Privacy Policy

PRIVACY POLICY Greetr, Inc. (“Greetr", “us,” “we”, and “our”) has created a platform service called Greetr whereby individuals can apply to job postings and job candidates and prospective and potential employers and their representatives can correspond with one another. Greetr is committed to respecting the privacy rights of users (“you”). Greetr created this Privacy Policy (the “Policy”) to explain its information collection and use practices and the protection of your information when you use our website ([INSERT]) (“Website”) and use our text messaging and related software and documentation (collectively, the “Services”). Any terms capitalized but not otherwise defined in this Policy shall have the meanings set forth in the End-User License Terms (“EULA”).

We are committed to your data protection and data privacy. We recommend you read this Policy to better understand what information we collect, how we use it, and who we may share it with. Additionally, this Policy will provide you with details on how you can control the use and disclosure of your information.

By accessing or using Services and related features, including accessing any other linked pages, features, content, mobile applications, or any other services we offer from time to time by in connection therewith (collectively, the “Content and Services”), you acknowledge that you accept the practices and policies outlined in this Policy, the EULA, and you hereby consent that we will collect, use, and share your information in the ways described in this Policy.

BY USING OUR WEBSITE OR SERVICES (A) ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTAND THIS POLICY; (B) REPRESENT THAT YOU ARE 18 YEARS OF AGE OR OLDER; (C) THAT YOU ARE A RESIDENT AND CITIZEN OF THE UNITED STATES, AND (D) THAT YOU ACCEPT AND AGREE TO ABIDE BY THE TERMS IN THIS POLICY. IF YOU DO NOT AGREE TO THE TERMS IN THIS POLICY, DO NOT DOWNLOAD, INSTALL OR USE THE APP, AND DELETE IT FROM YOUR MOBILE DEVICE.

III.WHAT DO WE DO WITH THE INFORMATION THAT WE COLLECT?

We use, aggregate, and retain your Personal Information as needed to provide you with access to our Website and Services and for other legitimate business reasons. At a high level, we use the Personal Information that has been provided by you directly or indirectly for the following purposes:

I.SERVICES

Employees and organizations (“Customers”), , subject to the terms of this Policy and our Terms of Use share certain information with us, including Personal Information (as defined below) such as their name and contact information in order to enable us to provide the Services and in order to correspond with potential employees. For clarity, job applicants cannot apply to open positions with our Customers via our Services. Prospective employees must apply to open positions directly with our Customers. Once our Customers have ingested a prospective employee’s Personal Information into their Applicant Tracking Systems (“ATS”), the Customer may share that information with Greetr to streamline communication with the individual. Greetr does not collect Personal Information directly from prospective employees.

In the event that prospective customers or other individuals correspond with us via our Website or otherwise reach out to us for information about our Services, they may also, subject to this Policy and our Terms of Use, share certain Personal Information with us so that we may provide them with the information and experience that they desire.

We collect and may use Personal Data in order to provide you with the best Service and Website experience, including offering Customers with ways more easily connect and communicate with potential employees whose information is contained in our Customers’ ATS. Additionally, the collection and use of your Personal Data helps us tailor and improve our services and communicate with you effectively. Please note that we may be deemed a “data controller” or a “data processor” as it relates to any Personal Data or Personal Information (as those terms are defined by applicable law, which, for the purposes of this Policy the terms shall be used interchangeably) shared in connection with your use of our Services and Website, including your membership information, as applicable. By visiting, joining, or using our Services or Website, or otherwise indicating that you agree to this Policy, you agree to, and authorize our use of your Personal Information as described in this Policy.

If you have any questions regarding this Policy, please contact us using the information provided at the end of this Policy.

II.WHAT INFORMATION DOES GREETR COLLECT?

We believe that it’s important for you to know what types of information we collect when you use our Services. Greetr collects the information described in this Policy. By using the Services, your information will be collected, stored and used in the manner described in this Policy. In many cases you have control over the information that you choose to provide.

We only collect and process your information as permitted by applicable law. These lawful bases include where it is: necessary for the performance of a contract to which you are a party; necessary for us to take steps, at your request, to enter into such a contract; necessary for the purposes of our legitimate interests or those of a third party and not overridden by the interests or fundamental rights and freedoms of any data subject; where you provide us with consent; or necessary for compliance with a legal obligation to which we are subject. Under applicable law, we may be obliged to secure and maintain technical and organizational measures to protect the security of your data, investigate and report any (suspected) breaches of those technical and organizational measures, or comply with legal and regulatory obligations, including, but not limited to, complying with minimum retention periods for certain types of data.

