This privacy policy (this “Privacy Policy“) governs how NetImpact Strategies, Inc. (“NetImpact” “we“, “our“, or “us“) collects, uses, and treats Personal Information (as defined below) that you provide to us: (i) through our website at https://netimpactstrategies.com (our “Website“); or (ii) while using the services and information available via our Website or in other instances in which we notify you that this Privacy Policy apply (collectively, the “Services“) (the Services, together with our Website, our “Platform“). This Privacy Policy establishes our rights and obligations with respect to your personal information, and lets you know your associated rights.

1. Scope of this Privacy Policy.
   1. Application of this Privacy Policy. Our Privacy Policy applies to anyone that uses or visits our Platform (collectively, “you“), subject to Section 1.2 (Exclusions from this Privacy Policy), including the following:
      • Our existing clients, prospective clients, and their agents or other authorized representatives (collectively, “Clients“);
      • Our contractors, vendors, and other service providers (collectively, “Service Providers“); and
      • Our visitors of our Website (collectively, “Site Visitors“).
   2. Exclusions from this Privacy Policy. This Privacy Policy does not apply to: (i) our application(s) and other offerings, the use of which is governed under separate terms and conditions, including, for example, end user license agreements (EULAs); or (ii) our current employees providing us information with respect to their employment with us. Moreover, if we provide you with links to other websites, then they are solely for your convenience and reference and we are not responsible for the privacy practices or content on, or accessed through, such links or websites.
2. Your Consent to this Privacy Policy. You indicate your consent to this Privacy Policy in different ways, depending on your relationship with us, as set forth below.
   1. Your Consent If You are a Site Visitor. By accessing and using our Website as a Site Visitor, you are acknowledging that you have read and understood this Privacy Policy, and agree to be legally bound by it. If you do not agree with the terms of this Privacy Policy, please refrain from accessing or using our Website. In addition, for certain Services or components of our Website, we may further confirm your consent by asking you to click an “I accept” or a similar button.
   2. Your Consent If You are Not a Site Visitor. Except as provided in Section 2.3 (Consent by User Acting in a Representative Capacity), your consent to, and your affirmative agreement that you have read and agree to, this Privacy Policy shall be by providing us information in connection with our business. By providing us information, including Personal Information, in connection with the Platform you are affirmatively agreeing that you have read and agree to this Privacy Policy, and to be legally bound by it.
   3. Consent by User Acting in a Representative Capacity. If you are agreeing to our Privacy Policy on behalf of a company or other legal entity (“Your Organization”), then (i) you represent and warrant that you have authority to act on behalf of, and to bind Your Organization, and (ii) for all purposes in this Privacy Policy, the term “you” means Your Organization on whose behalf you are acting.
   4. Right to Withdraw Consent. You have the right to withdraw your consent at any time, in accordance with Section 11 (Your Choices Regarding Your Personal Information; Opting Out).
3. The Information We Collect. The information that we collect about you falls into certain categories as further described in this Section 3 (The Information We Collect). This information consists of the following:
   1. Personal Information. We may collect certain information that identifies you as an individual (collectively, “Personal Information“). The Personal Information we collect may include the following:
      • Your name and email address;
      • Your other contact information, including a mailing address and phone number;
      • Information you may submit to us in connection with your job application; and
      • Geolocation information.
   2. Online Activity Information. We may also collect technical and device-related information through our Platform (collectively, “Online Activity Information“). Online Activity Information is typically collected automatically by technical means and, subject to Section 3.4 (Treatment of Combined Information), for purposes of our Platform, may consist of the following:
      • Device identifiers, such as cookies;
      • Device information, such as hardware and software settings;
      • IP addresses and log information, such as your device’s name, the type and version of your web browser, and referrer addresses that can function to identify a user device; and
      • Tracking information that we, or a third party, may collect.

