Privacy Policy

Information You Provide to Us

The information you provide to us through the Services or otherwise may include:

• Business contact information, such as your first and last name, e-mail and mailing addresses, phone number, professional title and company name.
• Information that you provide by filling in forms on our Services, including information provided at the time of registering to use our Services, subscribing to our service, posting material, or requesting further services.
• Information to be published or displayed on public areas of the Services, or transmitted to other users of the Services or third parties (collectively, “User Contributions”).
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Services and of the fulfillment of your orders. Financial information may be required before placing orders.
• Your search queries on the Services.
• Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information We Obtain From Other Third Parties

We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your personal information from other third parties, such as marketing partners and publicly available sources.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Services, 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 Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Services.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical data and may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Services according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Services.

Technologies Used for Automatic Data Collection

• Cookies (or browser cookies). A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.
• Flash Cookies. Certain features of our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Services. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see the “Your Choices” section below.
• Web Beacons. Pages of our Services and our e-mails 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).

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at time of collection:

• To provide, operate and improve our Services and its contents.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your subscription, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Services or any products or services we offer or provide though it.
• To allow you to participate in interactive features on our Services.
• To send you marketing and promotional communications.
• To display advertisements delivered by advertising partners, which may be targeted based on your use of the Services or your activity elsewhere online.
• To comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
• To disclose to law enforcement, government authorities and private parties as necessary or appropriate to protect our, your or others' rights, privacy, safety or property; enforce terms and conditions governing the Services; and protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
• For any other purpose with your consent.
• To create anonymous data by removing information that makes the data personally identifiable with you.

We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business.
• To professional advisors where necessary in the course of the professional services rendered to us.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Fluree, PBC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
• To third parties to market their products or services to you if you have consented to/not opted out of these disclosures. For more information, see the “Your Choices” section below.
• We also may provide functionality that enables you to disclose User Contributions to other users of the Services or the public. We do not control how other users or third parties use User Contributions, or any other personal information that you make available to other users or the public.

In this section, we describe the rights and choices available to all users:

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Services and visiting your account profile page. You may also contact us via our contact page to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you delete your User Contributions from the Services, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Services users. Proper access and use of information provided on the Services, including User Contributions, is governed by our terms of use.

Do Not Track and Global Privacy Control

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We do not respond to the legacy “Do Not Track” signal. We do, however, honor the Global Privacy Control (GPC) signal: when your browser sends GPC, we treat it as a verified request to opt out of the sale or sharing of your personal information, and we suppress all third-party analytics and advertising trackers for that browser. To learn more about GPC, please visit https://globalprivacycontrol.org.

Disclosure of Your Information for Third-Party Advertising

If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by contacting us and requesting to opt-out.

Promotional Offers from the Company

If you do not wish to have your email address used by the Company to promote our own or third parties' products or services, you can opt-out by sending us a request via our contact page. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

Targeted Advertising

If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by contacting us.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative or the Digital Advertising Alliance.

If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.

The Services may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.

Our Services are not directed to, and we do not knowingly collect personal information from, anyone under 16 years of age. If we learn we have collected or received personal information from a child under 13 without verification of parental consent or if a parent or guardian becomes aware that his or her child has provided us with information without their consent and contacts us, we will delete that information from our files as soon as reasonably practicable. If you believe we might have any information from or about a child under 16, please contact us.

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), gives you specific rights regarding your personal information. This section supplements the rest of this Privacy Policy and applies only to California residents.

Categories of Personal Information We Collect

In the past twelve months, we have collected the following categories of personal information about California consumers:

• Identifiers — name, email address, postal address, phone number, IP address, and cookie or device identifiers.
• Commercial information — records of products or services you have requested or expressed interest in.
• Internet or network activity — pages you visit on our Services, time on page, referring URL, and device and browser metadata.
• Geolocation — coarse location inferred from your IP address.
• Professional or employment-related information — job title and company name when you provide them via a form.
• Inferences drawn from the above — for example, lead-scoring derived from your activity and firmographic data.

We do not knowingly collect sensitive personal information as defined by the CCPA, and we do not use any personal information for the purpose of inferring characteristics about a consumer.

Sources of Personal Information

• Directly from you, when you complete a form, subscribe to our newsletter, or contact us.
• Automatically, from cookies, server logs, and similar technologies as you use our Services.
• From third-party data providers, including B2B contact-enrichment services that match an IP address or work email to firmographic records.

Business and Commercial Purposes

We use the personal information described above for the following business and commercial purposes:

• Providing, operating, and improving the Services.
• Responding to your inquiries and fulfilling requests for information or contact.
• Sending marketing and sales communications, where permitted.
• Analytics, including measuring the performance of our Services and marketing campaigns.
• Detecting and preventing fraud, security incidents, and other unlawful activity.
• Complying with legal obligations and enforcing our terms.

Categories of Personal Information Sold or Shared

Under the CCPA, the terms “sell” and “share” are defined broadly. We do not sell personal information for money. However, we “share” the following categories of personal information with advertising and analytics partners for purposes that may qualify as cross-context behavioral advertising or commercial sharing:

• Identifiers (including cookie IDs and IP address).
• Internet or network activity (pages visited on our Services).
• Inferences derived from the above.

We do not knowingly sell or share the personal information of consumers under 16 years of age.

Categories of Recipients

• Web analytics providers (e.g., Google Analytics) for measurement.
• B2B sales and prospecting platforms (e.g., Apollo) for identification and enrichment of business visitors.

Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to comply with legal, accounting, or reporting requirements. Marketing contact records are retained until you unsubscribe or request deletion. Server logs and analytics data are retained for up to 26 months. We delete or anonymize personal information when it is no longer needed for these purposes.

Your CCPA Rights

Subject to certain exceptions, California residents have the following rights:

• Right to know — request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purposes for collecting it, and the categories of third parties with whom we share it.
• Right to delete — request that we delete personal information we have collected from you.
• Right to correct — request that we correct inaccurate personal information we maintain about you.
• Right to opt out of sale and sharing — direct us not to sell or share your personal information.
• Right to limit use of sensitive personal information — note: we do not use sensitive personal information for purposes that trigger this right.
• Right to non-discrimination — we will not discriminate against you for exercising any of these rights.

How to Exercise Your Rights

To opt out of the sale or sharing of your personal information, visit Your Privacy Choices. We also honor the Global Privacy Control (GPC) signal — if your browser sends GPC, we treat it as a verified opt-out for that browser, and no further action is required.

To exercise any of the other rights described above, submit a request via our contact page with the subject line “CCPA Request” and a description of your request. We will verify your identity before responding, typically by asking you to confirm information already in our records.

You may designate an authorized agent to make a request on your behalf. The agent must provide signed written authorization, and we may still ask you to verify your own identity directly with us.

Response Timelines

We will confirm receipt of a verifiable request within 10 business days and respond substantively within 45 calendar days, with a possible 45-day extension when reasonably necessary. We will provide the response in writing, by mail or electronically at your option.

California “Shine the Light”

Separately from the CCPA, California Civil Code Section § 1798.83 permits California residents to request information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, contact us via our contact page with the subject line “Your California Privacy Rights.”

The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. We may also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Services.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Services (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Please direct any questions or comments about this Privacy Policy or our privacy practices to us via our contact page. You may also write to us via postal mail at:

Fluree, P.B.C. 486 Patterson Avenue, Suite 221 Winston Salem, North Carolina 27101