IF YOU DO NOT AGREE TO THE COLLECTION AND USE OF YOUR INFORMATION IN THIS MANNER, DO NOT USE OUR SERVICES OR WEBSITE. You may also opt out of the collection and use of your information as set forth in this Policy. If you choose to opt out, the Services may not function effectively.

A.Information Provided by You.

1. Personal Information. We receive, store, and collect any Personal Data you provide to us directly through our Services, such as through the creation of an account as part of our Services or that our Customers may share with us in order to communicate with job applicants.  When you create an account as part of our Services, you may be asked to provide to Greetr with certain information related to you or job applicants with which you would like to communicate via the Services such as (a) "Contact Data" (personally identifiable information about you, such as your name, social media handles, email address, and mobile phone number); (b) "Demographic Data" (Personal Information about you that doesn’t specifically identify you, such as your zip code, and country); and (c) "Usage Data" (information about your use of the Services that doesn’t specifically identify you, such as your preferences and general use of the Services). We may also receive select Personal Data when use our [“Contact Us”] functions of our Services or Website.

‍2. Non-Personal Profile Information. When using or communicating via our Services, you may have the option to share additional information about your professional skills, desires, and goals, as well as your education and work experience. The information that you share will only be shared with the individual and entity with which you share it.

‍3. Other Information Shared by You. When you use our Services, you may be asked to share additional information with Greetr in order to facilitate the provision of the Services and to secure your information, passwords. Our Services and Website may evolve over time. We may introduce new features, which may require or permit the collection of new information. If we collect materially different Personal Information or materially change how we collect, use or share your data, we will notify you and we may modify this Policy as necessary or appropriate.

Information Made Available by You, Your Technologies, or Devices.

1. Mobile Device and Service Use Data. When users use the Services on a mobile phone or other wireless telecommunications device, Greetr may automatically gather information, including carrier providers, geo-location information (if allowed by you), the types of mobile devices accessing the Services, and the types of operating systems accessing the Services (collectively, "Mobile Device Data"). Location services can be enabled or disabled at any time through the mobile device settings. Greetr uses Mobile Device Data to understand usage patterns and to improve its Services. Similarly, we log use data of our Website and Services to monitor, among other things, useability and security. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use. Additionally, as described later in this Policy, we use cookies and similar technologies (e.g., pixels) to collect data (e.g., device IDs) to recognize you and your device(s) on, off and across different services and devices where you have engaged with our Content and Services.  For additional information on Greetr’s uses of Mobile Device and Service Use Data, see “What Do We Do With The Information That We Collect” below.

‍2. Cookies and Other Tracking Technologies. We use Cookies, Clear GIFs, Web Beacons, Tracking Technologies or other similar solutions (collectively, “Tracking Technologies”) to collect or receive certain information when you visit or use our Services or Website or read an email or otherwise interact with content or communications from us. These Tracking Technologies may include first party cookies (i.e., those placed by the website being visited) and third party cookies (i.e., those placed by a website other than the one being visited), local shared objects (commonly referred to as “Flash Cookies” or “HTML 5 Cookies”) and tracking pixels (including transparent or clear gifs).

“Cookies” are small data files which are placed on your computer or mobile device when you visit a website or use an online service. For example, cookies enable us to identify and authenticate you and remember your preferences so we can enhance your experience with our Services and Website. [They also help us serve you ads relevant to your professional interests and to provide aggregated auditing, research, and reporting for advertisers, understand and improve our service, and know when content has been shown to you. Because your web browser may request advertisements and beacons directly from third party ad network servers, these networks can view, edit, or set third party cookies, just as if you had requested a web page from their site. Ads served by Greetr may also set third party cookies.] Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent.

We strongly recommend that you leave the cookies activated, however, because cookies enable you to take advantage of some of the features of our Website and if you decline or delete them, parts of our website and Premium Services may not function properly. [Even if you decline or delete cookies, you will continue to be served with advertisements; however, they will not be tailored to your preferences, usage patterns or interests.] Where legally permitted, we will assume that you have agreed to receive all cookies on our websites through your continued use; otherwise, your acceptance of such cookies by way of your browser settings or our consent management tool shall be deemed your acceptance of the use of such Tracking Technologies.

