https://info.perkville.com/privacy-july-1-2022
"Attention: Our PrivacyPolicy has been updated. For the latest version, please go to https//:info.perkville.com/privacy."

Perkville Privacy Policy
Posted: May 24, 2022
Effective: July 1, 2022

This Privacy Policy explains how Perkville, Inc. (“Perkville”,“we”, “us”, “our”) collects, uses, and shares information and the optionsavailable to you. If you have any questions, you may contact us. See the “ContactingUs” section below. 

We may change this Privacy Policy from time to time. Please consult thisPrivacy Policy regularly for updates. See “Modifications to this PrivacyPolicy” below for more information. 

User Consent: You consent to the practices described in thisPrivacy Policy by using or accessing our Services, and you represent that youare at least 18 years old.

California Users: If you are a resident of the State ofCalifornia, see the California Privacy Notice for additionalinformation about your rights and our disclosures. The California PrivacyNotice is in addition to this privacy policy.

California Employees, Job Applicants, Owners, Directors, Officers, andContractors: If you are a resident of California and you are anemployee, job applicant, controlling owner, director, officer, independentcontractor, or medical staff of ours, see the Privacy Notice forCalifornia Company Workforce.We hope that there aren’t any disputes between you andPerkville, but in case there are, these Terms some rules for how to resolvethem. Those rules are set out, below, in the sections called Disclaimers, Limitation of Liability, and Dispute ResolutionPleaseread these sections carefully as they include important agreements that couldaffect your legal rights. In particular:WHAT DOES THIS PRIVACY POLICY COVER?WHAT DOES THIS PRIVACY POLICY COVER?This Privacy Policycovers the information that we may collect or receive: (1) from users who:visit www.perkville.com, https://middle.app/, and other websites owned andoperated by us (including our client and user interfaces), use our softwareapplications, use our social media pages such as Facebook and Twitter, andreceive email messages from us (collectively, the “Perkville Pages”);and (2) through our technologies and platforms used by our business customersand third parties, including our referral and rewards platform and our Middleintegration platform (collectively with the Perkville Pages, the “Services”).

This Privacy Policy does not cover, and we are not responsible for, the privacyor data practices of or the processing of data by any third parties (except asrequired by applicable law), such as our business customers and any serviceproviders. See “Third Parties” below for more information.

Choice and Opting Out: see “Choices” below for information about yourchoices regarding opting out of email marketing communications, opting out ofPerkville’s cookies, opting out of interest-based advertising by third partiesfrom cookies, and opting out of the use of precise location. For information ondeactivating your Perkville account or your accounts with business customersvia the Services, please see “Access and Rights regarding PersonalInformation.Access and Rights: see “Access and Rights regardingPersonal Information” below for information about how to review, correct,update, suppress, or delete the personal information that Perkville maintainsabout you and to exercise other data subject rights.

International Transfers: see “International Information Transfers” belowfor information on the transfer of your personal data.COLLECTION OF INFORMATIONMiddle Integration Platform Collection:

Our Middle integration platform is used and accessed by our business customersand their employees and representatives only. Our Middle platform allows ourbusiness customers to integrate with various third party service providers andplatforms.

The Middle integration platform does not directly collect information about anyconsumers. However, our business customers may use the Middle integrationplatform for the purpose of collecting personal information about itscustomers. This privacy policy does not cover our business customers’collection or processing of their customers’ information through the Middleintegration platform. Please review the applicable business customer’s privacypolicy for information about its data practices.

We may collect the following personal information about you as an employee orrepresentative of our business customer:nameemail addressphone numberphysical addresstime spent on the Services and your activities on theServices, including pages visited, requested URL and referring URL, date andtime on the Services, information about interactions with our emails, and otheranonymous traffic-related data,unique identification numbers, including IP address andyour location derived from IP address,information provided by you,information to enable and authorize your logging in to theServices,browser information, including browser type and language,device information, including screen dimensions, devicebrand and model, and mobile device identifier, andaggregated information.Some of this information is provided by you, and isoptional. However, if you elect not to provide such information, you will notbe able to access the information you had requested to access or use.

Referral and Rewards Platform Collection:

Our referral and rewards platform is used and accessed by our businesscustomers, their employees and representatives, and their customers. Thisplatform allows our business customers to create custom rewards for theircustomers and referral offers for their customers to send to theirfriends. 

For our referral and rewards platform, we may collect the following personalinformation from you:nameemail addressphone numberPerkville user identification account numberbusiness customer identification numberunique identification numbers, including IP address andyour location derived from IP address,your staff identification number at the business customerof our referral and rewards Servicesphysical addressTwitter user IDyour Facebook “check-ins” for rewards points through ourreferral and rewards Services,your Tweets for rewards points through our referral andrewards Services,time spent on the Services and your activities on theServices, including pages visited, requested URL and referring URL, date andtime on the Services, information about interactions with our emails, and otheranonymous traffic-related data,transaction-related data relating to the referral andrewards Service such as: date, time and location a transaction took place(e.g., when and where a class was attended), description and/or classificationof the transaction (e.g., yoga class attended, gym check-ins, personal trainingsessions, referrals made, amount spent, etc.), quantity of items sold orservices associated with the transaction, number of rewards points added orredeemed in connection with the transaction,unique identification numbers, including IP address andyour location derived from IP address,demographic information (e.g., date of birth, gender) asprovided by you or the business customer,information provided by you,information to enable and authorize your logging in to theServices,browser information, including browser type and language,device information, including screen dimensions, devicebrand and model, and mobile device identifier, andaggregated information.Some of this information is provided by you, and isoptional. However, if you elect not to provide such information, you will notbe able to access the information you had requested to access or use.

