Privacy Policy

Last revised: November 14, 2023

Introduction

Zurple Inc. (“Company,” “Us,” “Our,” or “We”) respects Your privacy and is committed to protecting it through Our compliance with this Privacy Policy. Please read this Privacy Policy carefully to understand Our policies and practices regarding the Personal Information We collect from You, how We use it, how We share it, Your rights and choices, and how You can contact Us about Our privacy practices. To the extent that You are an End User or a Visitor, this Privacy Policy also outlines Your rights as a data subject, including the right to object to some uses of Your Personal Information by Us.

This Privacy Policy applies to Personal Information We collect about You from various sources, as further described in the “Personal Information We Collect and How We Collect It” section below.

Definitions

“Agent” means a real estate agent that has hired Us (a “Zurple Agent”) or one of Our corporate affiliates (an “Affiliate Agent”) as a service provider to find people such as Yourself to whom that real estate agent can offer its services.

“Agent Services” means (a) general home selling and purchasing advice, (b) information on market conditions, (c) information on availability of homes in the area, and (d) other information and requested services related to the consumer real estate market. Agent Services do not include anything that is covered by an agreement through which a real estate agent agrees to represent a buyer or seller of real estate.

“B2B Party” means a customer, supplier, vendor, or business partner (any of which can be a sole proprietorship or a formal legal entity) with whom We have a business relationship and who directly or indirectly provides Us with B2B Representative and/or End User Personal Information in connection with those B2B Representatives’ or End Users’ use of Our Services or otherwise.

“B2B Representative” refers to individuals who work for or on behalf of a B2B Party, or in the event that the B2B Party is a sole proprietorship, the B2B Representative is the sole proprietor.

“End User” means individuals who do business with, or otherwise interact with, a B2B Party but who are not doing business with Us directly.

“Personal Information” means any information that identifies or relates to an individual or can be used in conjunction with other information to identify an individual, whether such information is explicitly regulated by applicable law or otherwise.

“Processing” means any operation or set of operations which is performed on Personal Information, encompassing the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction or erasure of Personal Information. The terms “Process”, “Processes” and “Processed” will be construed accordingly.

“Service(s)” means the products and services that We offer.

“Visitor” means an individual that visits the Website or otherwise communicates with the Company and is not a B2B Representative or End User.

“Website” means any publicly accessible website hosted by or on behalf of the Company which is not part of a Service.

“You” and “Your” mean B2B Party, B2B Representative, End User, or Visitor, depending on the context as further explained in this Privacy Policy, and if there is no context which specifically identifies any of the foregoing, then “You” or “Your” means all of the foregoing collectively.

Scope, Generally (Controller vs. Processor)

Our Role as a Processor

Generally speaking and without regard to any particular definition under applicable law, We are a data processor (“Processor”) when We do not determine the purpose and means of Processing the Personal Data of B2B Representatives and End Users, and We only Process that Personal Information in accordance with the specific instructions of a B2B Party, as is the case when We Process Personal Information only as necessary to provide Our Services to a B2B Party. We receive instructions from B2B Parties through agreements We have with those B2B Parties, including any ancillary data privacy agreements or addenda (collectively a “B2B Agreement”). This Privacy Policy does not apply when We Process Personal Information as a Processor.

When You are a B2B Party and We act as a Processor with respect to the Personal Information that We receive from You or on Your behalf, You alone are responsible for providing appropriate privacy notices and disclosures to Your B2B Representatives and End Users with respect to Your Processing of their Personal Information.  You cannot rely on this Privacy Policy as a means for satisfying Your privacy notice and disclosure obligations.

When You are a B2B Representative or an End User and We act as a Processor with respect to Your Personal Information, the B2B Party with whom You have a relationship is responsible for providing appropriate notices and disclosures to You about how they Process Your Personal Information and You must refer to that B2B Party’s privacy policy or other notices for information regarding their privacy practices, Your rights, and how You exercise those rights.

Our Role as a Controller

Generally speaking, and without regard to any particular definition under applicable law, We are a data controller (“Controller”) when (i) We determine the purpose and means of Processing the Personal Information of B2B Representatives and End Users, as is the case when a B2B Party permits Us to Process that Personal Information in ways that relate to Our Services but are not strictly necessary in order to perform those Services, or (ii) We Process Personal Information at the specific direction of an End User as communicated to Us by a B2B Party.  This Privacy Policy only applies when We Process Personal Information as a Controller.