      To the extent that statutes, regulations, and any other laws that apply to the Services (collectively, “Applicable Law“) establish that Online Activity Information constitutes Personal Information, and such Applicable Law applies to information we collect from you, then we will treat the relevant Online Activity Information as Personal Information. In addition, sometimes Online Activity Information can be associated with your Personal Information, in which case we will treat it as Personal Information (as described in Section 3.4 (Treatment of Combined Information)). Otherwise we consider, and treat, Online Activity Information as Anonymous Information.

   3. Anonymous Information. Our Website also collects, processes, and/or uses information that does not identify you or your devices, including Personal Information that has been made anonymous by: (i) removing identifying fields and aggregating the information with other information so that individual subjects of the information cannot be re-identified, or (ii) anonymizing the information with techniques that remove or modify the identifying data so as to prevent re-identification of the anonymized information (collectively, “Anonymous Information“). Information that meets these criteria might include, for example, demographic information, statistical information (e.g., page views and hit counts), and general tracking information. We use Anonymous Information for our business operations. Because Anonymous Information does not include Personal Information, Anonymous Information is outside the scope of this Privacy Policy.
   4. Treatment of Combined Information. To enable us to better understand the characteristics of our users and/or to conduct the business, we may link your Personal Information with Online Activity Information associated with you or other Anonymous Information. If we combine or associate Online Activity Information or other Anonymous Information with your Personal Information, then we will treat the resulting combination as Personal Information.
4. How We Collect this Information. We collect the above information through the following means and technologies:
   1. Contacting Us. You can contact us with questions or comments. In order to communicate with us, you must provide certain Personal Information. By communicating with us for these purposes, you may provide us with your name, email address, and other Personal Information. In these instances, we use any information you provide to us for the purposes for which you submit the information.
   2. Questionnaires and Surveys. We may allow you to participate in surveys and questionnaires, which we may post on the Website or otherwise provide to you from time to time. You are free to choose whether to participate in a survey or questionnaire. We may ask that, in addition to providing your responses, you also provide Personal Information. In these instances, we use any information that you provide to us for the purposes for which you submit the information. Survey and questionnaire information may be used for the purposes of monitoring or improving our business. As further set out in Section 11 (Your Choices Regarding Your Personal Information; Opting Out), please understand that you will not be allowed to “opt out” of formal notices related to our business, such as those concerning the operation of the Website, legal notices, and other related notices concerning your relationship with us.
   3. Job Applications and Inquiries. You may submit to us Personal Information in connection with job applications and if you have questions for us. In each case, we collect the information you submit to us for various purposes, including to respond to your inquiries or to consider your candidacy for our employment opportunities.
   4. Newsletters. We may offer newsletters and other content that we believe may be of interest to you. We will use your Personal Information to provide you with this content. You can opt-out of receiving this content by following the instructions set out in Section 11 (Your Choices Regarding Your Personal Information; Opting Out).
   5. Submitted Content. As further set out below, we may provide you with the ability to submit content to us for our internal use or to submit content to us for public consumption (collectively, “Submitted Content“). If you include any Personal Information relating to others in your Submitted Content, then you represent that you have full permission and authority to do so.
      1. Submitted Content Provided to Us for Internal Use. We may provide you with the ability to submit Submitted Content to us (either directly or through a third party service), and we may also provide content to you, in order for us to better provide Services. For example, we may allow you to provide us with feedback related to the business. If you provide us with such Submitted Content, we will protect it in accordance with this Privacy Policy.
      2. Submitted Content Provided to Us for Public Consumption. We may give you the ability through our Website or a third party social media platform, to engage with us and others in public exchanges by providing Submitted Content. For example, we believe that your experiences with us can often act as the strongest promotion for our Services. To promote and illustrate our Services, we may wish to incorporate in our success stories or otherwise post on our Website or elsewhere, your endorsements or your other descriptions of experiences with us, as well as comments, feedback, and other information that you wish to share. Please understand that, if you include Personal Information in such Submitted Content, others will be able to read, collect, re-publish, and otherwise freely use such Personal Information. We are not responsible for Personal Information that you decide to include in such Submitted Content, and we will not take down, remove, or edit Submitted Content, except as required by applicable law.