For both our Middle integration platform and our referral and rewards platform,we may collect some of this information through: your browser or device; yourmobile device identifier; your use of our Services; your IP address; theaggregation of information; and the use of cookies and other similartechnologies (see Cookies and Similar Technologies below). Wemay also collect your personal information when you request information aboutthe Services, or you sign up to use the Services through our client login anduser interfaces, or you request access to our resources. 

For our referral and rewards platform only, we may collect your informationwhen a friend or family member has referred you through the referral andrewards Services, or when a business customer has identified you as theircustomer through the referral and rewards Services. You may also provide thenames and emails of friends and family on the pages of the Service where youcan refer people to our business customers. Referring friends and family isoptional. In addition, some of the personal information may be provided by ourbusiness customers’ staff members when they sign up for our referral andrewards Service as a business customer. 

Please see “Access and Rights regarding Personal Information” to see moreinformation about your rights regarding your personal information.USE OF INFORMATIONMiddle Integration Platform Uses:
We may use your personal information as an employee or representative of ourbusiness customer:to respond to your inquiries and fulfill your requests andprocess your business customer account,to send you communications that we believe may be ofinterest to you, including any communications for purposes of marketing to thebusiness customer you are associated with,for our business purposes, such as data analysis, fraudmonitoring and prevention and security, developing new products, enhancing,improving or modifying our Services, identifying usage trends, and determiningthe effectiveness of our Services, andto measure and report on the success of marketingcampaigns.Referral and Rewards Platform Uses:
We may use personal information:to respond to your inquiries and fulfill your requests andprocess users’ accounts,to track rewards in the rewards program of the referral andrewards Services and to reward the points,to send you communications that we believe may be ofinterest to you, including any communications for marketing purposes related tothe Services,to contact friends and family members referred through ourreferral and rewards Services,to allow business customers’ staff to log in and managetheir business’ rewards program in our referral and rewards Services,to allow our business customers to engage developers toretrieve data for business intelligence, reward redemption, and displayingreward program information in other applications,for our business purposes, such as tracking conversion ofprospective customers into actual customers, data analysis, fraud monitoringand prevention and security, developing new products, enhancing, improving ormodifying our Services, identifying usage trends, and determining theeffectiveness of our Services,to show you the closest establishment to redeem an offerthat you are considering for redeeming your points, andto measure and report on the success of marketingcampaigns, including to track conversion of prospective customers to actualcustomers.For both our Middle integration platform and our referraland rewards platform, we use your information:to send administrative information to you,to operate, improve, analyze and manage the Services,to ensure the Services function properly,to track your use of the Services to improve the design andfunctionality of the Services,to diagnose server problems and administer the Services viayour IP Address (a number automatically assigned to the computer or device thatyou are using by your internet service provider), andas we believe to be necessary or appropriate: (a) underapplicable law; (b) to comply with legal process and our legal obligations; (c)to respond to requests or requirements from public, law and governmentauthorities (including national security and law enforcement requirements) andprivate parties; (d) to enforce our terms and conditions; (e) to protect ouroperations and the security of our Services; (f) to protect our rights,privacy, safety or property, and/or that of you or others; (g) to allow us topursue available remedies or limit the damages that we may sustain; and (h) toprevent or stop activity we may consider to be, or to pose a risk of being,illegal, unethical or legally actionable activity.For both our Middle integration platform and our referraland rewards platform, we may partner with certain third parties to collectother information to engage in analysis, research, and reporting of Serviceusage patterns. These third parties may also deliver advertising to you onother websites and applications, based on your activity on our website andother websites over time. These third parties may set and access cookies onyour computer or other devices, and may also use web logs or web beacons. See “Cookiesand Similar Technologies” and see “Choices” to opt out ofinterest-based advertising by third parties from cookies.INFORMATION SHARINGMiddle Integration Platform Sharing:
Your personal information may be shared:with our third-party service providers who provide servicessuch as email management, hosting and storage, web serving, technical services,marketing analytics and other services, anddirectly by you in your account and other services to whichyou are able to post information and materials yourself.Referral and Rewards Platform Sharing:
Your personal information may be shared:with our business customers and their employees andservices providers to use our Services and to analyze the effectiveness andperformance of our Services,with our third-party service providers who provide servicessuch as email management, transaction management, campaign measurement, hostingand storage, web serving, performance tracking and reporting, technicalservices, marketing analytics and other services, anddirectly by you in your account and other services to whichyou are able to post information and materials yourself (including, withoutlimitation, our and your social media pages).For both our Middle integration platform and our referraland rewards platform, we may share information:among our affiliates for the purposes described in thisPrivacy Policy (Perkville, Inc. is the party responsible for the management ofthe information jointly used by it and its affiliates),with a third party in the event of any reorganization,merger, sale, joint venture, assignment, transfer or other disposition of allor any portion of our business, assets or stock (including in connection withany bankruptcy or similar proceedings), andas we believe to be necessary or appropriate: (a) underapplicable law; (b) to comply with legal process and our legal obligations; (c)to respond to requests or requirements from public, law and governmentauthorities (including national security and law enforcement requirements) andprivate parties; (d) to enforce our terms and conditions; (e) to protect ouroperations and the security of our Services; (f) to protect our rights,privacy, safety or property, and/or that of you or others; (g) to allow us topursue available remedies or limit the damages that we may sustain; and (h) toprevent or stop activity we may consider to be, or to pose a risk of being,illegal, unethical or legally actionable activity.We may also share and disclose other information that wecollect, including aggregate information such as total number of Perkvilleusers of our various Services and total number of Perkville business customersof our various Services, as we consider necessary to develop, grow, and provideour Services.

