This privacy policy (“Policy”) describes the privacy practices for our website, applications, APIs, and other services accessible via Flipturn | Home (getflipturn.com) and any subdomains, or any services, content or functionality offered on or through any of the foregoing and any related sites or applications (collectively the “Site”). This Policy is a legal statement that explains how Flipturn, Inc. (“Flipturn”, “we”, or “us”) may collect information from you, how we may use, maintain, protect, and share your information, and how you can control your information.

This Policy is incorporated by reference into our Terms of Service (the “Terms”). Before you use the Site, please read this Policy and the Terms carefully so you understand our policies and how we process your information. By accessing or using the Site or by accepting (including by clicking to accept or agree when the option is made available to you) any Terms that incorporate this Policy, you accept and agree to be bound and abide by this Policy and the Terms. If you do not agree with any terms of this Policy or the Terms, you may not access or use the Site for any purpose.

Information About You That We Collect

When you access or use the Site, we may collect the following personal information (also known as personal data or PII) (“Personal Information”). We mainly use Personal Information to provide and improve the Site, to help you use your account on the Site, and to enable us to help you customize your experience using the Site.

• Profile Data
  - Your name (business or personal), email address, and mailing address.
  - Site customizations.
  - Name and email of other users to invite to the Site.
  - Electronic notification preferences
• Usage Data. We collect information on how the Site is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (“IP address”), user agent, browser type, browser version, operating system, the pages of our Site that you visit, search queries you perform, information you may post to the Site, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data, and configuration input provided using the Site’s forms, such as keywords, categories, and search terms. Our Site and some third-party sites and HTML-formatted emails may use web beacons alone or with cookies to compile information about your website usage and your interaction with email. A web beacon is an electronic image, called a “single-pixel”, “1×1”, or “clear” GIF.
•  Location Data. We may use information about where you are located, such as using Internet Protocol (IP) address for a rough geolocation. We may use location information to provide, improve, and personalize the Site.
• Customer and Applicant Data. In some cases, during prospect and customer engagements, or when interviewing applicants for employment, we may record our meetings. These recordings are used for internal educational purposes only and are only captured with explicit consent at the initiation of recording.
• Employment-Related Data. We may receive and process employment-related information, such as employment history, resumes, background information, recordings of interviews, and other relevant information to help us to recruit new employees and independent contractors, and to manage our interactions with current employees and independent contractors.
• Support and Survey Data. At times, you may request assistance with the Site, report an error or bug on the Site, ask questions about your subscription or account, complete a survey, respond to a questionnaire, or otherwise interact with us regarding the Site, and in the process, you may provide information to us through forms on the Site or through electronic channels such as email.  We may request additional information related to any requests or submissions you make.
  

• Business Partner Data. We do business with many companies whose employees give us their contact information for communication regarding the Site or services we receive from those businesses. We never sell your Personal Information and only use it for purposes of communicating with those businesses. We may use that Personal Information for our own internal purposes to help us improve our business relations processes and practices. We may keep and process the Personal Information after the relationship ends with those businesses when we are required to do so by applicable law or to preserve legal claims that may arise.
• Privacy of Children. We are committed to protecting child privacy. The Site is not intended for children and we do not intentionally or knowingly collect information, personal or otherwise, about individuals under the age of 18, much less children under 13 years old. If you are aware of anyone under 18 using the Site, please contact us using the contact information provided below and we will take required steps to delete any such information and/or prevent that individual from accessing the Site.
• Sensitive Data. We never intentionally receive or process information regarding your sexual orientation, ethnicity, religious affiliation, refugee status, health, or personal finances.
• Anonymized Data. Personal Information does not include anonymized data, which is data that has been rendered anonymous in such a way that you are no longer identifiable (“Anonymized Data”). We may use anonymized data for our own purposes in any manner and without attribution or compensation to any person.
• Other Technologies. We may also use device identifiers, local storage, html modifiers, and different types of caching to help us understand the devices and users who access the Site. Those methods include device identifiers that are either hardware-based or software-based, persistent or non-persistent, and which may identify either a device or a software module within a device (such as a web browser).
• Other information. We may use any other information you provide during your use of the Site.

How We Collect Personal Information

We collect Personal Information from various sources, such as directly from you when you access or use the Site or automatically as you navigate through the Site. Information collected automatically may include, but is not limited to, Usage Data, cookies data, and so forth.

How We Use Personal Information

We may use Personal Information for the following reasons:

• To provide, maintain, and improve the Site (performance of contract);
• To personalize the Site (legitimate interest);
• To provide customer support (performance of contract);
• To detect, prevent, and address technical issues with the Site (performance of contract); 
• To monitor Site usage and analytics (legitimate interest);
• To secure the Site including fraud prevention, spam and malware protection (legitimate interest);
• To conduct research and development including the development of new features, tools, pricing, and functionality (legitimate interest);
• To notify you regarding changes to our Site including features, tools, and functionality provided by the Site (performance of contract);
• To notify you about our current or new offerings (performance of contract); 
• To enforce our Terms and other applicable agreements and/or policies (performance of contract);
• To contact you for potential market research purposes including completing surveys and questionnaires (legitimate interest); and 
• For any other purpose disclosed to you and/or obtained consent (consent).