When You are a B2B Party and We act as a Controller with respect to the Personal Information that We receive from You or on Your behalf pursuant to a B2B Agreement, We are responsible for providing appropriate privacy notices and disclosures to Your B2B Representatives and End Users with respect to Our Processing of their Personal Information as a Controller.  However, pursuant to the B2B Agreement, You agree to comply with all applicable laws, including those which may require You to provide notice to or gain consent from Your B2B Representatives and End Users prior to giving Us permission to Process that Personal Information as a Controller.  Specifically, You and Your legal advisors should consider whether You need to list Us in Your privacy policy and notify Your End Users of Our privacy practices by linking to this Privacy Policy.

When You are a B2B Representative or an End User and We act as a Controller with respect to Your Personal Information, this Privacy Policy describes Our privacy practices, including the Personal Information We collect from You, how We use it, how We share it, Your rights and choices, and how You can contact Us about Our privacy practices.  However, as mentioned in the “Our Role as a Processor” section above, You must refer to the privacy notices and disclosures of the B2B Party with whom You have a relationship for more information regarding that B2B Party’s privacy practices, including any notices or disclosures with respect to that B2B Party’s transfer of Your Personal Data to Us for Our Processing as a Controller.

When You are a Visitor, We are a Controller with respect to Your Personal Information. We Process Your Personal Information in accordance with this Privacy Policy and any other agreement We may have directly with You.  This Privacy Policy describes Our privacy practices, including the Personal Information We collect from You, how We use it, how We share it, Your rights and choices, and how You can contact Us about Our privacy practices.

 

Part A: Information for All Individuals (subject to applicable law, where stated)

Personal Information We Collect and How We Collect It

For B2B Representatives

When You are a B2B Representative, We collect the following Personal Information about You from the following sources:

Categories and Types of Personal Information We Collect	Sources From Which We Collect Your Personal Information
Identifiers, including real name, postal address, online identifier, Internet Protocol address, email address, telephone number, or other similar identifiers.	·         From a B2B Party with whom You are employed or otherwise do business with. ·         From You directly when You provide it to Us through communication or otherwise. ·         From Your use of the Services ·         From Your use of Our Website, including collection via cookies and other automated data collection technologies. ·         From third-party vendors and data brokers.
Financial Information, including bank account number, credit card number, debit card number, or any other financial information that is NOT combined with any required login credentials; and insurance policy number.
Commercial information, including records of products or services purchased, obtained, or considered.
Internet or other similar network activity, including  information on Your interaction with Our website, including traffic data, location data, logs, and information about Your computer, internet connection, operating system and browser type.
Geolocation data, including imprecise physical location derived from IP address and/or wifi networks.

For End Users

When You are an End User, We collect the following Personal Information about You from the following sources:

Categories and Types of Personal Information We Collect	Sources From Which We Collect Your Personal Information
Identifiers, including real name, postal address, online identifier, Internet Protocol address, email address, telephone number, or other similar identifiers.	·         From a Zurple Agent at Your direction. ·         From You directly when You provide it to Us through communication or otherwise. ·         From third parties at Your direction such as from Our corporate affiliates, including Top Producer Software Inc., Top Producer Software Corp., and Market Leader Group Inc.
Commercial information, including records of services requested.
Inferences drawn from other personal information, including profile reflecting a person’s preferences.
Geolocation data, including imprecise physical location derived from IP address and/or wifi networks.

For Visitors

When You are a Visitor, We collect the following Personal Information about You from the following sources:

Categories and Types of Personal Information We Collect	Sources From Which We Collect Your Personal Information
Identifiers, including real name, postal address, online identifier, Internet Protocol address, email address, telephone number, or other similar identifiers.	·         From You directly when You provide it to Us through communication or otherwise. ·         From Our Service Providers. ·         From Your use of Our Website, including collection via cookies and other automated data collection technologies. ·         From third parties, such as Our corporate affiliates, third party vendors, and data brokers.
Internet or other similar network activity, including information on Your interaction with Our website, including traffic data, location data, logs, and information about Your computer, internet connection, operating system and browser type.
Geolocation data, including imprecise physical location derived from IP address and/or wifi networks.