We ask our service providers to confirm that their privacy and securitypractices are consistent with ours, we provide our service providers with onlythe information necessary for them to perform the services we request, and weask our service providers not to use such information for any purpose otherthan as specified by Perkville.

Our third party service providers who provide usage analytics for our Servicesmay also use your information to provide you with more personalized advertisingcontent on other websites and applications. To opt out of interest-basedadvertising by third parties, see "Choices.”

Perkville may offer online resources that facilitate communications among thePerkville community and others. Whenever you voluntarily post information toany public forum offered by Perkville, such information along with your username can be accessed by other users of the forum, including members of thepublic if the forum is open to the public.COOKIES AND SIMILAR TECHNOLOGIESThe Reward Program, Rewards, Perks, Points, and otherbenefits made available in connection with the Service are promotional only andhave no cash or property value.  Businesses, and not Perkville, inaccordance with their agreements with Clients or at Businesses’ own discretion,determine how Points and all other benefits are awarded, calculated, valued,and redeemed, when they expire, are terminated, and User’s ownership, or lackthereof, of same. Perkville is not responsible for any unredeemed Points or benefits,or any Points or benefits that are lost. Businesses also do not bear suchresponsibility, unless specified in a separate agreement.Businesses’ VouchersWe and our service providers use cookies in connection withour Services. A cookie is a small data file that is stored on your computer’sor mobile device's memory. Some cookies help you navigate our Services,including setting a cookie to remember your login details. Our cookies arelinked to your login information so that you can use the Services on yourdevice throughout the day without logging in each time you visit the Services.Cookies also help us better understand the effectiveness of our Services (forexample, by tracking the way in which you respond to, select and interact withour Services and tracking the conversion of our prospective customers intoactual customers). Other cookies collect information about how you use ourServices, which highlights areas we can improve, including navigation. If yousubmit an inquiry through our Service and provide your name and email andsimilar information, that personal information will not be tied back to you forinterest-based advertising purposes across websites and applications, however,you may receive email marketing communications from us, and you may receiveinterest-based advertising from third parties based on cookies dropped on yourdevice by our third party service providers. To opt out of marketingcommunications and interest-based advertising by third parties, see “Choices.”

We and our service providers may also use "pixel tags," "webbeacons", "clear GIFs" or similar means (individually orcollectively "Pixel Tags") to analyze usage patterns of consumers.A Pixel Tag is an electronic image, often a single pixel, which is typically atransparent graphic image (usually 1 pixel x 1 pixel) that is placed on a webpage or in a mobile application and may be associated with cookies on your harddrive. Some Pixel Tags are used to drop cookies on users’ devices. Pixel Tagsallow us to count users who have visited certain websites and applications ofour business customers, and pages within such websites and applications, and tohelp determine the effectiveness of marketing campaigns.

Third parties may use cookies or similar technologies on visitors of ourServices to serve interest-based advertisements to such visitors when theyvisit other websites and mobile applications. Our business customers thatparticipate in the Services may also utilize cookies or similar technologies tomonitor the performance of their referral and rewards program in our Services.The collection of information through cookies or similar technologies by suchthird parties will be governed by such third parties’ own privacy policies andprinciples, which Perkville does not control.

For more information about cookies, including how to see what cookies have beenset on your device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu. To read about your choices withregard to Perkville’s and third parties’ uses of cookies in our Services,please see “Choices.”

We do not track users when they cross to third party websites, and we do notprovide targeted advertising to them, and therefore we do not respond to Do NotTrack (DNT) signals.LEGAL BASIS RELIED ON FOR PROCESSINGPERSONAL INFORMATION OF EUROPEAN DATA SUBJECTSData Processor. Perkville is a data processor with respectto personal data collected or received by us when we receive such informationfrom our business customers (the data controllers) that make their dataavailable for use via our Services, or you after you have signed up for ourService via our business customers.

Where we operate as a data processor, we are processing the data on behalf ofour business customers (the data controller(s) of the data) based on theirinstructions, and it is the responsibility of the data controller to establishan appropriate legal basis for the processing of the data. For example, we mayprocess data when the individual has consented to such processing. On certainoccasions we may rely on another lawful basis as a basis for processing, suchas when it is in our business customers’ and our legitimate interests to do soand when these interests are not overridden by the individual’s data protectionrights. Those legitimate interests include performing our obligations with respectto providing the Services and improving our Services.

Data Controller. On certain occasions, Perkville is a data controller.Perkville is a data controller with respect to any personal data collected orreceived by us when we receive personal information (such as name, phonenumber, and email address) through our Perkville Pages without being connectedto any business customer. In this case, the data controller is Perkville, Inc.Where Perkville operates as a data controller, we rely on legitimate intereststo process personal data to provide our Services. On certain occasions, we mayalso rely on the consent of the individual to process personal information (forexample, in some jurisdictions, when the user inputs personal information intothe Perkville Pages and consents to receive marketing communications). On otheroccasions, we may process personal information when we need to do this tofulfill a contract or where we are required to do so by law.RETENTIONWe will retain your personal information for the periodnecessary to fulfill the purposes outlined in this Privacy Policy unless alonger retention period is required or permitted by law, or an individualrequests deletion in accordance with applicable law. See “Access and Rightsregarding Personal Information.”CHOICESOpting Out of MarketingWe give you choices regarding ouruse and disclosure of your personal information for marketing purposes.

