Last Updated: July 21, 2020

This privacy notice applies to any InnerPal, Website, service, or tool (collectively "Services") where this privacy notice is referenced, regardless of how you access or use them, including through mobile devices. This Privacy Policy incorporates by reference the InnerPal terms of use. Note that we combine the information we collect from you from the Site, through the Service generally, or offline. This Privacy Policy sets forth our policy with respect to information that can be associated with or which relates to a person and/or could be used to identify a person ("Personal Data") that is collected from Users on or through the Services. We take the privacy of your Personal Data seriously. Because of that, we have created this Privacy Policy. Please read this Privacy Policy as it includes important information regarding your Personal Data and other information.

WE ARE NOT HEALTH CARE PROVIDERS. WE DO NOT COLLECT HEALTH CARE NOR MEDICAL INFORMATION. PLEASE CONSULT YOUR HEALTH CARE PROVIDER BEFORE MAKING ANY HEALTHCARE DECISIONS OR FOR GUIDANCE ABOUT A SPECIFIC MEDICAL CONDITION. BY ACCESSING OR USING OUR WEB BROWSER, YOU AGREE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE POLICIES AND TERMS. IF YOU DO NOT AGREE, YOU MAY NOT USE OUR SERVICES.

CMIA Compliance. CMIA establishes standards to protect Medical Information of the individuals that use the Service. We do not collect Medical Information.

HIPAA Compliance. The HIPAA Privacy Rule establishes standards to protect users of the Service individuals’ medical records and other personal health information. We do not collect information regarding the personal health of individuals. Users however may provide Mental Health providers with protected health information or “PHI,” as defined by the Health Insurance Portability and Accountability Act (HIPAA). This is any individually identifiable health information that a healthcare provider or another “business associate” to your healthcare provider receives about you. Any Medical information entered into InnerPal Services is not collected.

Changes. We may amend this privacy notice at any time by posting the amended version on this site including the effective date of the amended version.

We are a data Processor and Collector. We process data received from our services and take proportionate precaution in storing such information for short periods on our secure servers until permanently destroyed. Our servers and offices are located in the United States, so your information may be transferred to, stored, or processed in the United States. Our service collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, our Platform has collected the following categories of personal information from its consumers within the last twelve (12) months:

1. Category A: Identifiers
   1. Examples: A real name Information, Internet Protocol address, email address, or other similar identifiers, device information.
   2. Collected: YES
2. Category B: Personal information categories.
   1. Examples: A name, signature, Social Security number, physical characteristics 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 card number, debit card number, or any other financial information, medical information, or health insurance information.
   2. Collected: YES
3. Category C: Protected classification characteristics under applicable laws.
   1. Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
   2. Collected: YES

We obtains the categories of personal information listed above from the following categories of sources:

1. Directly from you. For example, from forms you complete on our Platform.
2. Indirectly from you. For example, from observing your actions on our Platform or interactions with our advertisers.

Personally Identifiable Information is information that identifies a specific person. When you engage in certain activities via the Company Service, including but not limited to creating an account, sending feedback, or otherwise participating in the Company Service (collectively, “Identification Activities”), we will ask you to provide certain information about yourself. We also collect the following:

• Identity Data
• Contact Data
• Technical Data
• Usage Data
• Transaction Data
• Financial Data
• Assessment Data
• Profile Data
• Marketing and Communications Data

If you elect to engage in an Identification Activity we will ask you to provide us with certain personal information about yourself, such as your name, address (including zip code), email address, credit card information, telephone number and/or any other information you provide to us, to process your transaction, send communications about them to you, and populate forms for future transactions. When you enroll in the Company Service, we will also ask you to provide us with additional information, such as credit card information. Depending on the Identification Activity, some of the information we ask you to provide will be identified as mandatory and some identified as voluntary. If you do not provide mandatory information for an Identification Activity, you will not be permitted to engage in that Identification Activity with the Company Service. Depending on the Identification Activity, Company might not re-ask you for Personally Identifiable Information if such are already stored with us. If you enroll in the Company Service through a third party (such as Facebook or Google) then Company will receive Personally Identifiable Information from such third party and by using the Company Service, you consent to such receipt of Personally Identifiable Information and its use pursuant to this Privacy Policy by Company.

Non-Personally Identifiable Information is information that does not identify a specific person. This type of information may include things like the Uniform Resource Locator (“URL”) of the Website you visited before coming to the Company Service or otherwise participating in the Company Service, the URL of the Website you visit after leaving the Company Service, the type of browser you are using, your Internet Protocol (“IP”) address, mobile carrier information, mobile device information, or general and/or aggregated location data that does constitute Personally Identifiable Information. We, and/or our authorized Third-Party Service Providers, may automatically collect this information when you visit or use the Company Service using electronic tools like Cookies and Web beacons or Pixel tags, as described below in this Privacy Policy. We use Non-Personally Identifiable Information to troubleshoot, administer the Company Service, analyze trends, gather demographic information, comply with applicable law, and cooperate with law enforcement activities. We will also share this information with our authorized Third-Party Service Providers to measure the overall effectiveness of our products and services.