Greetr uses several different types of cookies on our websites, including the following.
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I.Strictly Necessary Cookies. Strictly necessary cookies facilitate the operation of our Website. Without the use of these cookies, portions of our Website would not function properly.
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II.Performance Cookies. Performance cookies help us monitor the performance of our Website and how users interact with them. These cookies collect information such as how often users visit our Website, what pages they visit when they do so[, and what other websites they used prior to coming to our Website] and provide us with information that allows us to improve our Services and Website.

III.Functional Cookies. Functional cookies are used to remember your preferences on our Website and to authenticate your identity. For example, we use functional cookies to recognize and save your name and password on our Website.

IV.Flash Cookies. When you use a portion of our Website that employs Macromedia Flash Player, a small Flash Cookie may be used. The purpose of using these cookies is to store your flash player preferences and enhance your browsing experience.

[Although our Website does not currently respond to “do not track” browser headers, you can limit tracking through third-party programs and by taking the other steps discussed in this section. You may opt-out of Greetr’s use of certain cookies and similar Tracking Technologies by removing cookies or by setting your web browser and device settings to refuse cookies and similar Tracking Technologies. Please note that web browsers operate using different identifiers. As such, you must adjust your settings in each web browser and for each computer or device that you would like to opt-out on. Further, if you delete your cookies, you will need to remove cookies from your device after every visit to websites. You may download a browser plugin that will help you maintain your opt-out choices by visiting www.aboutads.info/pmc. You may block cookies entirely by disabling cookie use in your browser or by setting your browser to ask for your permission before setting a cookie. Blocking cookies entirely may cause some websites to work incorrectly.]

Strictly Necessary Cookies. Strictly necessary cookies facilitate the operation of our Website. Without the use of these cookies, portions of our Website would not function properly.
Performance Cookies. Performance cookies help us monitor the performance of our Website and how users interact with them. These cookies collect information such as how often users visit our Website, what pages they visit when they do so[, and what other websites they used prior to coming to our Website] and provide us with information that allows us to improve our Services and Website.
Functional Cookies. Functional cookies are used to remember your preferences on our Website and to authenticate your identity. For example, we use functional cookies to recognize and save your name and password on our Website.

Flash Cookies. When you use a portion of our Website that employs Macromedia Flash Player, a small Flash Cookie may be used. The purpose of using these cookies is to store your flash player preferences and enhance your browsing experience.

[Although our Website does not currently respond to “do not track” browser headers, you can limit tracking through third-party programs and by taking the other steps discussed in this section. You may opt-out of Greetr’s use of certain cookies and similar Tracking Technologies by removing cookies or by setting your web browser and device settings to refuse cookies and similar Tracking Technologies. Please note that web browsers operate using different identifiers. As such, you must adjust your settings in each web browser and for each computer or device that you would like to opt-out on. Further, if you delete your cookies, you will need to remove cookies from your device after every visit to websites. You may download a browser plugin that will help you maintain your opt-out choices by visiting www.aboutads.info/pmc. You may block cookies entirely by disabling cookie use in your browser or by setting your browser to ask for your permission before setting a cookie. Blocking cookies entirely may cause some websites to work incorrectly.]

III.WHAT DO WE DO WITH THE INFORMATION THAT WE COLLECT?

We use, aggregate, and retain your Personal Information as needed to provide you with access to our Website and Services and for other legitimate business reasons. At a high level, we use the Personal Information that has been provided by you directly or indirectly for the following purposes:

To provide you with our Services including, access to prospective employers and their representatives;
To create your account profile and job application history;
To send you satisfaction questionnaires, surveys, and information;

To tailor the content and Services delivered to you based on your activity, interests, and responsibilities;
To operate our Website and improve our Services;
To communicate with you, advertise to you or invite you to join us on social media platforms on which you participate;

To operate our Website and improve our Services;
To understand trends, usage statistics, and other data;
To respond to your Service inquiries or support requests and comments;

To test and evaluate potential new services and features;
To assist with security, fraud prevention and investigations.
To diagnose and resolve problems, analyze trends, and monitor usage and resource needs; and For any other purpose that we tell you about when you give us your Personal Information.

