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ContXtual, Inc. PrivacyPolicy

Last updated: May 10, 2022

ContXtual, Inc. (“ContXtual,” “we,” “us,” and “our”) provides a purpose built online platform for spatial computing to enable breakthrough products and services that allow our customers to communicate and collaborate in the metaverse using augmented and virtual reality (“AR/VR”) teleconferencing (the “Platform”). Our Privacy Policy (“Privacy Policy”) is designed to help you understand our practices regarding the collection, use, and disclosure of certain information, including your personal information, and to assist you in exercising your privacy rights.

Contact Us

If you have any questions about our privacy practices or this Privacy Notice, please contact us at:

ContXtual, Inc.
1916 Pike Place, Ste. 34

Seattle, WA 98101-1056
United States

support@contxtual.solutions 
https://www.contxtual.solutions/ 

Our Privacy Policy applies to information processed by us in the course of our business, including on our website (the “Site”), the Platform, and our related online and offline offerings (collectively, the “Services”).

Information We Collect

When you use our Services, we may collect the following kinds of information:

Personal Data

The personal data collected and processed by us in connection with your registration to and use of the Service can be divided into two general data categories: User Data and Analytics Data.

User Data

User Data is personal data collected directly from you or generated by our Service or us based on your use of the Service. We may collect User Data from our Users in a variety of ways, including, when they register to and use the Service, subscribe to a newsletter or fill out a form.

The following personal data collected and processed by us is necessary for our legitimate interest whilst fulfilling our contractual obligations towards our customer and other organizations and you and for the compliance with our legal obligations.

When User registers to the Service, we may collect the following information:

·       first and last name

·       email address

·       phone number

·       username

·       password

User Data You Give Us Voluntarily

We may also process other information provided by you voluntarily such as:

·       marketing opt-ins and opt-outs

·       data on your use of and interaction with the Service

·       data you have entered to the Service

·       information you provide in correspondence with us

Analytics

We use service providers such as Google Analytics and others to collect anonymized or aggregate information regarding user behavior and user demographics on the Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/
partners/
.

You can opt out of Google’s processing of data generated by your use of the Services by visiting http://tools.google.com/dlpage/gaoptout.

We may automatically collect the following Analytics Data when you visit or interact with our Service:

Device Information

We collect the following information relating to the technical device you use when using the Service:

·       device and device identification number, device IMEI

·       country

·       IP address

·       browser type and version

·       operating system

·       name of your Internet service providers

·       advertising identifier of your device

Usage Information

We collect information on your use of the Service, such as:

·       time spent on the Service

·       interaction with the Service

·       the time and date of your visits to the Service

·       the searches you made on the Service

Cookies, Web Beacons, and Personalized Advertising

We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect personal information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with the Services.

·        Cookies. Cookies are small text files placed in visitors’ device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.

·        Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Services that collects information about users’ engagement. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on particular content. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our Purpose for Collecting Your Personal Data

Purposes

There are several reasons for ContXtual to collect your personal data. We use your personal data to provide you the Service we processes your personal data to be able to make the Service available to you and to the entity you are representing.  If you contact our customer service, we will use the information provided by you to answer your questions or resolve your complaint.

Our Legal Obligations

We processes data to enable us to administer and fulfil our obligations under the law. This includes data processed for complying with our book keeping obligations and providing information to relevant authorities such as tax authorities.

For Communication And Marketing

We process your personal data to contact you regarding the Service and to inform you of changes relating to it. Your personal data is also used for the purposes of marketing the Service to the company you are representing.

For Quality Improvement Analysis

We may also process information about your use of our website and the Service to improve their quality, for example by analyzing any trends in their use. In order to ensure that our website and the Service are in line with your needs, personal data can be used for things like customer satisfaction surveys. When possible, we will do this using only aggregated, non-personally identifiable data.

De-identified and Aggregated Information Use

We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, de-identified or aggregated trends, reports, or statistics, or other analyses we create., and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

Basis to Collect and Use Your Data

ContXtual processes your personal data primarily to pursue our legitimate interest to run, maintain and develop our business and to create and maintain customer and other business relationships. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and we provide you with opt-out from our marketing communications and use anonymized or non-personally identifiable data when possible.

International Data Transfers

You agree that all personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States and other countries which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws. If you are a resident of the European Economic Area (EEA) and provide personal data to us, we will either seek your express consent to such transfer if you are an individual data subject in accordance with applicable law, or we will rely on mechanisms such as Standard Contractual Clauses.

