Privacy Policy 2.01

Opensense is software platform that unlocks email signatures as a marketing channel and helps businesses manage email signatures & disclaimers for IT, legal, and compliance.

This Privacy Policy applies to Opensense, Inc. and its affiliates and subsidiaries (“Opensense,” “we,” “us,” or “our”) and explains how we collect, use, disclose, secure and otherwise process personal information from individuals, in connection with our website and corresponding services(collectively, the “Services”), and the rights and choices available to individuals with respect to their information.

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Personal Information We Collect Directly from You

The information we collect from you directly is classified in the category of “Personal information”. This data category includes consumer name, mailing address, email address, phone, and other similar information. We collect that information in several ways:

• 1. We collect 'personal information’ when you complete forms or request information from us through our Services
• 2. When you contact us to report a problem with our Services
• 3. When you contact our customer support or otherwise correspond with us by phone, email, or other means.

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We collect this identifying information for the purpose of providing the services and information you are requesting. We also use this information when communicating with you and responding to any inquiries that you have initiated.

We are also required under Californian and similar laws to specifically disclose the categories of information that we have collected and sold or disclosed for any commercial purpose for the prior twelve-month period. We do not sell or disclose ‘personal information’ or any other category of collected personal information for any commercial purpose or for the commercial benefit of any party. We have not done so in the past12-months or at any time prior to that.

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What we collect about you from other sources. We also collect information about you indirectly from other sources. We collect that information in several ways:

• 1. When you connect to a social media platform through the interfaces we provide on our Services
• 2. Through any referral section of our Services
• 3. Through cookies and other automated means

Our Services include interfaces that allow you to connect with us through social media. If you connect to us through a social media platform, you allow us to access, use and store the information that you agreed the social media platform could share based on your settings on that respective social media platform. We will access, use and store that information in accordance with this Privacy Policy. If you choose to revoke our access at anytime you may do so by amending the appropriate settings from within your account settings on the applicable social media platform, to which we have not access to..

We may get your name and email address through various areas of our website. We may add this to information we get from our Services to offer you products and services that may be of interest to you or to invite you to events or webinars that may be of interest to you. In addition to Personal information we collect:

• 1. Commercial Information (browsing patterns)
• 2. Geographic Information (for localization and market perspective)
• 3. Internet, Network, Technical information (information about your device for better interaction with it)
• 4. Employment related information (title, role, office location and contact information)
• 5. Inferential data(about your interests).
• 6. Personal information as described by applicable privacy laws, including the CCPA, the GDPR, or UK Privacy Law.

As an example of our data collection practices we may log your computer or mobile device IP address, geographic location (should you choose to provide it), operating system name and OS version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Services, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Services.

We collect this information for the purposes of better understanding our market, global distribution, technology and our prospective customers’ and customers’ wants and needs.

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Changes to Your Personal Information

It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us by updating your registration profile or emailing us at the email below.

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Cookies and Similar Technologies

What are cookies?

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We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies(which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Services. We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Services; and (2) third party cookies, which are served by service providers on our Services, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

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Cookies we use

Our Services use the following types of cookies for the purposes set out below:

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Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools,” or “edit” facility). Many browsers are set to accept cookies until you change your settings. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit allaboutcookies.org.

If you do not accept our cookies, you may experience some inconvenience in your use of our Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.

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Pixel Tags

We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Services to track the actions of users on our Services. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Services, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal data.

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How We Use Your Personal Information

To operate the Services

We use your personal information to:

• 1. operate, maintain, administer, improve, and secure the Services;
• 2. study how the Services are used and to improve the Services and our other products;
• 3. manage and communicate with you regarding your account on the Services, if you have one, including by sending you service announcements, technical notices, updates, security alerts, and support and administrative messages;
• 4. better understand your needs and interests, and personalize your experience with the Services;
• 5. provide support and maintenance for the Services;
• 6. respond to your service-related requests, questions and feedback.

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To send marketing communications

If you request information from us or register for an account on the Services, we may send you Opensense-related marketing communications as permitted by law. You will have the ability to opt out or unsubscribe of such communications at any time.

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To provide a requested service

If you request a service through the Services, such assigning up for our newsletter, we may request personal information that we need to provide the requested service.

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To comply with law

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

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With your consent

We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Services, you instruct us to take a specific action with respect to your personal information, or you opt into third-party marketing communications.

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For compliance, fraud prevention and safety

We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Services;(b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

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How We Share your Personal Information

Except as described in this Privacy Policy, we do not share the personal information that you provide to us with other organizations. We disclose personal information to third parties under the following circumstances:

• 1. Service Providers. We may employ third-party companies and individuals to administer and provide the Services on our behalf (such as hosting, email delivery and database management services).These third parties may only use your information as directed by Opensense and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.
• 2. Compliance with Laws and Law Enforcement; Protection and Safety. Opensense may disclose information about you to government or law enforcement officials or private parties as required bylaw, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Service; (d)protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. See Our Transparency Report for more information.
• 3. Business Transfers. Opensense may sell, transfer or otherwise share some or all of its business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.