You may opt-out from receiving electronic communications from us. If you nolonger want to receive marketing-related emails from us on a going-forwardbasis, you may opt-out of receiving these marketing related emails bycontacting us at privacy@perkville.com or by clicking on the opt-outlink within the email message that you receive from us.

Please also note that if you do opt-out of receiving marketing-related emailsfrom us, we may still be required to send you administrative messages relatingto the Services from time to time.

Opting Out of Perkville’s cookies

You may disable cookies, including Perkville’s cookies, by modifying thesettings in your browser. However, please note that if you delete or disablecookies, you will not be able to stay logged in to the Services to interact andearn rewards points and, as a result, the Services will no longer be availableto you. Our cookie is required to provide our Services. Our cookies are linkedto your login information so that you can use the Services on your devicethroughout the day without logging in each time you visit the Services.

Opting Out of Interest-Based Advertising by Third Parties from Cookies Somethird parties who use cookies when you visit our websites, have opt outmechanisms either directly from their website or through an industry-developedweb page. If you go to optout.aboutads.info or www.aboutads.info/choices, you can learn how to exercise choiceregarding the collection of information about your online activities over timeand across multiple third-party websites, online services, devices, andapplications for interest-based advertising purposes. When you opt out ofreceiving interest-based advertising from third parties, note that the opt outonly applies to the applicable browser in which you set it.

For more information about cookies, including how to see what cookies have beenset on your device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu.

Third parties may also combine and use information from websites orapplications on your current browser or device with information from your otherbrowsers or devices for advertising purposes. To opt out of such practices,please follow the instructions above for opting out on each of your browsers,and also opt out on each of your mobile devices. Please note that you will needto opt out separately on (1) each of your browsers and (2) each of your mobiledevices to ensure that information collected on a particular browser or deviceis not used on another browser or device.

Opting Out of Use of Precise Location
To disable the collection of precise location information from your mobiledevice through mobile applications, you can access your mobile device settingsand choose to limit that collection.Android: For Android 6.0 and above: you can modify privacysettings in Settings > Applications > App Permissions > Location andtap the on/off toggle switch next to Location for each app which has permissionto use your location data. For earlier versions of Android: you can modifyprivacy settings in Settings > More > Permission and tap the on/offtoggle switch next to Location to turn location functions off for your device.Alternatively, you may uninstall the relevant program(s).iOS: In iOS you can modify privacy settings in Settings> Privacy. You can select location data from this list to see which appshave asked for permission to use your location data.ACCESS AND RIGHTS REGARDING PERSONALINFORMATIONIf you reside outside the European Economic Area, theUnited Kingdom and Switzerland, and you would like to review, correct, update,suppress, or delete the personal information that Perkville maintains aboutyou, or you would like to request a copy of your personal information held byus, you may contact us at privacy@perkville.com.

If you are a resident of the European Economic Area, the United Kingdom orSwitzerland, you have specific legal rights in regard to the handling of yourinformation. You have the following rights with respect to your personalinformation:The right to be informed,The right of access,The right to rectification,The right to erasure,The right to restrict processing,The right to data portability,The right to object,The right to lodge a complaint with a supervisoryauthority, andRights in relation to automated decision-making andprofiling.To exercise these rights as a resident of the EuropeanEconomic Area, the United Kingdom or Switzerland, email privacy@perkville.com or contact our applicableEuropean or UK representative under “Contacting Us” below.

For data that we process on our business customers’ behalf, you may also godirectly to the business customer and exercise these rights.

For customers using our referral and rewards program, you may deactivate youraccount by changing your preferences in the user settings page of those Services. You may also disconnect orreconnect to each business customer via the user settings page of those Services. 

For employees or representatives of business customers that use our Middleintegration platform, you may also email us at support@perkville.com. 

To opt out of receiving marketing communications from us, please see “Choices.”

To opt out of Perkville’s cookies, please see “Choices.”

To opt out of interest-based advertising by third parties from cookies, pleasesee “Choices.”

To opt out of the use of precise location, please see “Choices.”THIRD PARTIESThis Privacy Policy does not cover, and we are notresponsible for, the privacy or data practices of or processing of data by anythird parties (except as required by applicable law), including any thirdparties operating any site or service to which our Services link. The inclusionof a link on the Services does not imply endorsement of the linked site orservice by us or by our affiliates. These third parties are bound by their ownprivacy policies.

