BUILDWITHIN PRIVACY NOTICE

Revised:  July 27, 2023BUILDWITHIN INC. (the “Company”, “BuildWithin”, “we”, “us”, “ours”) is committed to protecting your privacy. We have prepared this Privacy Notice (or “Notice”) to describe to you our practices regarding our collection and use of your Personal Data and Personal Information (as defined herein). This Privacy Notice provides information about the types of information we collect from our Services and website and what we may do with that information.

In this Notice, we will outline and describe the following with respect to the Personal Data or Personal Information that we collect:
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- What information we collect
- How we collect it
- How we use it
- With whom we share your information
- How long we keep your information
- The security of your information
- Our Data Privacy Officer
- Our policy regarding children

You will note that throughout this Notice we use words that are capitalized. These are special terms that are defined within the applicable paragraph or under the Definitions Section in Section XI.

By accessing or using our websites, mobile applications (“apps”), or submitting information to us, or otherwise agreeing to this Policy, e.g., in the context of registering for any of our products or services, you understand and consent to our collection and use of your personal information as described herein.

I. WHAT INFORMATION WE COLLECT

A. Information you provide:
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If you are just browsing the BuildWithin website, we do not ask you to enter any personal information about yourself unless you complete a form to request a demo, download content, or interact in any way you choose on your own and is available on the webpage. We may also collect your user name, or handle, from Facebook or Twitter when you connect to us from them or wish to connect to them from us. We may also combine information you provide with Personal Data we collect automatically (as further described in Part I, Section B below) and with Personal Data we receive from third-parties. We may also associate information you provide with information we collect about you from different devices, browsers and platforms.

B. Information collected automatically:

‍Certain information that identifies you may be passively collected and stored on our or our service providers’ server logs, including your Internet Protocol (“IP”) address, browser type, operating system and information regarding what website pages you accessed and when. An IP address is a number that is automatically assigned to your computer when you use the Internet. In some cases your IP address stays the same from browser session to browser session; but if you use a consumer Internet access provider, your IP address may vary from session to session. We also use Cookies and navigational data like Uniform Resource Locators (“URL”) to gather information regarding the date and time of your visit to our website or access our Platform through a client and the information for which you searched and viewed. This type of information is collected to make our Services more useful to you and our Clients, and to tailor the experience with us to meet your special interests and needs.

Cookies. Cookies are small pieces of information that a website sends to your devices while you are viewing a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a better experience with our Platform. Persistent Cookies can be removed by following your Internet browser directions. If you choose to disable Cookies, some aspects of our Services may perform differently, for instance, you will need to re-enter your information each time you return to use the Services.

If you do not know what cookies are, or how to control or delete them, then we recommend you visit www.aboutcookies.org for detailed guidance. Cookies allow us to identify and authenticate visitors, track aggregate behavior, and enable important service features.  We may also contract with analytics services, third-party affiliate services, and third-party advertising companies to collect similar information. These cookies allow the ad servers to recognize your computer each time they send you an online advertisement, and compile information about you or others who use your computer. This information allows such advertising networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.
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Web Beacons/Tags. We may automatically collect aggregate anonymous information through files embedded in our services and emails known as “web beacons.” We may deliver a web beacon to you through our services from an advertising network with which we have contracted. Web beacons allow third parties to provide anonymized and aggregated auditing, research, and reporting for us. Web beacons also allow us to tell whether email recipients are able to properly view messages or if email messages have been opened, to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to users. We do not tie the information gathered by web beacons to personal information.

Flash LSOs. When we post videos, third parties may use local shared objects, known as “Flash cookies,” to store your preferences for volume control or to personalize certain video features. Flash cookies are different from browser cookies because of the amount and type of data and how the data is stored. The cookie management tools provided by many popular browsers will not remove Flash cookies. To learn how to manage Flash cookie privacy and storage settings, click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.Flash LSOs. When we post videos, third parties may use local shared objects, known as “Flash cookies,” to store your preferences for volume control or to personalize certain video features. Flash cookies are different from browser cookies because of the amount and type of data and how the data is stored. The cookie management tools provided by many popular browsers will not remove Flash cookies. To learn how to manage Flash cookie privacy and storage settings, click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.