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Your Choices

‍Access, update, correct or delete your information: we are happy to provide you information about whether We hold, or process on behalf of a third party, any of your personal information. If Your Personal Information changes, or if You no longer desire Our Services, You may correct, update, or delete it by emailing us and we will respond in a timely manner.

‍Marketing communications: you can always opt-out of marketing related emails by unsubscribing, however you may continue to receive service-related and other non-marketing emails.

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Choosing not to share your personal information

Where we are required by law to collect your personal information, or where we need your personal information in order to provide a requested service to you or operate the Services, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the requested service(s) or operate the Services. We will tell you what information you must provide to receive a requested service or interact with the Services by designating it as required on the Services or through other appropriate means.

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Security

The security of your personal information is important to us. We use a variety of industry-standard technical, contractual, administrative and physical security measures and procedures to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information. If You have questions about Our security measures in place, please contact us at the email below.

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Children

Our Site is not directed to children under 14. If a parent or guardian becomes aware that his or her child has provided us within formation without their consent, he or she should contact us at the email below. We will delete such information from our files as soon as reasonably practicable.

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International Transfer

Opensense is headquartered in the United States and has service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, country, or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction. European Union users should read the important information provided in this Privacy Policy about the transfer of personal information outside of the European Economic Area.

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Other Services and Services

The Services may contain links to other websites and services. These links are not an endorsement, authorization, or representation that we are affiliated with that third party. We do not exercise control over third-party websites or services and are not responsible for their actions. Other websites and services follow different rules regarding using or disclosing the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and the services you use.

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User-Generated Content

We may make our services available or link to features that allow you to share information online (e.g., on publicly accessible blogs or community forums). Please be aware that whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over and take no responsibility for, the use, storage, or dissemination of such publicly disclosed personal information. You may receive unsolicited messages from other parties by posting personal information online in public forums.

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Changes to this Privacy Policy

We are required to review and update and will review and correct, this policy at least annually or if there is any substantive change to our data collection and processing practices. We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices.

If we make material changes to this Privacy Policy, we will notify you in a manner that we believe will be reasonably likely to reach you (which may include posting a new privacy policy on our Site – or a specific announcement on this page or our blog). Any modifications to this Privacy Policy will be effective upon our posting of the new terms (or as otherwise indicated at the time of posting). By continuing to use the Services, you agree to be bound by the updated changes to the privacy policy.

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Contact Us

If you have any questions or concerns at all about our Privacy Policy, please feel free to email us at privacy@opensense.com or write to us at Opensense, Inc, 1390 Market St., Suite 200, San Francisco, CA 94102.

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Additional Information for UK and European Union Users

Personal information

References to “personal information” in this Privacy Policy are equivalent to “personal data” as defined by the European Union General Data Protection Regulation 2016/79 (“GDPR”), and any laws or regulations that amend, supplement, supersede, repeal or replace the GDPR or that are intended to ensure the continued application of the GDPR in the United Kingdom once it ceases to be a member state of the European Union (including the Data Protection Act 2018 (collectively, “UK Privacy Law”). We are the processor of your personal information for GDPR and UK Privacy Law purposes.

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Legal bases for processing

We only use your personal information as permitted bylaw. We are required to inform you of the legal bases of our processing of your personal information, which are based on one or more of the following:

• 1. Consent: The consent you provide to us when you share or submit your personal information with or to us;
• 2. Legitimate interest: Our “legitimate interest,” as defined by GDPR and UK Privacy Law, or the legitimate interest of a third party, including you. For example, we may use your data for fraud and security monitoring to ensure our networks and websites are secure, administer and conduct our business with you, and respond to your requests, inquiries, and complaints.
• 3. Contract: Our contract performance, directly or indirectly, between us and you or your employer.
• 4. Legal Obligation: Our compliance with a legal obligation that we are or may be subject to.

If you have questions about the legal bases of how we process your personal information, contact us at the email below.

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Use for new purposes.

We may use your personal information for reasons not described in this Privacy Policy where permitted by law, and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

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Your rights

GDPR and UK Privacy Law gives you certain rights regarding your personal information. You may ask us to take the following actions concerning your personal information that we hold:

• 1. Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.
• 2. Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• 3. Correct. Update or correct inaccuracies in your personal information.
• 4. Delete. Delete your personal information.
• 5. Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• 6. Restrict. Restrict the processing of your personal information.
• 7. Object. Object to our reliance on our applicable legal bases (see list of legal bases above) for processing your personal information.