   6. Cookies. A cookie is a small amount of data that is sent to your browser from a website’s computers and stored on your computer’s hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. We may include cookies on our Website and use them to recognize you when you return to our Website. You may choose not to accept cookies; however, you may need to enable cookies if you wish to access certain personalized features of our Website.
   7. IP Addresses; Logs. We may automatically receive and record information in our server logs from your browser or mobile device, including your IP address (the Internet address of your computer), your computer’s name, the type and version of your web browser or mobile device operating system, referrer addresses, and other generally-accepted log information. We may also record page views and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Website is being used, and for security and monitoring purposes.
   8. Tags. We may use so-called “pixel tags” – small graphic images (also known as “web beacons” or “single-pixel gifs”) – to tell us what parts of our Website have been visited or to measure the effectiveness of searches you perform on our Website. Pixel tags also enable us to send email messages in a format that you can read and they inform us whether emails have been opened. Pixel tags also help us ensure that our messages are of interest to you.
   9. Click-Throughs. We may send email messages, which use a “click-through URL” linked to content related to our business. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We may track this click-through data to help determine interest in particular topics and to measure the effectiveness of our customer communications.
   10. Configuration. In order to determine whether your computer or other device is supported by our system, we may collect certain Anonymous Information. This information includes, but may not be limited to, your operating system and browser, the presence of any software that our Website may require to operate with your computer or other device, or other third party software on your computer or mobile device.
   11. Other Uses. In addition to the uses specifically identified in this Section 4 (How We Collect this Information), there may be instances where you request information or other Services from us that are not described in this Privacy Policy. In that instance, we will use Personal Information that you submit in order to provide such information or Services to you.
   12. Information Provided to Third Parties. As explained further in Section 7.1 (Our Service Providers), we may engage third parties to perform certain services for us or on our behalf. The forms on our Website may be managed by such third parties, and we may obtain from the applicable service provider the information that you provide using such forms.
   13. Provision of Personal Information Offline. We may ask you to provide us with Personal Information via offline interactions. Personal Information we collect in this manner may include, for example, your name, username, email address, and other identifying information. If you provide information to us at our request, then we will strive to provide you with either verbal and/or written notice of this Privacy Policy upon your request for a copy of the Privacy Policy. We treat any information that you provide to us as Personal Information under this Privacy Policy.
5. How We Use The Information We Collect. We use the information that we collect or process, including Personal Information, Online Activity Information, and Anonymous Information, as permitted under applicable law and consistent with the terms of this Privacy Policy. More specifically, we use the information we collect for the following purposes:
   • To provide you with the Services you request and to communicate with you regarding our Services;
   • To use, and to allow you to provide us with, Submitted Content for purposes set out in Section 4.5 (Submitted Content);
   • To respond to your inquiries;
   • To customize and enhance your use of our Platform, such as by personalizing your experience with us;
   • To provide communications that might interest you, including marketing messages and to inform you of services that we think would be appealing to you, whether the services are provided by us or by others, and whether the services are available via NetImpact or a third party;
   • To perform analytics, quality control, market research, and to determine the effectiveness of our Services and promotional campaigns, to improve our Platform, and to develop new services;
   • To perform internal administration, auditing, operation, and troubleshooting; and
   • To share the information to third parties as permitted in this Privacy Policy

   In addition to the uses specifically identified above, there may be instances where you request information and Services from us that are not described in this Privacy Policy. In our discretion, we can use information that you submit in order to provide such information and Services.