Analytics. We may use analytics tools or similar tools provided by third parties (“Data Analytics Providers”) to help analyze how you and other users utilize our services. Analytics tools use cookies and other tracking technologies to collect information such as how often users visit our website, what pages they visit, and what other websites they have used prior to visiting our website. We use the information we get from analytics tools only to improve services. Analytics tools collect the IP address or other unique identifier assigned to you on the date you visited services. We do not combine the information generated through the use of analytics tools with your other personal information. Analytics tools provided by third parties plant a persistent cookie on your web browser to identify you as a unique user the next time you visit our website, and the treatment of that information is governed by the third party’s terms of use and/or privacy policy. To learn about how Google uses data related to website analytics when you use our site or apps, click here: https://policies.google.com
/technologies/partner-sites. For information about how Facebook uses cookies and other storage technologies, click here: https://www.facebook.com
/policies/cookies/.

Geolocation Data.  Subject to your device permissions, We (or Our service providers) may be able to collect information about the location of your device or may gather other general location data based on GPS data, mailing address, and/or billing address (hereinafter collectively referred to as “Geo-location Data”), to customize our Services based on your location. You can prevent your device from sharing precise location information, including without limitation some or all of the Geo-Location Data, at any time through your device’s operating system settings.
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The following third parties may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes.  For more information about the collecting, use and sale of your personal data and your rights with respect to these third parties, please see the links listed below:

Amazon Web Services - https://aws.amazon.com/blogs
/security/aws-gdpr-data-processing-addendum/
Google – policies.google.com/privacy
Okta - https://www.okta.com/privacy-policy/
Vercel - https://vercel.com/legal/privacy-policy
DataDog - https://www.datadoghq.com
/legal/data-processing-addendum/
Twilio - https://www.twilio.com/legal/data-protection-addendum
Webflow Intercom – www.webflow.com/legal/privacy
User Centrics – www.usercentrics.com/privacy-policy/
Intercom - https://www.intercom.com/legal
/privacy

BY INTERACTING WITH OUR WEB APPLICATION YOU GIVE CONSENT FOR US TO SHARE YOUR DATA WITH THESE PROCESSORS, AND FOR THEM TO TRANSFER THIS INFORMATION ONWARD TO THEIR PARTNERS IN CONNECTION WITH PROVIDING YOU SERVICES.

C. Information collected from third-parties:
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In addition to the information that we collect as described above, we also collect information about you from our third-party integrators and vendors. These parties are used by us to run our Platform and integrate our Services with our Clients. The information that we collect through these channels includes your geolocation data, derived from the address that you may submit when completing a website survey or form.

II. HOW WE COLLECT YOUR INFORMATION
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We collect your Personal Data in a number of ways, and this section will describe those methods.

A. Your direct interaction with us: We collect your Personal Data when you interact directly with us by coming to our website to browse, to request information, to download or view content and to interact with our site bot.

B. From our Clients: Another way we collect your Personal Data is from our Clients who contract with us to use BuildWithin services. If you provide your information via a form that uses our Platform, we will collect the information you provide on the form such as name,  
e-mail address and the full content of your message, including attached files, and other information you provide. This method of Personal Data submission to us could occur (i), for instance if the Data Subject completes a form created by a client but powered by BuildWithin.  Platform, or (ii) where the Client captures the Data you enter and then transmits that Data to us.

C. From Third-Party Technologies and Social Network Sites:
We may receive Personal Data about you from other sources with which you have interacted, such as through third-party technologies that are integrated into the Services like Alexa, which is owned by Amazon, or through social networks like Facebook or Twitter when you grant us permission to access these technologies to further use BuildWithin Services. Further, we may associate this Personal Data obtained from these sources with the other Personal Data we have collected about you from other sources as described in this Notice. We do not control or supervise how these third-parties process your Personal Data, and any information request that you have regarding the disclosure of your Personal Data from them to us should be made directly to those third-parties.