How We Share Personal Information

We may share Personal Information with third parties and as otherwise described in this Policy, in other applicable notices, or at the time of collection. Such sharing may include:

• Affiliates & Partners. We may share Personal Information with any applicable subsidiary, affiliate, or partner for purposes consistent with this Policy and who may contact you. We may share anonymized data or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your Personal Information, please see the Your Data Privacy Rights and Choices section below.
• Service providers. We may share Personal Information with third party companies and individuals that provide services on our behalf or help us operate the Site and our business (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These services, which include but are not limited to companies that provide cloud services, infrastructure, analytics services, and software to help us host and maintain the Site, and manage our business and customer relationships, may process Personal Information.  We take commercially reasonable steps to ensure that these service providers are secure and do not sell or disclose the Personal Information to other parties, or use Personal Information for any purposes other than the services they are providing to us.
• MIXPANEL. Please note that we may use Mixpanel to assess how users interact with the site. The Privacy Policy of Mixpanel is available at https://mixpanel.com/legal/privacy-policy/ and includes information regarding how to opt-out of certain aspects of their data processing practices. 
• Recruiting Providers. We may use the services of third parties to help us to recruit new employees and independent contractors and to manage our interactions with current employees and independent contractors. We do our best to contractually ensure that these third-party service providers comply with the policies we have adopted. However, we can’t guarantee their compliance in every case. We only use employment Personal Information for the direct purpose of the employment or independent contractor relationship, and we cease using it as soon as that relationship ends. However, we may keep and process that Personal Information after the relationship ends when we are required to do so by applicable law or to preserve legal claims that may arise.
• Professional advisors. We may disclose Personal Information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
• Compliance. We may share Personal Information for required compliance, fraud prevention and safety purposes.
• Business transfers. We may disclose Personal Information in the context of actual or prospective business transactions (e.g., investments, financing, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). For example, we may need to share certain Personal Information with prospective counterparties and their advisers. We may also disclose some or all of your Personal Information to an acquirer, successor or assignee of Flipturn as part of any business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization, sale of assets, or similar transaction, and/or in the event of bankruptcy, dissolution, or receivership in which Personal Information is transferred to one or more third parties as one of our business assets.
• Legal Disclosure. We may disclose Personal Information if required to do so by law or in the good faith belief that such action is necessary to conform to applicable law, comply with a judicial proceeding, court order or legal process served on us, protect and defend our rights or property, or investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our Terms.
• Consent. We may share your Personal Information for any other purpose disclosed to you and with your consent.
• Do Not Track Signals. We believe the “Do Not Track” technology standard, published by the World Wide Web Consortium, is still in draft form. We are unable to respond to Do Not Track signals set by your browser at this time due to its unclear standards and guidelines.

How We Protect Your Personal Information

• Security. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.  Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.
• Third-Party Links, Sites and Services. You may be able to access third party websites and other tools, services, or products via our Site, a link, or via our other tools. The privacy policies of these third parties are not under our control and may differ from ours. The use of any Personal Information that you may provide to any third parties will be governed by the privacy policy of such third party or by your independent agreement with such third party. If you have any doubts about the privacy of the information you are providing to a third party, we recommend that you contact that third party directly for more information or to review its privacy policy. This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any offering, site or other products and services used in connection with the Site. The inclusion of functionality or a link does not imply endorsement of the linked site or service by us or by our affiliates.

Your Data Privacy Rights and Choices

In this section, we describe the rights and choices available to all users. Users located in the European Union (“EU”), European Economic Area (“EEA”), United Kingdom (“UK”), Switzerland, and various US states can find information about their rights below.

• Your Rights Under the General Data Protection Regulation (“GDPR”). If you are a resident of the EU, EEA, UK, and/or Switzerland, you may have certain data protection rights with respect to the Personal Information that we may have collected about you. These rights may include the following:
  - The right to access, update or to delete the Personal Information we have about you;
  - The right to have your Personal Information corrected if the information is inaccurate or incomplete;
  - The right to object to our processing of your Personal Information;
  - The right to request that we restrict the processing of your Personal Information;
  - The right to be provided with a copy of your Personal Information in a structured, machine-readable and commonly used format; and.
  - The right to withdraw your consent at any time if we relied on your consent to process your Personal Information.
• Your Rights Under the California Consumer Privacy Act (“CCPA”). If you are a California resident, under the CCPA you may have certain rights with respect to the Personal Information that we may have collected about you. These rights may include the following:
• You can request the following information about how we have collected and used your Personal Information during the past 12 months:
  - The categories of Personal Information that we have collected;
  - The categories of sources from which we collected Personal Information;
  - The business or commercial purpose for collecting, selling and/or sharing Personal Information;
  - The categories of third parties with whom we disclose Personal Information;
  - The categories of Personal Information that we sold, disclosed, or shared for a business purpose; and
  - The categories of third parties to whom the Personal Information was sold, shared or disclosed for a business purpose.

