EU Addendum

Table of Contents

• Overview
• What Are Our Legal Bases for Processing Personal Data?
  • Data You Give Us or That We Receive From Our Affiliates or Service Providers
  • Data Automatically Collected About You
• What are Other Ways We Use Your Data?
• Transferring Personal Data Outside the EU, UK, or Switzerland
• What Are Your Choices and Rights?
• How to Contact Us

Overview

This EU Addendum (“EUAddendum“) supplements our Global Privacy Notice and explains how we collect, use, store, share, and otherwise process Personal Data about residents of the European Union, the United Kingdom, and Switzerland, as well as explains data rights and how to use them. Please read this EU Addendum carefully. This EU Addendum applies only to individuals who reside in the European Economic Area, the United Kingdom, or Switzerland.

As used here,”Personal Data” means any information that identifies you or can be used to identify you. If we use any capitalized terms that are not defined in this EU Addendum, you can find their meanings in the Global Privacy Notice. If there is any difference between what this EU Addendum says and what the Global Privacy Notice says, you should follow what is written in this EU Addendum.

What Are Our Legal Bases for Processing Personal Data?

Please see the Global Privacy Notice for a general disclosure on what Personal Data we collect and how we use it. Below, we describe further the legal bases we rely on to process your Personal Data under the GDPR.

Data You Give Us or That We Receive From Our Affiliates or Service Providers

Visiting the Platform

If you visit our Platform for informational purposes, we process your IP address, device and browser details (such as operating system, browser type and version, and device host name), referrer URL, time and date of your request, and clickstream data. We use this data to display the Platform, enable core functions, and maintain stability and security. The legal bases for this data processing are (i) performance of a contract with you (processing necessary to provide the Platform to you) and (ii) our legitimate interest in keeping the Platform secure, user-friendly, and functioning properly.

Using the Platform

When you use our Platform, we may need Personal Data (for example, your name and email address) to provide services or features you request. The legal basis for this data processing is performance of a contract with you. We process this data in order to grant you the desired access to our Platform.

Communicating With Us

If you contact us (for example, to request information or support), we process your name, contact details (such as your email address), and the contents of your message. We use this data to respond to you and provide support. The legal basis for processing this data is performance of a contract with you.

We may also send you updates about our Platform. We will generally send these only if you consent (for example, by signing up for a newsletter) and you have not opted out. You can object at any time using the contact details provided above or the unsubscribe link in our messages.

If we obtained your email address when providing a product or service, we may use it to market our own similar products or services. You can opt out at the point of collection and at any time thereafter by using the unsubscribe link in our emails.

The legal bases for this processing are (i) your consent and (ii) our legitimate interest in direct marketing where we use your email address to market similar products or services.

Participating in a Promotion, Contest, or Sweepstakes

If you choose to participate, we will process the data you provide (for example, your name, email address, and any other information requested at sign-up) for that purpose. The legal bases for the use of your contact details for promotions, contests, or sweepstakes is (i) your consent and (ii) our legitimate interest in direct marketing where we use your email address to promote similar products or services as provided to you before.

Data Automatically Collected About You

As you browse and interact with our Platform, we (and our service providers or other third parties) may use Automatic Tracking Technologies (as further detailed in the Global Privacy Notice). For strictly necessary Automatic Tracking Technologies, the legal bases for the use of your Personal Data are our legitimate interests in providing the webpage or a legal obligation to which we are subject. For non-strictly necessary Automatic Tracking Technologies, the legal basis is your consent.

What are Other Ways We Use Your Data?

In some cases, we process your Personal Data for the following additional purposes:

• Legal Obligations. We may process Personal Data to comply with laws (for example, record-keeping or tax requirements). The legal basis for such data processing is compliance with legal obligations to which we are subject.
• Corporate Transactions. We may process Personal Data in connection with mergers, acquisitions, sales, or other business transactions. The legal basis for this data processing is our legitimate interest to further the development of our company through mergers and acquisitions.
• Cooperation with Authorities. We may process Personal Data to meet obligations to cooperate with public authorities and government bodies. The legal basis for such processing is compliance with a legal obligation.
• Protection of Rights and Safety. We may process Personal Data to protect our rights, our users, customers, and others, including establishing, exercising, or defending legal claims. The legal basis for this data processing is either (i) compliance with legal obligations to which we are subject or (ii) our legitimate interest (or that of those affected) in asserting legal claims.

If we use your Personal Data for purposes not described above, we will tell you at the time of collection.

Transferring Personal Data Outside the EU, UK, or Switzerland

We are based in the United States. When you use our Platform, your Personal Data will be transferred to and processed in the United States.

When we share Personal Data with recipients outside the EU/EEA, the UK, or Switzerland (including to the United States), those countries may not offer the same level of data protection as under the GDPR. Data processed abroad may be subject to foreign laws and accessible to foreign authorities. Where required, we use safeguards to protect your Personal Data, such as: (i) an adequacy decision by the European Commission (or the UK or Swiss authorities); (ii) the European Commission’s Standard Contractual Clauses, including any UK International Data Transfer Addendum or UK-approved clauses, and Swiss-approved clauses; and/or (iii) other lawful transfer mechanisms. We also implement supplementary measures when needed. You can contact us to request more information about these safeguards.

If we transfer your personal data to a country outside the EU/EEA, the UK, or Switzerland, we do so only where a valid safeguard is in place. We rely on either: (a) an adequacy decision (or equivalent adequacy regulation) by the relevant authority (for example, the European Commission, the UK Secretary of State, or the Swiss Federal Council) confirming an adequate level of protection; or (b) where no adequacy decision exists, the appropriate Standard Contractual Clauses and, where required, supplementary measures.

What Are Your Choices and Rights?

Depending on your situation, you may have the rights below. To submit a consumer request use our interactive form found here Data Subject Request Forms, or contact us using the details in the How to Contact Us section below.

• Summarize. You can ask whether we process your personal data and request access to it, including a copy and information about why we process it, the types of data, who receives it, and how long we keep it.
• Correct or Restrict Processing. You can ask us to correct inaccurate or incomplete personal data, delete it, or limit how we use it—for example, if (a) it is incomplete or inaccurate, (b) it is no longer needed for the purposes for which it was collected, or (c) you withdraw the consent on which we are relying.
• Deletion. You can ask us to delete your personal data. However, there may be circumstances where we may not be able to agree to a deletion request due to a legal obligation or an applicable data retention request.
• Refusal or Withdrawal of Your Consent to Data Processing. If we rely on your consent to process your personal data, you can refuse to give consent and—without affecting processing that occurred before withdrawal—withdraw your consent to our processing of your personal data at any time.
• Right to Object. You can object at any time for marketing purposes, profiling, or other processing activities based on your interests. You can also object at any time to processing for direct marketing.
• Right to Data Portability. You can ask to receive personal data you provided to us in a structured, commonly used, machine-readable format and ask us to send it to another controller, where technically feasible.

You can take legal action to protect your rights and lodge a complaint with your competent supervisory authority if you believe your rights have been breached. For more information, please contact your local data protection authority – contact information may be found here: https://www.edpb.europa.eu/about-edpb/contact-us_en.

How to Contact Us

If you have any questions or comments about this EU Addendum, how we collect and use your data described here and in the Global Privacy Notice, or your choices and rights, please contact us using the details below.