Our Services allow employers to easily communicate with job applicants as they move through the application process. The information that you provide may be used to improve the Services and Website, including your interaction with the Services, communicating with you about new features, and any other purpose for which the information was collected. We may also draw upon this information in order to adapt the Services to your needs, to research the effectiveness of these items, and to develop new features. We may use automated systems to provide content and recommendations to help make our Services more relevant to our Members, thus, it is recommended that Members regularly review and maintain their information within the Services and our Website.

WHO DOES GREETR SHARE YOUR DATA WITH?

Greetr may share information with service providers, affiliates, partners (such as prospective employers, recruiters, and other third parties engaged to further the intent of the Website and Services in line with the information set forth in this Policy), and other third parties where it is necessary to meet the requirements of our EULA, to provide the Services, or for any other purposes described in this Policy.

Customers. As noted earlier herein, as a communication platform, Greetr may share communication and information, including Personal Information that you may share when using the Services with the intended recipient—the Customer with which you are corresponding. Greetr’s contractual arrangements with its Customers, when subject to our standard terms and conditions, require, among other things, that our partners (a) only use this information to contact you for such purposes; and (b) secure and protect your information in accordance with applicable law and our instructions. If you do not want this information shared, please see “Your Privacy Rights and Controlling Your Personal Information” below.
Vendors and Service Providers. Greetr may provide your Personal Information to certain vendors and service providers who are working for or with Greetr as described in this Policy and who require access to such information to facilitate the provision of our services, such as the provision of processing activities or corporate auditing services. Greetr will always attempt to limit the information that we provide to what is reasonably sufficient for those vendors or service providers to carry out their responsibilities as they relate to the fulfillment of our Website and Services.
[Third-Party Analytics. We allow our third-party analytics partners to collect certain information on our websites, as described earlier in this Policy.]

Business Transfers, Affiliates, and Subsidiaries. We may share or transfer the information that we collect in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. We may share your Personal Information within our organization, including with our affiliates and subsidiaries, in order to facilitate the provision of services in connection with your membership and use of our Website and Services.
Vital Interests. We may disclose the information that we collect where we believe that it is necessary in order to protect the vital interests of any person, or to exercise, establish, or defend our legal rights.
Other ways in which you specifically consent. We may share the information that we collect in other ways that you specifically consent.

Legal Compliance and Public Safety. We may share your Personal Information when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (a) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (b) enforce our agreements, (c) investigate and defend ourselves against any third-party claims or allegations, (d) protect the security or integrity of our services; or (e) exercise or protect the rights and safety of our members, personnel, or others. We may attempt to notify members about legal demands for their Personal Information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

V. EMAIL AND TEXT COMMUNICATIONS

By using the Services, you may receive periodic email [and text] communications from Greetr, such as new feature notifications and other information. You may also receive communications within our mobile applications from Greetr. You may opt-out of receiving certain types of emails and messages at any time by following the unsubscribe instructions contained in each message; however, you may continue to receive legally required notices and messages, provided that you continue to have an account in connection with our Services, or otherwise continue to use our Services.

VI. DATA RETENTION

We retain your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain Members’ Personal Information for so long as a Member’s account remains in existence or as needed to provide our Content and Services to our Members, to comply with our legal obligations, to resolve disputes, and to enforce our agreements. We may retain Personal Information after a Member has terminated their membership if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce this Policy, EULA, Terms of Use, and our Order Form, as applicable. We may also retain Personal Information, for a limited period, if requested by law enforcement.

VII. DATA SECURITY

The security of your Personal Information is extremely important to us. Greetr has implemented and maintains reasonable security procedures and practices designed to protect against the unauthorized access, use, modification, destruction or disclosure of your personal information, however, despite these efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. Both Greetr and users of the Services must do their part to ensure the security of data. You should ensure that any Personal Information shared with us is done by way of your Greetr personal account. Additionally, you should secure your account by protecting it with a strong password. You should not disclose your password to anyone. If you have reason to believe that the Personal Information that we hold about you, such as your account with the Services, other program profile(s), or other membership information is no longer secure, please notify us of the problem by emailing us via the feedback function in the app or writing to our physical address in the “Contact Us/Opt Out” section below.