Except as required by applicable law, we are also not responsible for theprivacy or data practices of or the collection, processing or use of data byour business customers, service providers, app developers, app providers, adservers, social media platform providers, operating system providers, wirelessservice providers or device manufacturers, including any personal informationyou disclose to other organizations through or in connection with the Services.When a consumer and business issue arises we may considerthe User's specific circumstances in applying our policies. We may choose to bemore lenient with policy enforcement in some cases.SENSITIVE INFORMATIONWe ask that you not send us, and you not disclose to us,any sensitive information (e.g., social security numbers or other governmentidentifiers, information related to racial or ethnic origin, politicalopinions, religion or other beliefs, medical or health conditions, criminalbackground, trade union membership, or sexual orientation) on or through theServices or otherwise to us, except where such information is legally required.CHILDRENOur Services are not intended for, nor directed to,individuals under the age of 18, and we request that these individuals, and anyother individual considered a minor under applicable law, not provide personalinformation through any of our Services. If you become aware that your childhas provided us with personal information without your consent, please contactus at privacy@perkville.com. If we become aware that a childunder 18 (or under the legal age under applicable law) has provided us withpersonal information without parental consent, we take steps to remove suchinformation and terminate the child's account.SECURITYInformation that we collect is stored using procedures andpractices reasonably designed to help protect from accidental or unlawfuldestruction, loss, alteration, unauthorized disclosure of, or access to,personal information transmitted, stored or otherwise processed by us.INTERNATIONAL INFORMATION TRANSFERSPlease be aware that the information we collect, may betransferred to and maintained on servers or databases located outside yourstate, province, country, or other jurisdiction, where the privacy laws may notbe as protective as those in your location. Please be advised that we processand store information in any country where we have facilities and/or employees,including the United States, or in which we engage service providers. Yourconsent to this Privacy Policy or your use of any of the Services or yoursubmission of your information to us or any of our business customers,represents your consent to such transfer, storage and processing outside ofyour country of residence, including the United States, which may havedifferent data protection rules than those of your country of residence. Model Clauses. If you are located in the European Economic Area, the United     Kingdom or Switzerland, we will protect your personal information when it     is transferred outside of your jurisdiction by (a) processing it in a     territory that provides an adequate level of protection based on its data     protection laws; or (b) implementing appropriate safeguards to protect     your personal information, such as relying on the European standard     contractual clauses.  Perkville currently relies on these European     standard contractual clauses (“Model Clauses”) for data transfers. Privacy Shield Notice. As of July 16, 2020, the European Court of Justice issued a     judgement declaring Privacy Shield invalid. Perkville now relies on other     transfer mechanisms, such as the Model Clauses described above, for the     cross-border transfer of dataEU-U.S. PRIVACY SHIELD AND SWISS-U.S.PRIVACY SHIELDCOMPLIANCE AND STATUS
Perkville complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S.Privacy Shield Framework, as applicable, as set forth by the U.S. Department ofCommerce regarding the collection, use, and retention of personal informationtransferred from the European Economic Area, the United Kingdom or Switzerlandto the United States. Perkville has certified to the Department of Commercethat it adheres to the Privacy Shield Principles of Notice, Choice,Accountability for Onward Transfer, Security, Data Integrity and PurposeLimitation, Access, and Recourse, Enforcement and Liability. If there is anyconflict between the terms in this privacy policy, the Privacy ShieldPrinciples and the Model Clauses described above, the Model Clauses control,then the Privacy Shield Principles. To learn more about the Privacy Shieldprogram, and to view our certification, please visit https://www.privacyshield.gov/

Perkville is accountable for information that it receives under the PrivacyShield and subsequently transfers to a third party. Perkville may transferpersonal information collected from the Services as described above in thisPrivacy Policy. Perkville may also transfer other information which meet thedefinition of “personal data” in the Privacy Shield Framework to serviceproviders and to its business customers as described above. If we sharepersonal data of  data subjects in the European Economic Area, the UnitedKingdom or Switzerland with a third-party service provider that processes thedata solely on Perkville’s behalf, then Perkville will be liable for that thirdparty's processing of such data in violation of the Privacy Shield Principles,unless Perkville can prove that it is not responsible for the event giving riseto the damage.

In compliance with the Privacy Shield Principles, Perkville commits to resolvecomplaints about our collection or use of your personal information withrespect to data subjects in the European Economic Area, the United Kingdom andSwitzerland. Such individuals who have inquiries or complaints under thePrivacy Shield Frameworks should first contact Perkville atprivacy@perkville.com or:

Perkville, Inc.
Attn: Privacy
C/O Port Workspaces
344 Thomas L. Berkley Way
Oakland, CA 94612
USA

Perkville has further committed to refer unresolved Privacy Shield complaintsto the ICDR (the international division of the American ArbitrationAssociation), an international alternative dispute resolution provider. If youdo not receive timely acknowledgment of your complaint from us, or if we havenot resolved your complaint, please contact the ICDR or visithttp://go.adr.org/privacyshield.html for more information or to file acomplaint. The services of the ICDR are provided at no cost to you.

Under certain conditions, you may be entitled to invoke binding arbitrationwhen other dispute resolution procedures have been exhausted.Seehttps://www.privacyshield.gov/article?id=ANNEX-I-introduction for moreinformation.

The Federal Trade Commission has jurisdiction over Perkville’s compliance withthe Privacy Shield FrameworkMODIFICATIONS TO THIS PRIVACY POLICYWe reserve the right to make changes to our Privacy Policy.Please look at the date at the top of this page to see when this Privacy Policywas last revised. Where required by law, we will obtain your consent to makethese changes.CONTACTING USFor any questions about this Privacy Policy or Perkville’sprivacy practices, please contact us by email at privacy@perkville.com, or by mail at:

Perkville, Inc.
Attn: Privacy
C/O Port Workspaces
344 Thomas L. Berkley Way
Oakland, CA 94612
USA

General Data Protection Regulation (GDPR) – European Representative

Perkville has appointed European Data Protection Office (EDPO) as itsGDPR Representative in the EU. You can contact EDPO regarding matterspertaining to GDPR:by using EDPO’s online request form:https://edpo.com/gdpr-data-request/by writing to EDPO at Avenue Huart Hamoir 71, 1030Brussels, BelgiumUK General Data Protection Regulation (GDPR) - UKRepresentative

Perkville has appointed EDPO UK Ltd as its UK GDPR representative in the UK.You can contact EDPO UK regarding matters pertaining to UK GDPR:by using EDPO’s online request form:https://edpo.com/uk-gdpr-data-request/by writing to EDPO UK at 8 Northumberland Avenue, LondonWC2N 5BY, United KingdomCALIFORNIA’S “SHINE THE LIGHT” LAWCalifornia's "Shine the Light" law permits usersof our properties that are California residents to request certain informationregarding our disclosure of personal information to third parties for theirdirect marketing purposes. To make such a request, please contact us at thecontact information under Contacting Us.California Privacy NoticeIf you are a California resident and we collect yourpersonal information, this Privacy Notice for California Residents(“California Notice”) applies to you ("consumers" or "you"),except as stated below. This California Notice is in addition to theinformation in our privacy policy above.