How We Use and Disclose Your Personal Information

For B2B Representatives

When You are a B2B Representative, We Process Your Personal Information described below for the following purposes:

Categories and Types of Personal Information	Purpose for Processing
Identifiers, including real name, postal address, online identifier, Internet Protocol address, email address, telephone number, or other similar identifiers.	·         To answer Your questions and handle complaints. ·         To send You marketing messages or promotional materials. ·         Improving Our Services, analyzing Our performance, and learning about Your trends and interests, including trends related to Our marketing efforts to You. ·         Compliance and harm prevention. ·         Reducing fraud and enhancing security. ·         To connect End Users with another Agent that will provide those End Users with Agent Services that the End User originally requested from You.
Financial Information, including bank account number, credit card number, debit card number, or any other financial information that is NOT combined with any required login credentials; and insurance policy number	·         Processing payment for Services ·         Reducing fraud and enhancing security.
Commercial information, including records of products or services purchased.	·         To connect End Users with another Agent that will provide those End Users with Agent Services that the End User originally requested from You. ·         To assist You in responding and fulfilling consumer rights requests. ·         To supplement our customer records. ·         Improving Our Services, analyzing Our performance, and learning about Your trends and interests
Internet or other similar network activity, including  information on Your interaction with Our website, including traffic data, location data, logs, and information about Your computer, internet connection, operating system and browser type.	·         Debugging. ·         Improving Our Services, analyzing Our performance, and learning about Your trends and interests. ·         Analyzing trends with respect to: o    ad impressions for unique visitors; and o    verification of positioning and quality of ad impressions. ·         Reducing fraud and enhancing security.
Geolocation data, including imprecise physical location derived from IP address and/or wifi networks.	·         Providing Our Services to You. ·         Improving Our Services, analyzing Our performance, and learning about Your trends and interests. ·         Reducing fraud and enhancing security.

When You are a B2B Representative, We disclose Your Personal Information described below to the following categories of third-parties and for the following purposes:

Categories and Types of Personal Information	Purpose for Disclosing	Categories of Parties to Whom We Disclose the Information
Identifiers, including real name, postal address, online identifier, Internet Protocol address, email address, telephone number, or other similar identifiers.	·         So that Our sub-processor/sub-contractors/service providers, can perform services for Us, such as fulfilling orders; processing payments; marketing; and providing customer service, financing, IT, storage. ·         Improving the Services, analyzing Our performance, and learning about customer trends and interests. ·         Supplementing or verifying Our records. ·         Preventing fraud or harm to Us or others.	·         Our corporate affiliates ·         Service Providers/Vendors
Financial Information, including bank account number, credit card number, debit card number, or any other financial information that is NOT combined with any required login credentials; and insurance policy number.	·         So that Our sub-processor/sub-contractors/service providers, can perform services for Us, such as process payments and financing.	·         Service Providers/Vendors
Internet or other similar network activity, including information on Your interaction with Our website, including traffic data, location data, logs, and information about Your computer, internet connection, operating system and browser type.	·         Improving the Services, analyzing Our performance, and learning about customer trends and interests. ·         Preventing fraud or harm to Us or others.	·         Service Providers/Vendors

For End Users

When You are an End User, We Process Your Personal Information described below for the following purposes:

Categories and Types of Personal Information	Purpose for Processing
·         Identifiers, including real name, postal address, online identifier, Internet Protocol address, email address, telephone number, or other similar identifiers. ·         Commercial information, including records of products or services purchased. ·         Inferences drawn from other personal information, including profile reflecting a person’s preferences. ·	·         To connect You with an another Agent that will provide You the Agent Services You originally requested from either a Zurple Agent or an Affiliate Agent.
Identifiers, including real name, postal address, online identifier, Internet Protocol address, email address, telephone number, or other similar identifiers.	·         To contact You to confirm whether You are still interested in receiving the Agent Services You requested from a Zurple Agent.