• You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• You can ask us to delete the Personal Information that we have collected from you.
• You can ask us to correct inaccurate Personal Information that we have collected about you.
• You can request to opt-out of disclosures of your Personal Information that constitute “selling” or “sharing” of your Personal Information as defined in the CCPA.
• You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.
• Your rights to have Personal Information deleted are subject to several exceptions, specifically the Personal Information that is necessary for us to:
  - Complete your transaction;
  - Provide you a good or service;
  - Perform a contract between us and you;
  - Protect your security and prosecute those responsible for breaching it;
  - Fix our system in the case of a bug;
  - Protect the free speech rights of you or other users;
  - Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §1546 et seq.);
  - Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
  - Comply with a legal obligation; and
  - Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
• Anonymized Data which cannot be re-identified and does not identify you or any individual person, is exempted under the CCPA (e.g., see Section 1798.145. Exemptions) and may be shared with third parties or provided for sale.
  - You may read more about your California privacy rights here. 
• Your Rights in Various Other Jurisdictions. Various other states, including but not limited to, Colorado, Connecticut, Virginia, and Utah, have passed laws providing their state residents rights that are the same or similar to those afforded under the CCPA and the GDPR. These rights, which we honor in the same fashion as outlined above, include without limitation rights to:
  - Confirm whether we process their Personal Information.
  - Access and delete certain Personal Information.
  - Data portability.
  - Opt-out of Personal Information processing for targeted advertising and sales.
  - Correct inaccuracies in their Personal Information, taking into account the information's nature processing purpose.
  - Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.
  - Outside of the US, if you are a resident of another country, state, or province with applicable data privacy laws and regulations that afford you with privacy rights similar to those afforded by the GDPR, CCPA, or other similar laws or regulations, we will honor any requests from you to exercise those privacy rights in accordance with those data privacy laws and regulations to the extent possible.

How to Exercise Your Privacy Rights

• Contact. Please contact us using the contact information provided below to exercise any of your privacy rights. We may require you to prove your identity in some cases to ensure the rights of third parties are not violated by your request. Keep in mind that in the case of a vague request we may engage the individual in a dialogue to better understand the motivation and context of the request. We reserve the right to reject or charge a reasonable fee to cover our administrative costs of providing the information for requests that are unduly burdensome or repetitive in nature, or if there are legal obligations to maintain the data due to a dispute, compliance, audit, or other investigation. Please consider your request before submitting it. We will respond as soon as we can, which is generally within thirty (30) days from when we receive your request.
• Agent. You may use an authorized agent to submit a request on your behalf so long as you provide us with written proof that you have authorized such person to act as your authorized agent for the purpose of the related request.
• Notification. We commit to notify you and the applicable data protection authority of breaches of your Personal Information within the timeframe required by law.  
• Data Protection Authorities. Subject to applicable laws, you may have the right to lodge a complaint with your local data protection authority about any of our activities that you believe are not compliant with applicable law.

Data Retention of Your Information

• We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We store some information indefinitely for operational purposes, such as technical support and abuse prevention. Other data such as web server logs or store sales reports are only kept as long as space is available for them. Please note that if you request that your Personal Information be removed from our databases, it may not be possible to completely delete all of your Personal Information due to technological and legal constraints.
• The retention period is determined by various criteria such as the type of user, the services to which you subscribe, and the nature of our relationship. The retention period can be lengthened or shortened based on the cancellation or re-enrollment in our Site. The retention period can also be modified based on internal changes in auditing requirements and/or mandatory retention periods provided by law and statute of limitations.

Transfer of Data

• Your information, including Personal Information, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.
• We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other Personal Information. Your consent to this Policy followed by your submission of such information represents your agreement to that transfer.
• For example, we may use specific appropriate safeguards, which are designed to give Personal Information effectively the same protection it has in Europe – such as standard-form contracts approved by relevant authorities for this purpose. 

Changes to this Privacy Policy

• We reserve the right to change this Policy at any time. Any change to this Policy will become effective on the date it is posted. We recommend that you retain a copy of this Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. 
• If you continue to use the Services after any changes to the Policy have been posted and become effective, that means you agree to all of the changes.

Contact Information

We are committed to protecting your privacy. If you have any questions, comments, or concerns about your information, this Policy, or any of our privacy practices, please contact us by email at support@getflipturn.com or by mailing correspondence to Flipturn located at 159 Court St. Unit 3, Brooklyn, NY 11201.