D. Third-party analytics:
Third-parties who provide us with analytics services for our Platform and Services may collect some of the information described in Section I, including, for example, IP address, access times, browser type and language, device type, device identifiers and Wi-Fi information. For instance, we use Google Analytics and similar services to perform certain analytical tasks about our web user’s activities. We use the User-ID feature of Google Analytics to combine behavioral information across devices and sessions (including authenticated and unauthenticated sessions).

III. HOW WE USE YOUR INFORMATION AND THE LEGAL BASIS FOR SHARING IT
We may use your information to:
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- process information you have submitted on a form either through one of our Client’s forms on a BuildWithin website form; via text message, voice recognition, conversational messaging system, or via phone call;
- seek your views or comments on the Services we provide;
- carry out our obligations arising from our website’s and web applications terms of use, or arising from any contracts entered into by us with our Clients; or
- provide, create and maintain a trusted and safer environment and comply with our legal obligations.

Applicable laws require us to have a “legal basis” for using and sharing your information. These legal bases include the following:
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- Your consent - to fulfill your express requests.
- To carry out our legitimate interests in our Platform. “Legitimate interests” is a technical term in data protection law which essentially means we have a good and fair reason to use your Personal Data and we do so in ways which do not hurt your interests and rights. We sometimes require your Data to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom or interests.
- To fulfill our obligations with you when the processing is necessary to perform a contract with you, like the Terms of Service.
- To measure the adequate performance of our interactions with you, and to comply with applicable laws.
- To promote the safety and security of the Services, our users, and other parties. For example, we may use the information to protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.
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IV. HOW WE SHARE YOUR INFORMATION
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A. With your consent:
Where you have provided express and unambiguous consent, we share your Personal Data as described at the time of consent.
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The specific ways in which you consent to share Personal Data that you provide to us is when we enable you to complete skills assessments, questionnaires, forms, send other users messages or assign tasks that are part of the work you do through our Platform. These messages may include your full name, e-mail address, mailing address and other contact information you may have provided as part of the submission. You are solely responsible for the specific message(s) you send using our Services.
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Information you share publicly through our Platform may be indexed through third party search engines, such as Google. We do not control the practices of third party search engines, and they may use caches containing your outdated information. You acknowledge that Personal Data that you submit when you interact with our Platform through our website or Services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such Personal Data by others.

B. Third-Party Sub-Processors:
We use third-party Sub-Processors (including contractors, service providers and third parties) to provide the Services and to help with our operations, which may require that these Sub-Processors have access to and use your Personal Data. For example, we may use a third-party to communicate with you (via telephone, email, or SMS) to provide customer support, to receive additional Data about you, and to perform analytics and other work that we may need to outsource. The Sub-Processors are bound by law and/or contract to protect the confidentiality and security of Personal Data, and to only process your Personal Data to provide requested services and only act on our documented instructions.

C. Third-Party websites:
We may provide links to other websites, such as social network sites (Meta, X) and other websites may provide links to our website and web applications. Third-party websites operate according to their own terms of use and privacy policies. BuildWithin has no control over such third-party websites, and by using our Platform and Services, you acknowledge and agree that we are not responsible for the availability of such third-party sites, and do not endorse and are not responsible or liable for any content, advertising, products or other materials on or available from such sites. You further acknowledge and agree that BuildWithin will not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any content, advertising, products, or other materials on or available from such sites.

D. De-identified information about you:
We may also share aggregated or de-identified information (i.e., information that does not personally identify you directly), or statistical information about you, including statistical data and historical use data, with others for a variety of purposes, including for their own uses, for example, for improving their services for you and others, or for educational purposes. Your Personal Data will not be shared on an individual, identifiable basis under these circumstances, nor can you ask us to restrict this type of sharing, since it does not identify you.