When You are an End User, We disclose Your Personal Information described below to the following categories of third-parties and for the following purposes:

Categories and Types of Personal Information	Purpose for Disclosing	Categories of Parties to Whom We Disclose the Information
Identifiers, including real name, postal address, online identifier, Internet Protocol address, email address, telephone number, or other similar identifiers.	·         To connect You with another Zurple Agent or an Affiliate Agent who will provide You the Agent Services that You originally requested from a Zurple Agent.	·         Third Parties- Zurple Agents ·         Third Parties- Our corporate affiliates, specifically: Top Producer Software Inc., and Top Producer Software Corp. (Please refer to their privacy policy located at https://www.topproducer.com/privacy for information about their privacy practices), and   Market Leader Group, Inc. (Please refer to their privacy policy located at https://www.marketleader.com/privacy/ for information about their privacy practices.)
Commercial information, including records of products or services purchased.
Inferences drawn from other personal information, including profile reflecting a person’s preferences.	·         To allow the Agent who will provide the Agent Services You requested to better address Your needs.

For Visitors

When You are a Visitor, We Process Your Personal Information described below for the following purposes:

Categories and Types of Personal Information	Purpose for Processing
Identifiers, including real name, postal address, online identifier, Internet Protocol address, email address, telephone number, or other similar identifiers.	·         To communicate with You, including responding to questions or enforcing Your privacy rights. ·         To send You marketing and promotional material. ·         Improving Our Services and Website, analyzing Our performance, and learning about Your trends and interests. ·         Analyzing trends with respect to: o    ad impressions for unique visitors; and o    verification of positioning and quality of ad impressions.
Internet or other similar network activity, including information on Your interaction with Our website, including traffic data, location data, logs, and information about Your computer, internet connection, operating system and browser type.	·         Debugging. ·         Improving Our Services and Website, analyzing Our performance, and learning about Your trends and interests. ·         Analyzing trends with respect to: o    ad impressions for unique visitors; and o    verification of positioning and quality of ad impressions. ·         Reducing fraud and enhancing security.
Geolocation data, including imprecise physical location derived from IP address and/or wifi networks.	·         Providing Our Services to You. ·         Improving Our Services and analyzing Our performance. ·         Reducing fraud and enhancing security.

When You are a Visitor, We disclose Your Personal Information described below to the following categories of third-parties and for the following purposes:

Categories and Types of Personal Information	Purpose for Disclosing	Categories of Parties to Whom We Disclose the Information
Identifiers, including real name, postal address, online identifier, Internet Protocol address, email address, telephone number, or other similar identifiers.	·         Improving the Website and the Services, analyzing Our performance, and learning about customer trends and interests. ·         So that Our sub-processor/sub-contractors/service providers, can perform services for Us, such as marketing and customer support. ·         Analyzing trends with respect to: o    ad impressions for unique visitors; and o    verification of positioning and quality of ad impressions. ·         Preventing fraud or harm to Us or others.	·         Service Providers/Vendors
	·         To send You marketing and promotional material, pursuant to Your direction.	·         Third parties- Our corporate affiliates, specifically Top Producer Software Inc., Top Producer Software Corp.. and Market Leader Group, Inc.
Internet or other similar network activity, including information on Your interaction with Our website, including traffic data, location data, logs, and information about Your computer, internet connection, operating system and browser type.	·         Analyzing trends with respect to: o    ad impressions for unique visitors; and o    verification of positioning and quality of ad impressions. ·         Improving the Services and Website, analyzing Our performance, and learning about customer trends and interests.	·         Service Providers/Vendors
Geolocation data, including imprecise physical location derived from IP address and/or wifi networks.	·         Analyzing trends with respect to: o    ad impressions for unique visitors; and o    verification of positioning and quality of ad impressions. ·         Preventing fraud or harm to Us or others.	·         Service Providers/Vendors

Aggregated, Deidentified, and Anonymized Data

We create aggregated, deidentified, or anonymized data derived from Our use of Your Personal Information, and such data can be used by Us as permitted by applicable laws. We shall not attempt to re-identify the data.