6. Other Essential or Internal Uses of Information. We may also use the information that we collect as we believe to be necessary or appropriate for certain essential purposes, including:
   • To comply with applicable law and legal process;
   • To respond to requests from public and government authorities;
   • To detect, prevent, or investigate potential security incidents or fraud;
   • To facilitate the functionality of our Platform;
   • To enforce our terms and conditions;
   • To protect our operations or those of our affiliates;
   • To protect our rights, privacy, safety or property, security and/or that of our affiliates, you or others; and
   • To allow us to pursue available remedies or limit the damages that we may sustain.
7. How We Disclose this Information. We value your privacy, and we share the information we collect only in the manner set out below.
   1. 1. Our Service Providers. We engage third parties to perform functions on our behalf, and these may include maintaining the Platform, collecting information, responding to and sending email or other messages, and other functions useful to our business. In this capacity, we may provide service providers with Personal Information, Online Activity Information, and Anonymous Information (as applicable). The following are examples:
         • Our Platform may include links to third party websites, such as those offering services that augment those Services offered on our Platform, and plug-ins that integrate with third party resources, such as CMS applications and associated tools.
         • We may use service providers to: (i) provide customer service (where applicable); (ii) process and distribute email and newsletters; (iii) manage marketing and similar activities; (iv) provide you with access to various forms and platforms on which to perform activities, including registering for webinars and other events that we may provide or make available; and (v) assist in organizing and hosting events and programs. These service providers generally require access to your Personal Information in order to perform these services.
         • We may use analytics service providers to assist us in understanding and using Online Activity Information and other information that we collect via the Platform.
         • We may use service providers to anonymize and aggregate Personal Information in order to generate Anonymous Information.

         We require our service providers to contractually commit to protect the privacy and security of the Personal Information they process on our behalf.

      2. Questions of Harm; Legal Process. We may disclose your Personal Information and Online Activity Information to third parties, including law enforcement agencies, attorneys, and private investigators, where it is necessary, or where we have a good faith belief that it is necessary to: (i) comply with legal process; (ii) protect and defend our rights and property, including the Platform and associated content; (iii) protect against misuse or unauthorized use of our Platform and associated content; (iv) protect the personal safety or property of Platform users or the public, including your personal safety or property (it being understood that we assume no duty to provide, or monitor the need for, such protections); and (v) cooperate with public and government authorities including, where required, authorities outside your jurisdiction.

   While you are not able to opt out of this use of information, we will take reasonable steps to limit such use, and disclose only the information we reasonably believe is necessary for the above purposes. If we receive legal process calling for the disclosure of your Personal Information, then we will attempt to notify you within a reasonable amount of time, unless such notification is not permitted.