Where noted in this California Notice, the CCPA temporarily exempts certainpersonal information reflecting a written or verbal business-to-businesscommunication or transaction (“B2B personal information”) from certain CCPArequirements. In addition, employees, job applicants, contractors, owners,directors and officers of Perkville who are California residents do not havethe same rights as set forth in this California Notice. See “Collectionof Information” below for additional information about excluded personalinformation.

All terms defined in the California Consumer Privacy Act of 2018 (CCPA) havethe same meaning when used in this California Notice.

Collection of Information

We collect information that identifies, relates to, describes, isreasonably capable of being associated with, or could reasonably be linked,directly or indirectly, with a particular consumer, device or household ("personalinformation").

We have collected the following categories of personal information from ourconsumers within the last twelve (12) months:CCPA CategoryA. Identifiers.B. Personal information categories listed in the CaliforniaCustomer Records statute (Cal. Civ. Code § 1798.80(e))C. Protected classification characteristics underCalifornia or federal law.D. Commercial information.E. Biometric information.F. Internet or other similar network activity.G. Geolocation data.H. Sensory data.I. Professional or employment-related information.J. Non-public education information (per the FamilyEducational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part99)).K. Inferences drawn from other personal information.CCPA CategoryA real name, alias, postal address, unique personalidentifier, online identifier, Internet Protocol address, email address,account name, Social Security number, driver's license number, passport number,or other similar identifiers.A name, signature, Social Security number, physicalcharacteristics or description, address, telephone number, passport number,driver's license or state identification card number, insurance policy number,education, employment, employment history, bank account number, credit cardnumber, debit card number, or any other financial information, medicalinformation, or health insurance information.Some personal information includedin this category may overlap withAge (40 years or older), race, color, ancestry, nationalorigin, citizenship, religion or creed, marital status, medical condition,physical or mental disability, sex (including gender, gender identity, genderexpression, pregnancy or childbirth and related medical conditions), sexualorientation, veteran or military status, genetic information (includingfamilial genetic information).Records of personal property, products or servicespurchased, obtained, or considered, or other purchasing or consuming historiesor tendencies.Genetic, physiological, behavioral, and biologicalcharacteristics, or activity patterns used to extract a template or otheridentifier or identifying information, such as, fingerprints, faceprints, andvoiceprints, iris or retina scans, keystroke, gait, or other physical patterns,and sleep, health, or exercise data.Browsing history, search history, information on aconsumer's interaction with a website, application, or advertisement.Physical location or movements.Audio, electronic, visual, thermal, olfactory, or similarinformation.Current or past job history or performance evaluations.Education records directly related to a student maintainedby an educational institution or party acting on its behalf, such as grades,transcripts, class lists, student schedules, student identification codes,student financial information, or student disciplinary records.Profile reflecting a person's preferences, characteristics,psychological trends, predispositions, behavior, attitudes, intelligence,abilities, and aptitudes.Categories of Sources:We obtain the above categories of personal information fromthe following categories of sources:Directly from you,Automatically collected information,Our business customers,Our service providers, andInformation when you log in with a third party’s singlesign-in.What is not personal information ornot covered?De-identified or aggregated consumer information is notpersonal information under CCPA.Publicly available information from government records isnot personal information under CCPA.Health or medical information covered by the HealthInsurance Portability and Accountability Act of 1996 (HIPAA) and the CaliforniaConfidentiality of Medical Information Act (CMIA) or clinical trial data arealso not personal information under CCPA.Personal information covered by certain sector-specificprivacy laws, including the Fair Credit Reporting Act (FRCA), theGramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act(FIPA), and the Driver's Privacy Protection Act of 1994 are also not personalinformation under CCPA.Certain “excluded personal information” is temporarilyexcluded from the definition of personal information. The term “excludedpersonal information” means personal information that we collect about anatural person who resides in California in the course of the person acting asany of the following (to the extent we collect and use the information solelywithin the context of that role):a job applicant of Perkville,an employee of Perkville,a controlling owner of Perkville,a director of the board or an officer of Perkville,a medical staff member of Perkville (if any), anda contractor of Perkville.Also, emergency contact information and information neededto administer benefits for the individuals covered above is not covered by thisCalifornia Notice.Use of InformationWe may use the personal information for one or more of thefollowing purposes:Fulfilling your requests.Providing and improving the Service, including trackingrewards.Sending you communications.For our business purposes.As we believe to be necessary or appropriate: (a) underapplicable law; (b) to comply with legal process and our legal obligations; (c)to respond to requests or requirements from public, law and governmentauthorities (including national security and law enforcement requirements) andprivate parties; (d) to enforce our terms and conditions; (e) to protect ouroperations and the security of our Services; (f) to protect our rights,privacy, safety or property, and/or that of you or others; (g) to allow us topursue available remedies or limit the damages that we may sustain; and (h) toprevent or stop activity we may consider to be, or to pose a risk of being,illegal, unethical or legally actionable activity.As described to you when collecting your personalinformation or as otherwise permitted in the CCPA.We will not collect additional categories of personalinformation or use the personal information we collected for materiallydifferent, unrelated, or incompatible purposes without providing you notice.Information SharingSales of Personal Information
In the preceding twelve (12) months,we have not sold your personal information. “Sold” is defined under the CCPA.