Other Purposes for Processing and Disclosing Your Personal Information

We may also Process and disclose Your Personal Information:

• To competent public authority, government, regulatory or fiscal agency where it is necessary to comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or exercise Our rights under any agreement which governs Your relationship with Us, including Our rights under any such agreements that may be exercised for billing and collection purposes.
• If We believe disclosure is necessary or appropriate to protect Our rights, property, or safety, Our customers, or others. This may include the exchange of information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
• Subject to some restrictions under applicable laws, We may transfer, whether for consideration or otherwise, Your Personal Information as an asset that is part of a bankruptcy, merger, or other similar transaction involving all or any portion of Our business. Any such transfer does not affect Your rights under any applicable laws.

Information We Collect Through Automatic Data Collection Technologies 

As You navigate through and interact with Our Website, We may use automatic data collection technologies to collect certain information about Your equipment, browsing actions, and patterns, including:

• Details of Your visits to Our Website, 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.

The information We collect automatically does include Personal Information. It helps Us improve Our Website and deliver a better and more personalized experience, including by enabling Us to:

• Estimate Our audience size and usage patterns.
• Store information about Your preferences, allowing Us to customize Our Website according to Your individual interests.
• Speed up Your searches.
• Recognize You when You return to Our Website.

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. Our Website will issue cookies when You direct Your browser to Our Website, unless You refuse to accept browser cookies by activating the appropriate settings on Your browser or by communicating Your preferences to Us through Our cookie consent management interface. Please refer to the “Exercising Your Rights” section at the end of this Privacy Policy for more information on how your preferences can be changed or withdrawn. If You refuse to accept browser cookies You may be unable to access certain parts of Our Website or utilize certain functionality.
• 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).

Third-Party Use of Cookies and Other Tracking Technologies

Third parties may use cookies alone or in conjunction with web beacons 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, including Personal Information, about Your online activities over time and across different websites and other online services.  However, those third parties may only collect and use this information in their capacity as Our service provider for the purposes of improving Our Services and helping Us better understand and market Our Services to You.

International Data Transfers

In order to carry out the Processing activities described above, We may make use of subcontractors that act on Our behalf as Processors. These subcontractors will be contractually obligated by Us to Process Your Personal Information only in accordance with Our instructions, only for the purposes described above, and only for the period of time necessary to preform those purposes.

In some cases, these subcontractors may be located outside of the data privacy jurisdiction in which You reside.  In the event such international data transfers are necessary, We will take the necessary organizational, technical and contractual measures to ensure the protection of Your Personal Information. In certain situations, We may be required to disclose Personal Information in response to lawful requests from law enforcement and national security authorities of that jurisdiction.

For questions or comments about our practices with respect to international data transfers, please refer to the “Contact Information” section at the end of this Privacy Policy.

Consequences of Not Providing Your Personal Information

Personal Information gathered by Us for the purposes defined in this Privacy Policy may be required by Us, either directly or indirectly, in order for Us maintain a relationship with You; therefore, Your failure to provide Us with Your Personal Information may negatively affect Our ability to:

• Provide Services to You and fulfill Our contractual obligations with You;
• Fulfill legal requirements;
• Enter into a contract with related parties and continuing to contract with those related parties; or
• Maintain contact with You.

Data Security and Storage

We have implemented technical, administrative, and physical security measures that are designed to protect Your Personal Information from unauthorized access, disclosure, use, and modification. Such measures include the encryption of sensitive information. We regularly review Our security procedures to consider appropriate new technology and methods. Even so, please be aware that no security measure is perfect. Thus, We cannot guarantee the security of Your Personal information at all times. You should always be vigilant when it comes to the protection of Your Personal Information.

Retention Period

Subject to any opt-out rights You may have and all applicable laws, We retain Your Personal Information for only as long as reasonably necessary to carry out the purposes for which We originally collected it, as set forth in this Privacy Policy.  Notwithstanding the foregoing, we may continue to retain Your Personal Information to comply with our legal and regulatory obligations; to enable fraud monitoring, detection and loss prevention activities; to comply with our tax, accounting, and financial reporting obligations; and where required by our contractual commitments to third-parties.  The retention period may also depend on the terms of any B2B Agreement we have with a B2B Party.