   1. Corporate Transactions. We shall be entitled to transfer information that we collect (including Personal Information) to a third party in connection with or in contemplation of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition (including a disposition in connection with a bankruptcy or similar proceedings) of all or substantially all assets or stock of the business unit or division responsible for the information under this Privacy Policy; provided the acquiring third party has agreed to safeguard your Personal Information with protections that are compatible with those set out in this Privacy Policy.
   2. Our Affiliates. We may choose to rely on and share the information we collect with our affiliates. By “affiliate” we mean an entity that is closely related to us, such as an entity that controls, is controlled by, or is under common control with, NetImpact. Our affiliates will be bound by the terms of this Privacy Policy
8. How We Safeguard the Information We Collect. We recognize the sensitivity of our users’ Personal Information and we have put in place security systems designed to prevent unauthorized access to or disclosure of this information. Our security systems include physical, technical, and administrative information security controls, and we take commercially reasonable steps to secure and safeguard such Personal Information in accordance with applicable law.
9. Our Retention of Data. We retain Personal Information for the period of time necessary to fulfill the purposes for which we obtained the Personal Information and consistent with applicable law. We use the following criteria to set our retention periods: (i) the duration of our relationship with you; (ii) the existence of a legal obligation as to the retention period; and (iii) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations).
10. Accuracy and Minimization of Data. We take reasonable steps (i) to maintain the accuracy of the Personal Information we process, and (ii) to limit the Personal Information that we process to that which is reasonably necessary for the purposes for which we obtained the information.
11. Your Choices Regarding Your Personal Information; Opting Out.
    1. Discretionary Account Information. To allow appropriate control over Personal Information, you can view, change, or update discretionary information that you have previously submitted either by contacting us as provided in Section 16 (Contact Us) below.
    2. Opt-Out of Marketing Communications. If we choose to send to you, or you have elected to receive, bulletins, updates, or other marketing-related materials, we will provide you with the ability to decline – or “opt out” – of receiving such communications. Instructions for opting-out will be provided if and when we determine to send you such a communication. For example, if you no longer wish to receive email messages from us, you can opt out of this Service by either: (i) following the “unsubscribe” instructions located near the bottom of each email message, or (ii) contacting us as provided in Section 16 (Contact Us) below. Please understand that we may still communicate with you in connection with administrative notices concerning any transactions, operation of the Platform and legal notices.
    3. State-Specific Notices Regarding Your Privacy Rights.
       1. California Shine the Light Disclosure. California law requires certain businesses to respond to requests from California users who ask about business practices related to disclosing Personal Information to third parties for their own direct marketing purposes. The California “Shine the Light” law further requires us to allow California residents to opt out of certain disclosures of Personal Information to third parties for their own direct marketing purposes.
       2. California Do No Track Notice. Our Website does not change its behavior when receiving “Do Not Track” signals from browser software, and handles all Personal Information consistent with this Privacy Policy.
       3. Nevada Disclosure. For Nevada residents, please note that we do not sell personal information as defined by Nevada law. You can submit a request to us as set out in Section 16 (Contact Us) below.
12. Advisory Regarding Participation by Children and Teens. Under U.S. Federal Law (as reflected in the Children’s Online Privacy Protection Act), WE DO NOT COLLECT OR STORE ANY PERSONAL INFORMATION FROM INDIVIDUALS THAT WE KNOW ARE UNDER THE AGE OF 13. If you wish further information concerning privacy policies in general, and concerning online social networking and safety, you should visit the following website: http://www.ftc.gov/privacy/index.html.
13. Third Party Sites. Our Platform may link to (or be linked from) third party websites or third party features (“Linked Sites”). We have no control over third parties that operate such Linked Site, and we are not responsible for the content, availability, or security of such Linked Sites. Third parties may use your information for their own purposes, including for behavioral or advertising purposes. The inclusion of a link on our Platform to a Linked Site is provided for your convenience only and does not imply endorsement of the Linked Site, the third party, or its products or services. If you decide to access any of the Linked Sites, you do so subject to the terms and conditions of use for such Linked Sites. Any Personal Information that you provide through a Linked Site will be subject to the privacy policy of its operator and not this Privacy Policy.
14. Complaints. If you have a suggestions on how we can improve our Services or complaints you would like us to address, please contact us at the address set out in Section 16 (Contact Us). If you are a California resident, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs. Other states may provide similar avenues for lodging complaints. Please check with your state’s consumer protection authority.
15. Changes to this Privacy Policy. From time to time, we may change this Privacy Policy for our business purposes and to comply with changes in applicable law. In the event of any substantive or material changes, we will communicate these changes to you by posting the updated Privacy Policy on the Website and/or notifying you of the change via the Website, email, or other methods. Your continued use following such notice constitutes your agreement to follow and be bound by the updated Privacy Policy. If you do not agree with any changes to our Privacy Policy, please contact us using the information set forth in Section 16 (Contact Us).
16. Contact Us. If you would like to contact us, please email us at pr@netimpactstrategies.com.
17. Effective Date. The effective date of this Privacy Policy is May 3rd, 2022.
18. Copyright and Legal Notice. © 2022 NetImpact Strategies, Inc. All rights reserved. No part of this content may be reproduced, stored in any form without written permission from NetImpact Strategies, Inc.