You can submit these requests by email to email address below or our mailing address. You may also contact our Data Protection Representative(see here for more information). We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we reject your request, we will tell you why subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us as described above or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

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Cross-Border Data Transfer

Whenever we transfer your personal information out of the European Economic Area (EEA) to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on one of the following safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation:

• 1. The consent you provide to us when you share or submit your personal information with or to us and when you visit our Services;
• 2. Contracts approved by the European Commission which impose data protection obligations on the parties to the transfer. For further details, see the European Commission Model contracts for the transfer of personal information to third countries; or
• 3. Other valid and applicable safeguards under GDPR and UK Privacy Law.
• 4. Standard Contractual Clauses

Please get in touch with us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

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Additional Information for Californian Consumers

The California Consumer Privacy Act (Assembly Bill 375),as amended (“CCPA”), affords Californian consumers specific rights regarding their personal information. These rights have been described in this Privacy Policy and are further highlighted in this section.
If you need to access this notice in an alternative format, please contact us at privacy@opensense.com.

Do Not Sell My Info

We do not, and will not, sell – as defined under CCPA –your personal information (see below for further info).

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What is Personal Information under CCPA

“Personal information” is anything that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Californian consumer or household.

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Privacy Policy

We provide this Privacy Policy to describe our activities about the personal information we collect and use and to inform you of your rights regarding your information. You have the right as a Californian consumer to expect the Privacy Policy to be available, accessible and easy to understand, and reviewed and updated at least annually describing our personal information collection activities over the prior 12 months. If our business changes or additional processing for new purposes are planned, you have the right to expect an update to the Privacy Policy to be provided describing these purposes.

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How We Obtain Your Data (Please see the following sections)

• 1. What data we collect directly from you
• 2. What data we collect about you from other sources
• 3. Cookies
• 4. Children

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Note on Children

The CCPA requires opt-in consent to information use for minors under the age of 16 and verified parental consent for children under the age of 13. We do not knowingly collect or process the information of children.

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‍Your Rights under CCPA regarding Your Personal Information

You have the right as a Californian consumer to expect disclosures as to how we collect, use and care for your personal information, our purposes for collection and what we do with the information we collect, and in specific, if your information is sold to other parties.

California law provides you as a consumer specific rights with regard to the management and sale of your personal information. You have the right as a Californian consumer to expect disclosures as to whether we for our benefit or on behalf of another company, share or sell the personal information we collect or process for commercial gain. The law imposes on certain businesses an obligation to provide the means by which these rights can be exercised.

You may ask that we or partners for whom we process or those working on our behalf take specific actions with regard to the information about you.

• 1. You may exercise these rights without concern. You cannot be charged for these requests, penalized in any way, denied benefits, products or services or charged differently for benefits, products or services for doing so.
• 2. You can do this by contacting us as described here or here.
• 3. You, or your authorized agent, may request the following actions in relation to your personal information:
• ~3.1. Opt-out. Discontinue the sharing, transfer, disclosure or sale of your information and not be contacted to request the resumption of those activities for at least 12-months.
• ~3.2. Request to Know. Provide you with information about what we hold and the processing of your personal information.
• ~3.3. Request to Delete. You have the right to request that we erase your personal information and for us to direct the same of any third-party service providers processing your information on our behalf.
• ~3.4. Portability. Request that any information held be returned by mail or electronically, and if electronically held, be returned in a format permitting its transfer to another service.

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Verifying Your Identity

Please note that after submitting your initial request we may require additional information about your identity if we cannot verify it with the information you submitted and the information we already have. We are restricted from using that additional information for any purpose other than verifying your request or for security or fraud prevention. Except as required under CCPA, we must delete any additional information collected for the purpose of verifying your identity as soon as practical after processing your request. We will confirm receipt of your request within ten (10) days from receiving it and will respond within the timelines established under CCPA.

We, or our partners, on verification of your identity and legitimate standing to make the request, and if not an undue or unreasonable hardship for us, must act on your request, or at a very minimum, advise you as to why we cannot. There are specific reasons under the law which prevent accommodation of some requests, but if denied, we will advise as to why, to whom you may submit a complaint, and your options for challenge, redress or escalation.

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Exercising your rights

If you have a specific question or concern about your rights, or questions about our Privacy Policy in support of your rights as a Californian consumer or wish to exercise your rights as a Californian consumer, please contact us by using the means included in the contact us section or using the online request available [here]. You may exercise these rights twice in a 12-month period. If an option is available to compensate you for the use of your information, you must be advised of this. We will make best efforts to address your requests within 45 days, but where that is not possible will advise you of the need for n extension of an additional 45 days.

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Inquiries, data or information requests, complaints

If you have questions, would like to submit an inquiry, data or information request(s), or have a complaint about our use of your personal information or our response or handling of your requests regarding your personal information, you may contact us as described here. You can also submit a complaint to the California Office of the Attorney General here. For more information on the California Consumer Privacy Act please visit https://www.oag.ca.gov/privacy/ccpa