Children Under the Age of 16

Our Website and Services are not intended for children under 16 years of age. You may not knowingly or unknowingly provide Us Personal Information of minors under 16 years of age through Your use of the Website or Services. We do not knowingly collect Personal Information from children under 16. We do not sell or share Personal Information of children under age 16. No one under age 16 may provide any Personal Information to Us.  If You are under 16, do not use or provide any Personal Information on Our Website or through Our Services. If We learn We have collected or received Personal Information from a child under 16 without verification of parental consent, We will delete that information. If You believe We might have any information from or about a child under 16, please contact Us using the Contact Information provided at the end of this Privacy Policy.

Your Privacy Rights

Depending on Your location and subject to applicable law and certain other limitations, You may have the rights set forth below with respect to Your Personal Information.  To exercise any of the following rights, please refer to the “Exercising Your Rights” section at the end of this Privacy Policy.

Right to Know and Data Portability. You have a right to request additional information about the categories of Personal Information collected, sold, disclosed, or shared; purposes for which this Personal Information was collected, sold, disclosed, or shared; categories of sources of Personal Information; and categories of third parties with whom We disclosed or shared this Personal Information. You have a right to receive this information in a portable and, to the extent technically feasible, in a readily useable format that allows You to transmit this information to another entity without hindrance.

Right to Opt-Out of Our Sale of Your Personal Information. To the extent that the “Sale of Personal Information” section below indicates that We sell Your Personal Information, You have a right to opt-out of those sales.

Right to Opt-Out of Our Sharing or Use of Your Personal Information for Targeted Advertising or Cross-Context Behavioral Advertising. To the extent that the “Targeted Advertising / Cross-Context Behavioral Advertising” section below indicates that We share or use Your Personal Information for either of those activities, You have a right to opt-out of those activities.

Right to Withdraw Consent to Use Sensitive Personal Information. To the extent that the “Personal Information We Collect and How We Collect It” section above indicates that We use Your Sensitive Personal Information, You have a right to withdraw Your consent to allow Us to use that Sensitive Personal Information.

Right to Deletion. You have the right to request the deletion of Your Personal Information, subject to certain limitations.

Right to Correct. You have the right to request the correction of any inaccuracies in the Personal Information We hold about You, subject to certain limitations.

Right to Non-Discrimination. We will not discriminate against You for exercising any of Your rights identified in this section of the Privacy Policy.  For example, charge You a different price, or provide a different level or quality of goods or services just because You exercised Your rights under this section of the Privacy Policy; however, We may offer You financial incentives that can result in different prices, rates, or quality levels, provided that (i) You provide Your revocable, opt-in consent to participate in such financial incentive programs, (ii) the financial incentives reasonably relate to the value of Your Personal Information, and (iii) We provide written terms that describe the program’s material aspects.  Furthermore, there may be situations where Your Personal Information is required by Us, either directly or indirectly, in order for Us maintain a relationship with You.  Please refer to the “Consequences of Not Providing Your Personal Information” section in Part A of this Privacy Policy for more information.

Right to Appeal.  You have the right to appeal any decision made by a Us regarding Your privacy rights identified in this section.

As a reminder, when You are a B2B Representative or an End User and We act as a Processor with respect to Your Personal Information, the B2B Party with whom You have a relationship is responsible for providing appropriate notices and disclosures to You about how they Process Your Personal Information and You must refer to that B2B Party’s privacy policy or other notices for information regarding their privacy practices, Your rights, and how You exercise those rights.

 

Part B: Additional Information for Residents of Particular Jurisdictions

Information for Residents of All “US Privacy Law States” (as hereinafter defined)

If You are a resident of California, Colorado, Connecticut, Utah, and Virginia (each a “US Privacy Law State”), We Process Your Personal Information in accordance with the state privacy law that is applicable in Your US Privacy Law State, which is one of the following:

• In California: the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (the “CCPA”);
• In Colorado: the Colorado Privacy Act (the “CoPA”);
• In Connecticut: the Connecticut Personal Data Privacy and Online Monitoring Act (the “CPDP”);
• In Utah: the Utah Consumer Privacy Act, which goes into effect on December 31, 2023 (the “UCPA”); and
• In Virginia: the Virginia Consumer Data Protection Act (the “VCDPA”).