VIII. THIRD PARTY WEBSITES

The Website may contain links to other sites. Greetr does not own or control the content or links that appear on these sites and is not be responsible for the privacy and security practices employed by websites linked to, or from our Website. This Policy does not apply to any such third party apps. The third parties to whom we may provide this information may include commercial partners, sponsors, licensees, researchers and other similar parties. Before visiting or providing Personal Information to third party websites, you should inform yourself of the privacy policies and practices (if any) of that third party app, and should take those steps necessary to, in your discretion, protect your privacy.]

IX. CHILDREN'S PRIVACY

We do not seek or knowingly collect any Personal Information about children under 13 years of age. If we become aware that we have unknowingly collected Personal Information from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our database. If you are under the age of 13, please do not submit any Personal Information through our Services and Website, and rely on a parent or guardian to help you use our Services and Website. If Greetr obtains actual knowledge that it has collected Personal Information from a child under the age of 13, Greetr will promptly delete such information from its database. If you believe that we might have any information from or about a child under 13, please contact us via the feedback function in the Services and Website.

XIII. INTERNATIONAL USERS

EU and UK GDPR Privacy Rights and Controlling Your Personal Data If you wish to access, rectify, erase, restrict, transfer, or object to the use of your information, or deactivate your membership, please access our EU and UK Data Subject Rights Request Form. If you have any other questions in connection with this Privacy Policy or the use of your personal information, please email us at [INSERT]. [Please note that every email sent by Greetr includes information as to how one can unsubscribe from future communications.] Subject to applicable law, you have the following rights in relation to your Personal Data:

Right of Access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
Right to Rectification: If your Personal Data is inaccurate or incomplete, you are entitled to have it rectified or completed. If we have shared your Personal Data with others, we will tell them about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
Right to Erasure: You may ask us to delete or remove your Personal Data and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion, for example if we are required by law to keep it). If we have shared your data with others, we will tell them about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.

Right to Data Portability: You have the right to obtain your Personal Data from us that you consented to give us or that is necessary to perform a contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
Right to Object: You may ask us at any time to stop processing your Personal Data, and we will do so if we are processing your Personal Data for direct marketing and otherwise. However, if we are relying on a legitimate interest to process your Personal Data and we demonstrate compelling legitimate grounds for the processing we may continue; or
Rights in Relation to Automated Decision-Making and Profiling: You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, which produce a significant legal effect on you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us, or with your explicit consent.

Right to Withdraw Consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Your withdrawal of consent will not affect apply to data that was processed prior to our receipt of your withdrawal of consent.
Right to Lodge a Complaint with the Data Protection Authority: If you have a concern about our privacy practices, including the way we have handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

LGPD Privacy Rights If you are a resident of Brazil, the Lei Geral de Proteção de Dados Pessoais (LGPD), Federal Law No. 13,709/2018, may provide you with additional privacy rights with respect to the collection and use of your personal information. If you wish to access, rectify, erase, restrict, transfer, or object to the use of your information, or deactivate your membership, please access our LGPD Data Subject Rights Request Form. If you have any other questions in connection with this Privacy Policy or the use of your personal information, please email us at [sales@greetr.io].

Processing of Personal Data. For data subjects residing in Brazil, these provisions supersede any potentially divergent or conflicting provisions contained elsewhere in this Policy. As it relates to this Section XIII(B), the term “Personal Data” shall be as defined by the LGPD. Greetr processes the Personal Data of data subjects covered by the LGPD in accordance with the principles declared by the LGPD, which include: good faith, purpose, adequacy, necessity, free access, data quality, transparency, security, prevention, non-discrimination and accountability and accountability. To learn more about the categories of Personal Data we process and why we process Personal Data, please see Sections I through IV of this Policy. Subject to the exceptions provided for by law, the LGPD provides for the processing of Personal Data, including by digital means, of an individual or legal entity governed by public or private law, with the aim of protecting the fundamental rights of freedom and privacy, as well as the right to the free development of the personality of the natural person.
Sensitive Personal Data. We will only process Sensitive Personal Data in accordance with the criteria defined by the LGPD, as summarized in this Section: (1) with your consent; (2) in compliance with a legal or regulatory obligation; (3) for the performance of a contract or preliminary procedures related to a contract with the holder; (4) for the regular exercise of rights in judicial, administrative or arbitration proceedings; (5) for the protection of life or for reasons of physical safety; and (6) for fraud prevention purposes and/or to ensure the security of the data subject.
Anonymized Data. The LGPD does not apply to the use of anonymized data, which is generally defined as data relating to a holder who cannot be identified, directly or indirectly, through the use of reasonable technical means available at the time the data is processed.