Disclosures of Personal Information for a Business Purpose
We may disclose your personal information to a third party for abusiness purpose. When we disclose personal information for a business purpose,we enter into a contract that describes the purpose and requires the recipientto both keep that personal information confidential and not use it for anypurpose except performing the contract.

We share your personal information with the following categories of thirdparties:Our affiliates.Our business customers.Our business customers.A buyer of our business.The public, voluntarily by you.We may also share your information as we believe to benecessary or appropriate: (a) under applicable law; (b) to comply with legalprocess and our legal obligations; (c) to respond to requests or requirementsfrom public, law and government authorities (including national security andlaw enforcement requirements) and private parties; (d) to enforce our terms andconditions; (e) to protect our operations and the security of our Services; (f)to protect our rights, privacy, safety or property, and/or that of you orothers; (g) to allow us to pursue available remedies or limit the damages thatwe may sustain; and (h) to prevent or stop activity we may consider to be, orto pose a risk of being, illegal, unethical or legally actionable activity.

In the preceding twelve (12) months, we have disclosed the following categoriesof personal information for a business purpose:
Category A: Identifiers.

Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California orfederal law.
Category D: Commercial information.
Category E: Biometric information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category K: Inferences drawn from other personal information.Your Rights and ChoicesUnder the CCPA, California residents have specific rightsabout their personal information. See below for information about these rights.The CCPA does not give these rights to consumers with B2B personalinformation.Access to Specific Information and Data PortabilityYou have theright to request that we disclose certain information to you about ourcollection and use of your personal information over the past 12 months. Oncewe receive and confirm your verifiable consumer request (see Exercising Rights),we will disclose to you:The categories of personal information we collected aboutyou.The categories of sources for the personal information wecollected about you.Our business or commercial purpose for collecting thatpersonal information.The categories of third parties with whom we share thatpersonal information.The specific pieces of personal information we collectedabout you (which will allow you to exercise your data portability right).Deletion Request
You have the right to request that wedelete any of your personal information that we collected from you and stillretain, subject to certain exceptions. Once we receive and confirm yourverifiable consumer request (see Exercising Rights), we will delete(and direct our service providers to delete) your personal information from ourrecords, unless an exception applies.

We may deny your deletion request if retaining the information is necessary forus or our service providers to:Complete the transaction for which we collected thepersonal information, provide a good or service that you requested, takeactions reasonably anticipated within the context of our ongoing businessrelationship with you, or otherwise perform our contract with you.Detect security incidents, protect against malicious,deceptive, fraudulent, or illegal activity, or prosecute those responsible forsuch activities.Debug products to identify and repair errors that impairexisting intended functionality.Exercise free speech, ensure the right of another consumerto exercise their free speech rights, or exercise another right provided for bylaw.Comply with the California Electronic CommunicationsPrivacy Act (Cal. Penal Code § 1546 et. seq.).Engage in public or peer-reviewed scientific, historical,or statistical research in the public interest that adheres to all otherapplicable ethics and privacy laws, when the information's deletion may likelyrender impossible or seriously impair the research's achievement, if youpreviously provided informed consent.Enable solely internal uses that are reasonably alignedwith consumer expectations based on your relationship with us.Comply with a legal obligation.Make other internal and lawful uses of that informationthat are compatible with the context in which you provided it.Exercising Rights
To exercise your rights above, please submita verifiable consumer request to us by either:Emailing us at privacy@perkville.com and providing your full name and email address andthe request that you are making (e.g., right to access, portability ordeletion).Submitting a web form located on oursupport portal and providing yourfull name and email address and the request that you are making (e.g., right toaccess, portability or deletion).The CCPA does not give these rights to consumers with B2Bpersonal information.

Only you, or someone legally authorized to act for you, may make a verifiableconsumer request about your personal information.

You may only make a verifiable consumer request for access or dataportability twice within a 12-month period. The verifiable consumerrequest must:Provide sufficient information that allows us to reasonablyverify you are the person about whom we collected personal information or anauthorized representative.Describe your request with sufficient detail that allows usto properly understand and respond to it.
We cannot respond to your request or provide you with personal information ifwe cannot verify your identity or authority to make the request.

Making a verifiable consumer request does not require you to create an accountwith us. We may require you to make your request through your account if youhave an account with us.
Format of Response and Timing
We will try to respond to a verifiable consumer request withinforty-five (45) days of its receipt. If we require more time, we will informyou of the reason and extension period.

If you have an account with us, we will deliver our written response to thataccount. If you do not have an account with us, we will deliver our writtenresponse by mail or electronically.