If You are a resident of any one of the US Privacy Law States, then this “Information for Residents of All US Privacy Law States” section discloses Our privacy practices and Your rights as a resident of any one of those US Privacy Law States.  The disclosures in this section are in addition to those disclosures set forth in (i) Part A of this Privacy Policy, and (ii) for California residents, the “Supplemental Information for California Residents” section of this Privacy Policy below.  To the extent that anything in Part B of this Privacy Policy conflicts with anything in Part A of this Privacy Policy, the conflicting content in Part B shall take precedence.

Sale of Personal Information

We do not sell Your Personal Information.

A transfer, whether for consideration or otherwise, of Your Personal Information as an asset that is part of a bankruptcy, merger, or other similar transaction involving all or any portion of Our business is not a “sale” under the laws of US Privacy Law States.

Targeted Advertising / Cross-Context Behavioral Advertising

Generally speaking, “targeted advertising” and “cross-context behavioral advertising” are defined under the applicable laws of US Privacy Law States as the display of an advertisement to You based on Personal Information about You obtained or inferred over time from Your activities across nonaffiliate websites, applications, or online applications.

We do not share Your Personal Information with third parties for targeted advertising or cross-context behavioral advertising. Additionally, We do not Process Personal Information for Our own targeted advertising or cross-context behavioral advertising purposes.

 

Supplemental Information for California Residents

This “Supplemental Information for California Residents” section applies to natural persons who are California residents.  If You are a consumer located in California, We Process Your Personal Information in accordance with the CCPA.  The disclosures in this section are in addition to those in (i) Part A of this Privacy Policy and (ii) the “Information for Residents of All US Privacy Law States” section of Part B of this Privacy Policy.  To the extent that anything in the preceding items (i) or (ii) conflicts with anything in this “Supplemental Information for California Residents” section, the conflicting content in this section shall take precedence.

Notice at Collection

Categories of Personal Information We Collect. The categories of Personal Information We may collect and have collected about You in the preceding 12 months, including any Sensitive Personal Information where applicable, along with the sources from which We collected that Personal Information, are identified in the “Personal Information We Collect and How We Collect It” section of this Privacy Policy.

Business Purposes for Collection and Use of Personal Information. The business purposes for which We collect, use, and disclose Your Personal Information, along with the categories of third-parties to whom We disclose that Personal Information, are identified in the “How We Use and Disclose Your Personal Information” section of this Privacy Policy.

Commercial Purposes for Collection and Use of Personal Information (Sale and Sharing). We neither sell Your Personal Information nor share it with third parties for cross-context behavioral advertising.

Retention Period of Personal Information. We retain Your Personal Information as set forth in the “Retention Period” section of this Privacy Policy.

Sensitive Personal Information

We do not Process Your “sensitive” Personal Information, as that term is defined by the CCPA.

California Shine the Light Law

You may ask Us to provide You with a list of the types of Personal Information that We have disclosed during the preceding year to third parties for their direct marketing purposes, and the identity of those third parties. If You are a California resident and would like such a list, please refer to the “Exercising Your Rights” section at the end of this Privacy Policy.

Notice of Financial Incentives

We do not offer any financial incentive in exchange for the collection of Your Personal Information.

Your CCPA Rights

As an individual residing in California, You have the rights identified in the “Your Rights as a Resident of a US Privacy Law State” section of this Privacy Policy with respect Our use and disclosure of Your Personal Information.

In addition to those rights, if the “Sensitive Personal Information” section above indicates that We Process Your Sensitive Personal Information for the purpose of inferring characteristics about You, You have the right to limit that particular use of Your Sensitive Personal Information as set forth in Section 1798.121 of the CCPA.

To exercise any of these rights, please refer to the “Exercising Your Rights” section at the end of this Privacy Policy.

Information for Nevada Residents

This “Information for Nevada Residents” section applies to residents of Nevada.  If You are a resident of Nevada, We Process Your Personal Information in accordance with the “Nevada Privacy of Information Collected on the Internet from Consumers Act.”  The disclosures in Part A of this Privacy Policy also apply to residents of Nevada, except in the event that anything in this section conflicts with the sections above, in which case this section shall take precedence.  For the sake of clarity, the disclosures in the “Information for Residents of All US Privacy Law States” do not apply to residents of Nevada.

