Privacy Notice

1. SCOPE AND UPDATES TO THIS PRIVACY POLICY

This Privacy Policy applies to personal information processed by us, including on our websites, services, and other online or offline offerings (collectively described as the “Services”). Unless specifically described herein, this Privacy Policy does not apply to personal information that our customers provide in using our Services (“Customer Data”), which is instead governed by the customer’s respective privacy policies regarding their collection and use of Customer Data. Our processing of Customer Data is governed bythe contracts that we have in place with our customers, not this Privacy Notice. Any questions or requests relating to Customer Data should be directed to the relevant customer’s legal or privacy team.

Changes to our Privacy Policy. Wemay revise thisPrivacy Policy from timetotimein our sole discretion. If there are any material changes to this Privacy Policy, we will notify you to the extent required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

2. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain

automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us, including the following as applicable:

• Account Creation. We may collect personal information when you create an account, such as name, email address, username(s), and professional details.

• Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third- party paymentprocessors.We do not directly collect orstoreany paymentcard information entered through our Services, but we may receive information associated with your payment (e.g., name, billing address).

• Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or educational programs or other offerings, request customer or technical support, or otherwise communicate with us.

• Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.

• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provideusing the publicsharing featuresofthe Serviceswillbeconsidered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.

• Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.

• Conferences, Trade Shows, and Other Events. Wemaycollect personal information from individuals when we attend or host conferences, trade shows, hackathons, socials or happy hours, and other events.

• Business Development and Strategic Partnerships.We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

• Job Applications. We may post job openings and opportunities. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use our Services.

• Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address),and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.

• Cookie Policy (and Other Technologies).We, as well as third parties that provide content, advertising, or other functionality on our Services,may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services.

  • Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.

  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
    Our uses of these Technologies fall into the following general categories:
    

    • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;

    • Performance-Related. We may use Technologies to assess the performance of our Services, including analytics to help us understand how individuals use our Services (see Analytics below);

    • Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;

    • Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party digital properties.
      See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

  • Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services.Some of our analytics partners include:

    • Google Analytics. For more information abouthow Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data),please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

C. Personal Information Collected from Other Sources

Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations.For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings.

3. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services

We use your information to fulfill our contract with you and provide you with our Services, such as:

• Managing your information and accounts;

• Providing access to certain areas, functionalities, and features of our Services;

• Answering requests for customer or technical support;

• Communicating with you about your account, activities on our Services, and policy changes;

• Processing your financial information and other payment methods for products or Services purchased;

• Processing applications if you apply for a job we post on our Services; and

• Allowing you to register for educational programs or other events, offerings, programs, or communities.

B. Administrative Purposes

We use your information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

• Detecting security incidents, protecting against malicious deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

• Measuring interest and engagement in our Services;

• Improving, upgrading, or enhancing our Services;

• Developing new products and services;

• Ensuring internal quality control and safety;

• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;

• Debugging to identify and repair errors with our Services;

• Auditing relating to interactions, transactions, and other compliance activities;

• Sharing personal information with third parties as needed to provide the Services;

• Enforcing our agreements and policies; and

• Carrying out activities that are required to comply with our legal obligations.

C. Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we may market to you include email campaigns, text messages, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.

If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

D. With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

E. Other Purposes

We also use your personal information for other purposes as requested by you or as permitted by applicable law.

• De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information, such as information about the device from which you access our Services, or other analyses we create.

4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide our Services

The categories of third parties with whom we may share your personal information are described below.

• Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and
  vendors that provide us with IT support, authentication, security, hosting, payment processing, analytics, alerting, customer service, and related services.

• Third-Party Services You Share or Interact With. Certain features and functionalities of the Services may link to or allow you to interface, interact, or share information with, access and/or use third-party websites, services, products, and technology (collectively, “Third-Party Services”). Any information shared with or otherwise collected by a Third-Party Service may be subject to the Third-Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.

• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with
  business partners with whom we jointly offer products or services.

• Affiliates. We may share your personal information with our company affiliates, if any.

• Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”

• APIs/SDKs. We may use or offer third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the Services. For more information about our use of APIs and SDKs, please see https://docs.blocklens.io/.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information associated with you to external parties if we, in goodfaith,believe doing so is required orappropriateto:comply with law enforcement ornational security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owedtous; or assist withan investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices.The privacy choices you may have about your personal information are determined by applicable law and are described below.

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email or otherwise by contacting us as forth in “Contact Us” below to opt out of receiving future emails. Note that you will continue to receive transaction- related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy).

• Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or otherwise by contacting us as set forth in “Contact Us” below.

• Phone Calls. If you receive an unwanted marketing phone call from us, you may opt out of receiving future phone calls from us by following the instructions which may be available on the call or otherwise by contacting us as set forth in “Contact Us” below.

• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

• Cookies and Personalized Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits.
  However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. 

Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

• Access to and Portability of Your Personal Information, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal
  information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”);

• Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;

• Request Deletion of your personal information;

• Request Restriction of or Object to our processing of your personal information; and

• Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and willnot affect the lawfulness of processing before your withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in“Contact Us” below. We will process such requests in accordance with applicable laws.

6. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. However, we do not warrant or guarantee the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

7. INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to the United States or other countries that may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of the applicable laws.

8. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services,resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

9. CHILDREN’S INFORMATION

The Services are not directed to children under 16 (or other age as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.

10. OTHER PROVISIONS

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

11. CONTACT US

Blocklens is the controller of the personal information we process under this Privacy Policy. If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at [email protected].