i. Information You Voluntarily Give Us

ii. Information Collected Automatically

When you use Nudge, Inc., we collect some information automatically. The technologies we use to assist with this data collection include cookies, web beacons, tags and scripts and software development kits (or SDKs). We use these technologies on our digital properties, including our websites and apps, as well as in our email communications.

The categories of personal information we collect automatically include:

iii. A Note about Sensitive Personal Information

We generally don’t want to gather sensitive information about you. This includes:

• Government-issued IDs (such as your driver’s license, passport or social security number)
• Your racial or ethnic origin
• Your political opinions
• Your religion or other beliefs
• Your health, biometric or genetic characteristics
• Any trade union membership
• Your sexuality (information about your sex life or sexual orientation)
• Any criminal background
• The content of your private communications (other than messages you may send to us)

However, some laws define account access information, such as a username and password, as sensitive personal information, but we collect that information only for the accounts you create directly with us and not for any other account you may have with a third party.

Finally, there are situations when we request certain of the above information , but you can decline to answer. Outside those situations we would prefer you never share these types of information with us.

i. Privately Owned Databases:

Marketing, data analytic and social media-owned databases give us access to a range of information — like public data, survey data and more. This data sometimes includes your mailing address, your gender, your age, your household income and other demographic data.

ii. Social Media Platforms and Other Third-Party Services:

(Social media platforms include services like Facebook. Third-party services include services like Google)

You can link your social media or other third-party account to a Nudge, Inc. Service. By linking the services, you authorize us to collect, store and use any information they may give us(e.g., your email address).

We also receive information from you when you interact with our pages, groups, accounts or posts on social media platforms. This includes aggregate data on our followers (e.g., age, gender and location), engagement data (e.g., “likes,” comments, shares, reposts and clicks), awareness data (e.g., number of impressions and reach) and individual users’ public profiles.

We use your information to help you use and navigate Nudge, Inc., such as:

• Making Nudge, Inc. available to you
• Arranging access to your account
• Providing customer service
• Responding to your inquiries, requests, suggestions or complaints
• Completing your payments and transactions
• Sending service-related messages (e.g., a change in our terms and conditions)
• Letting you take part in paid services, polls, promotions, surveys, panels, research and comments.

We track your interests to personalize your experience using technology like algorithmic recommendations and machine learning. We also show you prices, promotions, products or services we believe you’ll find interesting, based on demographic and usage data.

We analyze data on our users’ subscriptions, purchases and usage behaviors. This helps us make business and marketing decisions.

For example, our analysis, which includes the use of technology like machine learning, lets us predict preferences and price points for our products and services. It helps us determine whether our marketing is successful. It also shows us characteristics about our subscribers, which we sometimes share in aggregate with advertisers.

Google Analytics is one of the analytics providers we use. You can find out how Google Analytics uses data and how to opt out of Google Analytics.

• For auditing: We verify that our internal processes work as intended and comply with legal, regulatory and contractual requirements.
• For fraud and security monitoring: We detect and prevent cyberattacks or unauthorized robot activities.
• For customer satisfaction: We assess users’ satisfaction with Nudge, Inc. and our customer care team.

We market our Nudge, Inc. to you. Sometimes we use marketing vendors to do this.

We serve ads through websites, locations, platforms and services operated and owned by third parties. Often these ads are targeted at people who have visited or registered for a Nudge, Inc. Service but have not subscribed to or purchased anything. The ads are also targeted at people with similar traits or behaviors to our subscribers or customers.

Sometimes we aggregate or de-identify information so that it can no longer identify you, as defined under applicable laws. This helps us better understand and represent our users, such as when we measure ad performance, create advertising interest-based segments or compile survey results. We can use and disclose this aggregated or de-identified information for any purpose, unless an applicable law says otherwise.

Our affiliates may access your information for the purposes listed here.

We work with service providers, as defined above, to carry out certain tasks, including:

When performing these tasks, service providers may have access to your personal information.

We sometimes allow them to use aggregated or de-identified information for other purposes, in accordance with applicable laws.

There are situations when we disclose your information to third parties beyond our service providers.

It is worth noting how practices of certain vendors and changes in law outside of our control have changed what we can say about this.

While we try to control the behavior of our vendors that we understand to be service providers, some of those vendors engage in activities beyond our control that may be seen by a regulator as the activities of “third parties,” not service providers.

The following provides more information about the circumstances in which we know we are disclosing personal information to third parties that are not service providers.

i. Communications Preferences

The choices described below are limited to the email address, phone or device used. They won’t affect subsequent subscriptions.

ii. Access, Correct, Change/Update, Delete or Restrict Processing of Your Personal Information

In some jurisdictions, you may exercise the following choices:

• Access, modify or delete the personal information we have about you
• Be informed of or receive an electronic copy of the personal information we have about you, for data portability.
• Restrict, or object to, how we process personal information about you

For example, in the European Union and the United Kingdom, you have the right to object to, or obtain a restriction of, the processing of your personal information under certain circumstances; and where the processing is based on your consent, you have a right to withdraw that consent at any time for future processing.

