you.
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• Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
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• Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement: 
  
  - in connection with the establishment, exercise, or defense of legal claims; 
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  - to comply with laws or to respond to lawful requests and legal process;
   
  - to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
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  - to detect, suppress, or prevent fraud;
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  - to protect the health and safety of us and others; or 
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  - as otherwise required by applicable law.
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• With Your Consent or At Your Direction: We may disclose personal information about an individual to certain other third parties or publicly with their consent or at their direction. For example, with an individual’s consent or direction we may post their testimonial on our Sites or Service-related publications.
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• For any other lawful purpose, or other purpose that you consent to.
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IV. Third-Party Data Collection and Online Advertising

We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the Sites, AdID, and other similar information. If permitted by your device settings, they may also collect location data through GPS, Wi-Fi or other methods. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. 

Please see Online Ads of the Control Over Your Information section below, to learn how you can opt out of interest-based advertising.

We may engage in the following:
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• Social Media Platforms. We may display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, LinkedIn, and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks. 
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• Third Party Partners. We work with a variety of third-party partners to provide advertising services. For example, we use Google Analytics to recognize you and link the devices you use when you visit our Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s website, “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here: https://tools.google.com/dlpage/gaoptout/.
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We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.]

For more information about these practices and your choices regarding cookies, please see the Control Over Your Information section below.
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V. Control Over Your Information

You may control your information in the following ways:
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• Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices). 
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• Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at founders@subsets.com. We may not be able to modify or delete your information in all circumstances.
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• Online Ads: To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
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Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles. may control your information in the following ways:
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VI. Children’s Personal Information

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.
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VII. Links to Third-Party Websites or Services

Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.
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VIII. State-Specific Disclosures

• Nevada: If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Although we do not currently sell covered information, please contact us at founders@subsets.com with the subject line “Nevada Opt Out Request” to submit such a request.

IX. Updates to This Privacy Notice

We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
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X. Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to founders@subsets.com.

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