Nevada residents have the right to request that We do not sell certain Personal Information to select third parties for monetary consideration, even if their Personal Information is not currently being sold.  To exercise this right, please refer to the “Exercising Your Rights” section at the end of this Privacy Policy.

Information for Canadian Residents

This “Information for Canadian Residents” section applies to residents of Canada. If You are a resident of Canada, We Process Your Personal Information in accordance with the “Personal Information Protection and Electronic Documents Act (“PIPEDA”),” along with any applicable provincial private sector privacy legislation that is substantially similar to PIPEDA. The disclosures in Part A of this Privacy Policy also apply to residents of Canada, except in the event that anything in this section conflicts with Part A of this Privacy Policy, in which case this section shall take precedence.

By engaging with the Website or taking other actions which indicate Your acceptance of Our Terms of Use, You consent to Our use and disclosure of Your Personal Information as indicated in this Privacy Policy. At any time You may “opt-out” or withdraw Your consent to allow Us to Process of Your Personal Information, subject to legal or contractual restrictions and reasonable notice. However, please see the “Consequences of Not Providing Your Personal Information” section above for the possible implications of withdrawing Your consent.

If the disclosures provided in the “How We Use and Disclose Your Personal Information” indicate that We Process Your Personal Information for marketing purposes, You may opt-out of the Processing of Your Personal Information for this purpose. Additionally, to the extent that the “Targeted Advertising / Cross-Context Behavioral Advertising” section above indicates that We share or use Your Personal Information for either of those activities, You may opt-out of this Processing.

To exercise any opt-out rights you have under this “Information for Canadian Residents” Section, please refer to the “Exercising Your Rights” Section at the end of this Privacy Policy.

We have procedures in place to receive and respond to complaints or inquiries about Our handling of Personal Information, Our compliance with this Privacy Policy, and Our compliance with applicable privacy laws. To submit any such compliant or inquiry, please contact our Privacy Officer using the contact information provided in the “Contact Information” section below.

 

Changes to Our Privacy Policy

We reserve the right to amend this Privacy Policy at Our discretion and at any time. When We make changes to this Privacy Policy, We will post the updated Privacy Policy on the Website and update the Privacy Policy’s effective date. The date the Privacy Policy was last revised is identified at the top of the page. If You would like Us to notify You of any changes to this Privacy Policy, You must ensure We have an up-to-date, active, and deliverable email address for You; otherwise, You are responsible for periodically visiting Our Website and this Privacy Policy to check for any changes.

Exercising Your Rights

The following methods are available to send Us a request to exercise Your rights defined in this Privacy Policy or that You are otherwise entitled to under applicable law:

• Send an email with the subject line “Data Privacy Request” to: ccpa@zurple.com
• Browse to Our Data Privacy Request form which is located here: https://privacy-central.securiti.ai/#/dsr/766856a1-0267-48f8-8137-cfa120541afa
• Write Us at:

Zurple Group Inc.

Attn: Data Privacy Request

10045 Mesa Rim Rd, Suite 3

San Diego, CA 92121

Not all of Your rights can be exercised through each individual method.  In some cases, You may need to utilize more than one method to exercise all of Your rights.  If You have any doubt as to whether a particular method is effective with respect to a particular right, please contact Us using the email method specified above.

All requests must provide sufficient information for Us to be able to verify You are the person whose Personal Information We hold.  Whenever possible, You must describe Your request in enough detail so that We can properly locate the Personal Information related to the request. We cannot respond Your request unless We can verify Your identity and locate Your Personal Information. You may designate, in writing or through a power of attorney, an authorized agent to make requests on Your behalf by contacting Us using the same methods. We may still require You to directly verify Your identity and confirm that You provided the authorized agent permission to submit the request.

Contact Information

To ask questions, or comment about this Privacy Policy and Our privacy practices, or for any other privacy-related inquiries, please:

Email Us at privacy@csiperseus.com

Write Us at the following postal address:

Zurple Inc. c/o Perseus Management Group

Attn: Privacy Officer

11350 McCormick Rd, EP 3, Suite 200

Hunt Valley, MS 21031

 

 

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