If you’d like to exercise any of the above choices, contact us via email at [email protected]. In your request, please be specific. State the information you want changed, whether you’d like your information suppressed from our database or whether there are limitations you’d like us to put on how we use your personal information. Please use the email address linked to that personal information — we only complete requests on the information linked to your email address. To verify your identity, we will email the email address you provide us, and which matches our records, and wait for your response. In some instances, we may also ask for additional information. This is how we verify your identity before complying.

In some jurisdictions, you can designate an authorized agent to make a request on your behalf. In order to do that, please provide the agent with written permission, signed by you, authorizing the agent to submit the request on your behalf. The agent must submit that written permission along with the request. We will contact you to verify your identity — and the authorized agent’s permission — before a response to the request is sent.

We’ll respond to your request in a manner consistent with applicable law, including any exceptions that may result in a request being denied in whole or in part.

We might need to keep certain information for recordkeeping purposes, or to complete a transaction you began prior to requesting a change or deletion (e.g., if you make a purchase or enter a promotion, you might not be able to change or delete the personal information provided until after the completion of the purchase or promotion).

In some cases, your request doesn’t ensure complete removal of the content or information (e.g., if another user has reposted your content).

iv. Browser and Platform Controls

v. Other Rights and Choices

You will not receive discriminatory treatment by us for the exercise of your privacy rights.

This Policy has been designed to be accessible to people with disabilities. If you experience difficulties accessing this Policy, please contact us at [email protected]. If you’d like, you can lodge a complaint with a data protection authority. A list of E.U. data protection authorities is available. But we encourage you to first contact us with any questions or concerns.

In some jurisdictions, you may appeal to us if we refuse to take action on your exercise of certain choices described above. In order to appeal such a refusal, please contact us at [email protected], using the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email.

i. Notice at Collection

At or before the time of collection, you have a right to receive notice of our practices, including the categories of personal information and sensitive personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared and how long such information is retained.

ii. Rights to Know, Correction and Deletion

You have a right to request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information. Note that we have provided much of this information in this Privacy Policy. You also have rights to request that we correct inaccurate personal information and that we delete personal information under certain circumstances, subject to a number of exceptions.

iii. “Do Not Sell or Share My Personal Information”

To the extent Nudge, Inc. “sells” your personal information (as the term “sell” is defined under the CCPA), you have the right to opt-out of that “sale” on a going-forward basis at any time.

If you’re a California resident, you have a right to opt-out from the “sale” or “sharing” of your personal information with third parties who are not our service providers (as those terms are defined under the California Consumer Privacy Act and the California Privacy Rights Act, or “CCPA” for short in this Policy). To exercise this right, click the Do Not Sell/Share My Information link on the bottom of the webpage where your information is being collected or go to “Account” and then “Settings” and “About This App” and click the “Do Not Sell/Share My Information” link there. You can also submit a request to opt-out by emailing us at [email protected] with the subject line “California Resident - Do Not Sell or Share.” Finally, if your browser supports it, you can turn on the Global Privacy Control to opt-out of the “sale” or “sharing” of your personal information.

If you have an account with Nudge, Inc. and are logged in, we will save your preference and honor your opt-out request across browsers and devices so long as you remain logged in. If you are not logged in, or do not have an account with any Nudge, Inc. listed above, your opt-out of the “sale” or “sharing” of personal information will be specific to the browser or device from which you have clicked “Do Not Sell/Share My Personal Information” and until you clear your cookies (or local storage in apps) on this browser or device.

We do not knowingly “sell” or “share” (as those terms are defined by the CCPA) the personal information of minors under 16 years old.

iv. Right to Limit Use and Disclosure of Sensitive Personal Information

If you are a California resident, effective January 1, 2023, you have a right to limit our use of sensitive personal information for any purposes other than to provide the services or goods you request or as otherwise permitted by law. To opt-out from such additional purposes, contact us via email at [email protected].

v. Authorized Agents

You can designate an authorized agent to make a request to exercise your rights under the CCPA on your behalf. In order to do that, please provide the agent with written permission, signed by you, authorizing the agent to submit the request on your behalf. The agent must submit that written permission along with the request. We will contact you to verify your identity — and the authorized agent’s permission — before a response to the request is sent.

vi. Non-Discrimination Rights

You may exercise any of your rights listed in this section without fear of unlawful discrimination.

vii. Record of Requests

We keep a record of requests that we received from California residents.

For data deletion and data access requests, our readers submit requests through email. In the email, they must indicate whether they reside in California. We then send an identity verification email to the user. If the user does not verify their identity in 45 days, their request will be denied. If the user does verify in 45 days, we begin to fulfill their request.

viii. California “Shine the Light” Privacy Rights

Under the California “Shine the Light” law, California residents can opt out of our sharing of their information to third parties (and sometimes affiliates) for their direct marketing purposes.

• To do so, email us at [email protected] with “Shine the Light Opt Out” in the subject line and your account number and phone number in the body of the email.

ix. Removal of Content for California Minors

If you’re a California resident under 18 years old and you’re registered with a Nudge, Inc. Service, you can ask us to remove content or information you’ve posted to a Nudge, Inc. Service. Email us at [email protected] with “California Under 18 Content Removal Request” in the subject line and tell us what you want removed. We will make reasonable efforts to remove the post from public view, although we cannot ensure the complete removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.