E. As required by law or legitimate business interest:
In addition, we may disclose your Personal Data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. Likewise, we may disclose your Personal Data to our professional advisers as reasonably necessary for the purposes of managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. Also, we may share some or all of your Personal Data in connection with or during negotiation of any merger or similar transaction involving sale or transfer of some or all of our business or assets. If another company acquires our company or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Notice.

V. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
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A. Opting Out:
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You can make the following choices regarding your personal information:

Promotional and Other Emails. You may choose, during the account registration processes on one of our websites or web applications, or otherwise, to provide us with your email address for the purpose of allowing us to send emails. newsletters, surveys, offers, and other materials related to the services or programs the client is implementing. You can stop receiving these emails by sending a request to the email address in the Contact Us section below. If you decide not to receive these emails, we will do our best to not send you emails moving forward.

A third party may use technology (e.g., a cookie) to collect information about your use of our websites so that they can provide advertising about products and services tailored to your interests. You can adjust your cookies preference in your computer settings.

Analytics. Many analytics providers allow end-users to opt out of the retention of their information, including our third-party analytics providers. Please note that, typically, unless you create an account with the analytics provider, your choice to opt out applies only to the device from which you make the request, because the providers use cookies on that device to recognize your choice. If you get a new device, install a new web browser, update your browser, or otherwise erase/alter your browser cookie files you may clear the opt-out cookie.

You may learn more about the use of information by and opting-out of analytics from our third-party provider, Google, by visiting its opt-out page at the following links:
www.google.com/policies/
privacy/partners/
https://tools.google.com/
dlpage/gaoptout

VI. SECURITY OF YOUR INFORMATION
To help protect the privacy of your Personal Data collected by us, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your Personal Data to those employees who need to know that information to provide the Services. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of personal data processed by the services.  We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.

Unfortunately, the transmission of information via the internet is not completely secure. Although We do our best to protect your personal information, We cannot guarantee the security of your personal information transmitted to Our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
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VII. QUESTIONS, CONCERNS, OR COMPLAINTS – CONTACT DETAILS
To contact our Privacy Officer: By Telephone: 888-769-7479
‍By Email: Privacy@BuildWithin.com
‍By Mail: BuildWithin Inc.
900 19th Street
Washington, D.C., 20009
Attention: Ximena Gates

VIII DEFINITIONS
Words that are capitalized in this Notice have the following meanings:
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“Client” means a customer of BuildWithin, who engages the Company, among other things, to use the Company services and platform.

“Personal Data” or “Personal Information” means any information relating to an identified or identifiable natural person (“Data Subject” or “Consumer”); an identifiable person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal Data includes “Special Categories of Personal Data”.

“Processing” means any activity that involves the use of Personal Data.  It includes obtaining, recording or holding the Data, or carrying out any operation or set of operations on it including organizing, amending, retrieving, using, disclosing, erasing or destroying it.
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“Processor” also means us, or any other natural or legal person (including corporations, partnerships or other business entities) which, acting alone or jointly with others, Processes Personal Data for a controller or a party with whom you deal directly and is primarily responsible for the security of your Data and your privacy rights.
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“Services” means collectively the BuildWithin platform (“Platform”) and related services.
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“Special Categories of Personal Data” includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

Capitalized terms not defined in this section or elsewhere in this Policy have the meaning as defined in our Terms of Use.

IX. Changes and updates to the Privacy Notice
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As our Company, membership and Services may change from time to time, this Privacy Notice is expected to change as well. We reserve the right to amend the Privacy Notice at any time, for any reason, without notice to you, other than the posting of the amended Privacy Notice at this Site. We may choose to e-mail periodic reminders of our notices and terms of use, but you should check our Site frequently to see the current Privacy Notice and Terms of Use that are in effect and any changes that may have been made to them.
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Last Updated: July 27, 2023