This Privacy Policy explains how information is collected, used, and disclosed by Engag3d, Inc. and its subsidiary, Engag3d Pty Ltd ("Engag3d") and applies to information collected when you use or access the Engag3d Service through https://www.engag3d.com ("Engag3d Website"), https://<client name>.engag3d.com ("Engag3d Marketing Automation Platform"). We respect the privacy rights of users and recognize the importance of protecting information collected about you.

Please read the following carefully to understand how we will collect, use, and maintain your personal information. It also describes your choices regarding the use, access, and correction of your personal information.

We may change this Privacy Policy from time to time. If we make any changes, we will revise the "Last Updated" date at the end of this Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). If there are material changes to this Privacy Policy, we will notify you more directly by email or means of a notice on the home page prior to the change becoming effective. We encourage you to review our Privacy Policy whenever you access the Engag3d Service to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this Privacy Policy and do not wish your information to be subject to the revised Privacy Policy, you will need to cancel your Engag3d Plan with us and stop using the Engag3d Service. Your use of the Engag3d Service after the posting of such changes shall constitute your consent to such changes.

We may collect certain user information (including personal information and/or sensitive personal information) in the following ways.

Information You Provide To Us. We collect information you provide directly to us including when you use the Engag3d Service.

• For example, we collect information when you enter into an agreement with Engag3d as a customer, access and use the Engag3d Service (including but not limited to when you upload, download, or share information), participate in any interactive features of the Engag3d Service, submit a contact form, participate in a survey, activity or event, apply for a job, request customer support, or communicate with us via email and third-party social media sites. You may, however, visit our website anonymously, unless you have previously submitted your information through a form.
• The types of information we may collect directly from you include your name, username, email address, postal address, phone number, information about your Engag3d Plan preferences, employer's name, job title, transactional information (including services purchased or subscribed to and billing address), your registration for promotional offers and events, your newsletter subscriptions, as well as any contact or other information you choose to provide. Please be aware that the information you choose to provide in selecting your Engag3d Plan may reveal or identify information that is not expressly stated (for example, information you provide may reveal your gender). We also store information that you upload or provide to the Engag3d Services ("Content") in order to provide you with the features and functionality of the Engag3d Service.

Information We Collect Automatically When You Use the Engag3d Service. When you access or use the Engag3d Service, we may automatically collect information about you, including:

• Usage, Log, and Device Information: We collect information from your use of the Engag3d Service such as system activity, hardware settings, browser type, browser language, the date and time of your visit, and the referral URL. We monitor user activity in connection with the Engag3d Service and may collect information about the features and preferences you use, the Content you upload, download, share, or access while using the Engag3d Service, the Content you access, and any actions taken in connection with the access and use of your Content in the Engag3d Service.
• Information Collected by Cookies and Other Tracking Technologies: A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. You can set your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies.
  We use cookies and tracking scripts to understand and save your preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contract with third-party service providers to augment the Engag3d Service. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

Engag3d is a cloud based service provider and invests significant resources in providing its services in a secure manner. The Engag3d platform uses geographically distributed server infrastructure hosted using Amazon Web Services (AWS) Virtual Private Cloud. For more details, visit https://aws.amazon.com/privacy/

We may use the information collected through the Engag3d Service for the limited purpose of providing the Engag3d Service and related functionality and services for which Engag3d has been engaged. The information may be used for a variety of purposes, including:

• Provide, operate, maintain, and improve the Engag3d Service;
• Enable you to access and use the Engag3d Service;
• Send you technical notices, updates, security alerts, and support and administrative messages;
• Provide and deliver the services and features you request, process, and complete transactions, and send you related information, including purchase confirmations and invoices;
• Respond to your comments, questions, and requests, and provide customer service and support;
• Communicate with you about services, features, surveys, newsletters, offers, promotions, events, and provide other news or information about Engag3d and our select partners;
• Process and deliver survey entries and rewards;
• Monitor and analyze trends, usage, and activities in connection with the Engag3d Service and for promoting Engag3d;
• Investigate and prevent fraudulent transactions, unauthorized access to the Engag3d Service, and other illegal activities;
• Personalize and improve the Engag3d Service, and provide content and/or features that match your interests and preferences or otherwise customize your experience on the Engag3d Service; and
• For other purposes about which we notify you.

Additionally we may disclose personal data in special cases when we have a good faith belief that such action is necessary to: (a) conform to legal requirements or to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements; (b) protect and defend our rights or property; or (c) act to protect the interests of our users or others.

Do Not Track. Some browsers offer a "do not track" ("DNT") option. Because no common industry or legal standard for DNT has been adopted by industry groups, technology companies, or regulators, we do not respond to DNT signals. We will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

We will not share personal information about you or any Content with any third parties without your consent except as described in this Privacy Policy, or as defined in an agreement with us, in connection with the Engag3d Service. For example, we may share personal information about you:

• To Vendors, Consultants, and Other Service Providers: We may share your information with third-party vendors, consultants, and other service providers who are working on our behalf and require access to your information to carry out that work, such as to process billing or as it relates to any feature of the Engag3d Service. These service providers are authorized to use your personal information only as necessary to provide services to Engag3d and are based in North America (including USA), Europe (including UK), Australia and Asia (including India).
• In Compliance with Laws: We may disclose your information to a third party:
  1. if we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request;
  2. to enforce our agreements and policies;
  3. to protect the security or integrity of the Engag3d Service;
  4. to protect Engag3d, our customers, or the public from harm or illegal activities;
  5. to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person; or
  6. as otherwise directed by you.
• For Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You may be notified thereafter via email of any such change in ownership or control of your personal information.
• As Aggregated and/or Anonymized Data: We may also share aggregated and/or anonymized information with third parties that does not directly identify you.