We Share Your Data Within Our Company and With Certain Third Parties

We only share your personal data within our organization if and as far as reasonably necessary for the purposes of this Privacy Policy. We do not share your personal data with third parties outside of ContXtual unless one of the following circumstances applies:

For The Purposes Set Out In This Privacy Policy And To Authorized Service Providers

To the extent that third parties need access to User Data in order for us to provide the Service, we provide such third parties with your data (such as our authentication service partners). Furthermore, we may provide your personal data to our affiliates or to authorized service providers who perform services for us (including accounting, payment, hosting and advertising partners).  When your personal data is processed by third parties as data processors on behalf of ContXtual, we take contractual measures to ensure that your data is processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations and subject to our instructions and appropriate obligations of confidentiality and security measures.

For Legal Reasons and Legal Processes

We may share your personal data with third parties outside of our company if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, crime, security or technical issues; and/or (iii) protect the interests, properties or safety of ContXtual, the Users or the public as far as in accordance with the law. Whenever possible, we will inform you about such processing.

Disclosures to Protect Us or Others

We may access, preserve, and disclose any personal information we store in association with you to external parties if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation and prosecution of suspected or actual illegal activity.

Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your personal information may be transferred as part of such a transaction as permitted by law and/or contract.

With your consent

We may share your personal data with third parties outside our company when we have your explicit consent to do so. You have the right to withdraw this consent at all times.

Data Retention

We retain the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Your Privacy Rights and Choices

General
You may have the right to opt into certain uses of your personal information, or based on type of use and/or your geographic location, to object to or opt out of certain uses of your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at anytime by contacting us as described below.

Email Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to optout of those communications (e.g., communications regarding the Services or updates to this Privacy Policy).

Mobile Devices

We may send you push notifications through our Apps. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. With your consent, we may also collect precise location information if you use our Apps. You may opt out of this collection by changing the settings on your mobile device.

“Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Interest-Based Advertising

You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Depending on your domicile and applicable law, we may seek your express consent to the placement of cookies. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt out of personalized advertisements on some mobile applications by following the instructions for Android and iOS. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from advertisers that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at http://www.networkadvertising.org/
managing/opt_out.asp
, http://www.youronlinechoices.eu/ and http://www.aboutads.info/choices/.

Please note you must separately opt out in each browser and on each device.

Other Rights Depending On Your Location

Depending upon your location and in accordance with applicable laws, such as if you are resident in the EEA or in California, you may have the right to:

Access personal information about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic personal information transferred to another party.

Request Correction of your personal information where it is inaccurate or incomplete.

Request Deletion of your personal information, subject to certain exceptions prescribed by law.

Request Restriction or Object to Processing of your personal information, including the right to opt in or opt out of the sale of your personal information to third parties.

Not be Discriminated Against by us for exercising your privacy rights.

If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

Information Security

We take steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy. We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information. Unfortunately, no measures can be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us.  To the extent permitted by applicable law, by using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by sending a notice through the Services or by sending an e-mail to you.

Third Party Websites/Applications

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of, such other websites or applications. Visiting these other websites or applications is at your own risk.

Children’s Information

The Services are not directed to persons under 16 (or to children as required by applicable law), and we do not knowingly collect personal information from children. We will try to establish that you are at least 16 years old, and we require that if you are not, please do not misrepresent your age or use the Services. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any child’s personal information in violation of applicable law, we will promptly take steps to delete such information.

Supervisory Authority

If you are located in the European Union or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

Changes To Our Privacy Notice

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

California Consumer Privacy Act (CCPA) Privacy Notice

This CCPA Privacy Notice applies to California consumers and supplements the Privacy Notice.

We do not sell personal information. For purposes of the CCPA, we have collected the following categories of consumers’ personal information in the last 12 months:

Category of Personal Information

Category of Source(s)

Identifiers.

You, both directly and indirectly via the Services.
Our service providers, business partners, third party services, and advertising partners.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

You, both directly and indirectly via the Services.
Our service providers, business partners, third party services, and advertising partners.

Protected classification characteristics under California or federal law.

You, both directly and indirectly via the Services.
Our service providers, business partners, third party services, and advertising partners.

Commercial information.

You, both directly and indirectly via the Services.
Our service providers, business partners, third party services, and advertising partners.

Internet or other electronic network activity.

You, both directly and indirectly via the Services.
Our service providers, business partners, third party services, and advertising partners.

Geolocation data.

You, both directly and indirectly via the Services.
Our service providers, business partners, third party services, and advertising partners.

Professional or employment-related information.

You, directly.

Education information.

You, directly.

Inferences drawn from other personal information to create a profile about a consumer.

You, both directly and indirectly via the Services. Our service providers, business partners, third party services, and advertising partners.

We use the collected personal information for the following commercial and business purposes: (1) to provide and improve the Services; (2) for marketing purposes;(3) for fraud prevention and legal purposes; (4) to secure the Services; and(5) for audit purposes. Personal information within each of the categories maybe shared with the following categories of third parties: (1) service providers; (2) business partners; (3) advertising partners; and (4) other users. The categories of personal information are shared for the commercial and business purposes listed above.

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