Any disclosures we provide will only cover the 12-month period preceding therequest's receipt. The response we provide will also explain the reasons wecannot comply with a request, if applicable. For data portability requests, wewill select a format to provide your personal information that is readilyuseable and should allow you to transmit the information from one entity toanother entity.Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights.Unless permitted by the CCPA, we will not:Provide you a different level or quality of goods orservices.Suggest that you may receive a different price or rate forgoods or services or a different level or quality of goods or services.Deny you goods or services.Charge you different prices or rates for goods or services,including through granting discounts or other benefits, or imposing penalties.We may offer certain financial incentives permitted by theCCPA that could result in different prices, rates, or qualitylevels. The incentive will reasonably relate to your personal information'svalue to us and contain written terms that describe the program's materialaspects. Participation in a financial incentive program requires your prioropt-in consent, which you may revoke at any time.Provide you a different level or quality of goods orservices.Suggest that you may receive a different price or rate forgoods or services or a different level or quality of goods or services.Deny you goods or services.Charge you different prices or rates for goods or services,including through granting discounts or other benefits, or imposing penalties.Privacy Notice for California CompanyWorkforceThis Privacy Notice for California CompanyWorkforce (“California Workforce Notice”) applies solely to employees,job applicants, controlling owners, directors, officers, independentcontractors, and medical staff of Perkville (if any) who reside in California (“you” or “CompanyWorkforce”).

We have adopted this California Workforce Notice to comply with the CaliforniaConsumer Privacy Act of 2018 (CCPA) with respect to certain Company Workforce.Any terms defined in the CCPA have the same meaning when used in thisCalifornia Workforce Notice.CategoryA. Identifiers.B. Personal information categories listed in the CaliforniaCustomer Records statute (Cal. Civ. Code § 1798.80(e))C. Protected classification characteristics underCalifornia or federal law.D. Commercial information.E. Biometric information.F. Internet or other similar network activity.G. Geolocation data.H. Sensory data.I. Professional or employment-related information.J. Non-public education information (per the FamilyEducational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part99)).K. Inferences drawn from other personal information.ExamplesA real name, alias, postal address, unique personalidentifier, online identifier, Internet Protocol address, email address,account name, Social Security number, driver's license number, passport number,or other similar identifiers.A name, signature, Social Security number, physicalcharacteristics or description, address, telephone number, passport number,driver's license or state identification card number, insurance policy number,education, employment, employment history, bank account number, credit cardnumber, debit card number, or any other financial information, medicalinformation, or health insurance information.Some personal information includedin this category may overlap withAge (40 years or older), race, color, ancestry, nationalorigin, citizenship, religion or creed, marital status, medical condition,physical or mental disability, sex (including gender, gender identity, genderexpression, pregnancy or childbirth and related medical conditions), sexualorientation, veteran or military status, genetic information (includingfamilial genetic information).Records of personal property, products or servicespurchased, obtained, or considered, or other purchasing or consuming historiesor tendencies.Genetic, physiological, behavioral, and biologicalcharacteristics, or activity patterns used to extract a template or otheridentifier or identifying information, such as, fingerprints, faceprints, andvoiceprints, iris or retina scans, keystroke, gait, or other physical patterns,and sleep, health, or exercise data.Browsing history, search history, information on aconsumer's interaction with a website, application, or advertisement.Physical location or movements.Audio, electronic, visual, thermal, olfactory, or similarinformation.Current or past job history or performance evaluations.Education records directly related to a student maintainedby an educational institution or party acting on its behalf, such as grades,transcripts, class lists, student schedules, student identification codes,student financial information, or student disciplinary records.Profile reflecting a person's preferences, characteristics,psychological trends, predispositions, behavior, attitudes, intelligence,abilities, and aptitudes.Deidentified or aggregated consumer information is notpersonal information under CCPA.Publicly available information from government records isnot personal information under CCPA.Health or medical information covered by the HealthInsurance Portability and Accountability Act of 1996 (HIPAA) and the CaliforniaConfidentiality of Medical Information Act (CMIA) or clinical trial data arealso not personal information under CCPA.Personal information covered by certain sector-specificprivacy laws, including the Fair Credit Reporting Act (FRCA), theGramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act(FIPA), and the Driver's Privacy Protection Act of 1994 are also not personalinformation under CCPA.Use of Personal InformationWe may use the personal information of the CompanyWorkforce for one or more of the following purposes:Employees, directors andofficers: We may use yourinformation for the following purposes: identifying you, verifying workauthorization, administering taxes and health, medical and other benefit plans,keeping track of your records, contacting you, facilitating payment to bankaccounts, contributing to 401(k) plans, garnishing wages required by law,evaluating performance, tracking efficiency and productivity, protectingagainst disclosure of confidential information and trade secrets, and ensuringcompliance with applicable laws and company policies.Job applicants: We may use your information for the following purposes:identifying you, keeping track of records, contacting you, evaluating yourcandidacy, performing background and reference checks, and onboarding you.Independent contractors: We may use your information for the following purposes:identifying you, administering taxes, keeping track of your records, contactingyou, facilitating payment to bank accounts, evaluating performance, trackingefficiency and productivity, protecting against disclosure of confidentialinformation and trade secrets, and ensuring compliance with applicable laws andcompany policies.Legal and Other Uses: We may also use your information if we believe it isrequired or appropriate: (a) to prevent or stop activity that we may think is,or is at risk of being, illegal, unethical or legally actionable activity; (b)to protect our rights, privacy, safety or property, and that of you and others;(c) to protect our operations and the security of our Services; (d) underapplicable law; (e) to comply with legal process and our legal obligations; (f)to respond to requests or requirements from public, law and governmentauthorities (including national security and law enforcement requirements) andprivate parties; (g) to enforce our terms and conditions; and (h) to allow usto pursue available remedies or limit potential damages.We may use your information as described to you whencollecting your personal information or as otherwise set forth in the CCPA.The Company will not collect additional categories ofpersonal information or use the personal information we collected formaterially different, unrelated, or incompatible purposes without providing younotice.