Engag3d complies with the General Data Protection Regulation ("GDPR") with respect to personal data it receives in connection with the Engag3d Service.

Engag3d may act as a data controller under GDPR. For example, if you provide information to Engag3d or to one of our customers through the Engag3d Service, we may be a controller with respect to the personal data you share with us. In these situations, we will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you), and "legitimate interests." Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us at privacy@engag3d.com.

In other situations, Engag3d may act as a data processor under GDPR. For example, if a company contracts with Engag3d for access to the Engag3d Service, and in the course of that relationship shares personal data with Engag3d, the company may be the controller with respect to such data, and Engag3d may be a processor

You may access your Engag3d Service only through the use of an individual user ID and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been compromised in any way. In addition, always log out and close your browser when you finish your session.

If you have any questions about the security of your personal information, you can contact us at privacy@engag3d.com.

Account and Platform Information and Retention. You may update, correct, or delete information about you at any time by either logging into your Engag3d Service and modifying your information, or by emailing us at privacy@engag3d.com.

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy. If you wish to cancel your Engag3d Service, please email us at privacy@engag3d.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time. We will respond to your access request within 30 days.

Upon request, Engag3d will transfer your personal information that we have collected via the Engag3d Service. We will respond to your query within 30 days. To request this information, contact us at privacy@engag3d.com.

We will retain your information for as long as your Engag3d Service is active or as needed to provide you with the Engag3d Service. We will retain and use your information to comply with our legal obligations, resolve disputes, and enforce our agreements.

We will retain personal data we process on behalf of our customers and partners as directed by paying customers and partners. Engag3d will retain this personal information as necessary to comply with legal obligations, resolve disputes, and enforce agreements.

Upon request, Engag3d will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information that we are aware of. To request this information, contact us at privacy@engag3d.com.

If you have a complaint about the way your personal information is handled by Engag3d or one of our Partners, please email your complaint to Engag3d at privacy@engag3d.com. If the complaint cannot be resolved by Engag3d, it may be referred to the relevant authority responsible for personal data privacy regulation.

Marketing Communications. You may opt out of receiving promotional and newsletter emails from Engag3d by following the opt-out instructions provided in those emails. You may also optout of receiving promotional emails and other promotional communications from us at any time by emailing privacy@engag3d.com with your specific request. If you opt out, we may still send you non-promotional communications, such as security alerts and notices related to your access to or use of the Engag3d Service or our ongoing business relations.

Tracking Scripts and Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies or to prompt you before accepting such a cookie. Please note that, if you choose to remove or reject browser cookies, this could affect the availability or functionality of the Engag3d Service.

If you are a California resident, there are some additional rights that may be available to you under the California Consumer Protection Act ("CCPA").

• Exercising Your Rights: This policy explains the tools that we have made available to you to exercise your data rights under the CCPA, such as the right to deletion and the right to request access to the categories of information we have collected about you. For more information on how to exercise your rights please visit the "Your choices" section of this policy. We encourage you to manage your information, and to make use of the privacy controls we have included in our Services. You will not be discriminated against for exercising any of your privacy rights under the CCPA. In order to protect your information from unauthorized access or deletion, we may require you to provide additional information for verification. If we cannot verify your identity, we will not provide or delete your information.
• Sharing Your Personal Information: We don't sell your personal information. We do share your information with others as described in the "How we share information we collect" and "Sharing and Disclosure of Information" section of this policy.
• Processing Your Information: This policy describes the categories of personal information we may collect, the sources of that information, and our deletion and retention policies. We've also included information about how we may process your information, which includes for "business purposes" under the CCPA - such as to protect against illegal activities, and for the development of new products, features, and technologies. If you have questions about the categories of information we may collect about you, please be sure to visit the section of this policy called, "Information Collected". For more details about our processing activities, please be sure to visit the section called, "Use of Information."

If you have any questions or would like to exercise your rights under the CCPA, you can reach out to us at privacy@engag3d.com.

We may place links on the Engag3d Service, including the content that we publish online. When you click on a link to a third-party website from our Website, your activity and use on the linked website is governed by that website's policies, not by those of Engag3d. We encourage you to review their privacy and user policies.

The Engag3d Service is not directed to individuals under 18. We do not knowingly collect personal information from individuals under 18. If you become aware that an individual under 18 has provided us with personal information, please contact us at privacy@engag3d.com. If we become aware that an individual under 18 has provided us with personal information, we will take steps to delete such information. Please note, if you are under the age of 18, you may not use our website, products, or services.

Any questions about this Privacy Policy should be addressed to privacy@engag3d.com or to:

Registered US Address
Engag3d, Inc.
2035 Sunset Lake Road, Suite B-2,
Newark, Delaware 19702

Registered Australian Address
Engag3d Pty Ltd
24 Tuckeroo Parade,
North Lakes, Queensland 4509

Last Updated: July 8, 2021