Legal Basis for Processing. For information about our legal bases for processing Personal Data, please see Section II of this Policy.
Data Subject Rights. Subject to applicable law, you have the following rights in relation to your Personal Data: (1) confirm whether the company processes your personal data; (2) access your personal data; (3) correct incomplete, incorrect or outdated data; (4) carry out the anonymization, blocking or deletion of unnecessary, excessive or processed data that does not comply with the requirements of the LGPD; (5) obtain data portability to another service or product provider, respecting our commercial and industrial secrets; (6) obtain notification about changes in the processing of personal data; (7) review decisions based on the processing of Personal Data carried out exclusively by automated means; (8) delete Personal Data processed with the consent of the holder, except in cases of exceptions provided for in the LGPD; (9) obtain information from public or private entities with which we share your Personal Data; and (10) obtain information about the possibility of providing or denying your consent and the consequences thereof.
Requests. You can exercise the above rights by sending an email to [sales@greetr.io]. You can also make a request through your legal representative. We will do our best to promptly respond to your request. Your rights with respect to information confirming the processing of your Personal Data or access to your Personal Data will be forwarded by Greetr, as soon as possible, in a simplified form, or within 15 days after receiving your request. If you submit a request for rectification, deletion, anonymization or blocking of Personal Data, we will ensure that your request is immediately communicated to other parties with whom we share your Personal Data, in order to allow third parties to also be able to fulfill your request – except in cases where such communication is demonstrably impossible or involves disproportionate effort on our part.

ANPD. You also have the right to petition the National Data Protection Authority (ANPD) regarding the processing of your Personal Data by Greetr. A Data Subject may, in addition, file a judicial appeal for alleged violations of applicable law.
Data Retention. For information about our data retention practices, please see Section VI of this Policy.
Security. For information about our data security practices, please see Section VII of this Policy. Please note that, should an incident occur involving Personal Data, where the matter relates to Brazilian residents and involves compliance with the LGPD, we will notify the data subject and the ANPD, in accordance with applicable legal provisions.

International Transfers. For information about the transfer of Personal Data, please see Section XIII(C).

Transfer of Personal Data

IXX. Your Privacy Rights and Controlling Your Personal Information

If you would like Greetr to delete your Personal Information from its system, please contact us at the address included in the “Contact Us/Opt Out” section below or via the feedback function in the app with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request; however, we may retain an archived copy of your records as required by law or for other legitimate business purposes. In order to use the Services to its full potential, we need to ensure that your Personal Information is complete and accurate. By using the Services, you represent and warrant that all information you provide in connection with your use of the Services and Websites will be complete and accurate, and that you will update that information within the Services and Websites as necessary or able to maintain its completeness and accuracy. If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for their direct marketing purposes.  For California residents, additional disclosures required by California law may be found in our California Privacy Notice. To request a list of the names and addresses of third parties to whom we disclosed such information during the preceding calendar year along with a list of the categories of information disclosed, please send an email to [INSERT] or write to us at the address listed in Section XXIII below.

XXI. REVISIONS AND MODIFICATIONS TO THIS POLICY

We may modify or amend this Policy from time to time. If we change our Policy, we will post those changes in addition to updating the “Last Updated” date at the top of this Policy. We encourage you to read this Policy regularly. Where applicable, your continued use of our Services and Website shall constitute your acceptance of the modified or amended Policy. If there will be any changes made to the use of your Personal Information in a manner materially different from that stated at the time of collection, we will notify you by posting a notice on our website.

XXII. ACCEPTANCE OF POLICY

By using our Services and Website, you signify your acceptance of this Policy. If you do not agree to this Policy, please do not download, install or use our Services and Website.

XXIII. CONTACT US/OPT OUT

Greetr respects your privacy rights. If you have any questions about this Policy or the use of your information, or if you would like to opt out of the collection of your Personal Information or request that your Personal Information be deleted from the Services and Website, please write to us via the feedback function in the app or at the address provided below. We will attempt to respond to all questions in a timely manner. Please note that you will be unable to use the Services and Websites once your information has been deleted
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Greetr, Inc.
177 Huntington Avenue #170
Boston, MA 02115-3134
Email Address: sales@greetr.io
Phone No.: [617-435-9950]
Effective: [3/1/2023]