Personal information collected from Third Parties. We supplement the personal information we collect directly with information collected from third parties and add it to your account information. For example, we collect and use demographic and other information that is publically available in an applicable jurisdiction, additional contact information, credit check information, and information from credit bureaus, as allowed by applicable national laws

1. We allow you to share information with social media sites, or use social media sites to create your account or to connect your account with the respective social media site. Those social media sites may give us automatic access to certain personal information retained by them about you (e.g., content viewed by you, content liked by you, and information about the advertisements you have been shown or have clicked on, etc.). If you provide us with access to any site with video content, then you agree that we can share your video viewing with, or obtain information about your video viewing from, third-party social media sites for at least two years or until you withdraw authorization or connection to the social media site.
2. You control the personal information you allow us to have access to through the privacy settings on the applicable social media site and the permissions you give us when you grant us access to the personal information retained by the respective social media site about you. By associating an account managed by a social media site with your account and authorizing us to have access to this information, you agree that we can collect, use and retain the information provided by these social media sites in accordance with this privacy notice. We may also use plug-ins or other technologies from various social media sites. If you click on a link provided via a social media plug in, you are voluntarily establishing a connection with that respective social media site.
3. If you give us personal information about someone else, you must do so only with that person’s authorization. You agree to inform them how we collect, use, disclose, and retain their personal information according to our privacy notice.

Information Collected From All Users. Information you provide to us: For all Users we collect Personal Data when you voluntarily provide such information to the Services, such as when you register for access to the Services, contact us with inquiries, respond to one of our surveys or browse or use certain parts of the Services. The Personal Data we may collect includes without limitation your name, address, email address and any other information that you choose to provide and/or that enables Users to be personally identified.

1. Information we automatically collect: We also automatically collect certain technical data that is sent to us from the mobile device and/or browser through which you access the Services ("Automatic Data"). Automatic Data, includes without limitation, a unique identifier associated with your access device and/or browser (including, for example, your Internet Protocol (IP) address) characteristics about your access device and/or browser, statistics on your activities on the Services, information about how you came to the Services and data collected through Cookies, Pixel Tags, Local Shared Objects, Web Storage and other similar technologies. You can find out more information about how we use Cookies and other similar tracking technologies in our Cookie Policy.
2. When you register for the Services or otherwise submit Personal Data to us, we may associate other Non-Personal Data (including Non-Personal Data we collect from third parties) with your Personal Data. At such instance, we will treat any such combined data as your Personal Data until such time as it can no longer be associated with you or used to identify you.

User Profiles. User may create a profile, with certain or all information publicly available. Clients and Agencies may also create organization profiles. You may have the opportunity to create a profile, which consists of information about you, and may include Personal Information, photographs, examples of your work, information on work previously performed via the Service and outside the Service, skills, tests taken, test scores, hourly pay rates and earnings information, feedback information and other information, including your username (“Profile”). You may edit certain information in your Profile via your account and may choose to limit who is able to view certain content you post to your Profile. Clients and Agencies of associated individual users or companies may also have the opportunity to create an organization Profile. If, in any case, you believe that an unauthorized profile has been created about you, you can request for it to be removed by contacting us.

Cookies. The Service may provide you the opportunity to participate and post content publicly in forums, on blogs, through interactive features on InnerPal and through other communication functionality (“Community Forums”). You may choose, through such features or otherwise, to submit or post questions, comments, or other content (collectively, “User Forum Content”). Please note that certain information, such as your name and Profile may be publicly displayed on the Service along with your User Forum Content. Please note that your use of Community Forums is subject to the InnerPal Forum Rules and our Terms of Service. If you choose to voluntarily disclose Personal Information in your User Forum Content or use Community Forums to link to your Profile, that information will be considered public information and the protections of this Privacy Policy will not apply. To request removal of your personal information from our blog or community forum, contact us.

User Profiles. We use cookies, web beacons, unique identifiers, and similar technologies to collect information about the pages you view, the links you click, and other actions you take when using our Services, within our advertising or email content. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use both persistent cookies that remain on your computer or similar device (such as to save your registration ID and login password for future logins to the Service and to track your compliance with the InnerPal Terms of Service) and session ID cookies, which expire at the end of your browser session (for example, to enable certain features of the Service. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functionality of the Service.

We collect and use the Personal Data we collect in a manner that is consistent with this Privacy Policy, and applicable privacy laws. We may use the Personal Data as follows:

Specific Reason. If you provide Personal Data for a certain purpose, we may use the Personal Data in connection with the purpose for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.

1. We use your personal information to provide and improve our Services, provide you with a personalized experience on our sites, contact you about your account and our Services, provide you customer service, provide you with personalized advertising and marketing, and to detect, prevent, mitigate and investigate fraudulent or illegal activities.
2. We use the personal information we collect from you for a range of different business purposes and according to different legal bases of processing.

Access and Use. If you provide Personal Data in order to obtain access to or use of the Services or any functionality thereof, we will use your Personal Data to provide you with access to or use of the Services or functionality and to analyze your use of such Services or functionality. For instance, if you supply Personal Data relating to your identity or qualifications to use certain portions of the Services, we will use that information to make a decision as to granting you access to use such Services and to assess your ongoing qualification to use such Services.

Internal Business Purposes. We may use your Personal Data for internal business purposes, including without limitation, to help us improve the content and functionality of the Services, to better understand our Users, to improve the Services, to protect against, identify or address wrongdoing, to enforce our Terms of Service, to manage your account and provide you with customer service, and to generally manage the Services and our business.

Marketing. We may use your Personal Data for our marketing and advertising purposes, including (without limitation) by email, display media, and targeting other devices (such as tablets, mobile devices and televisions). We do this in order to inform you about services or events we believe might be of interest to you, develop promotional or marketing materials and display InnerPal or event-related content and advertising on or off the Services that we believe might be of interest to you. We may also do this on behalf of a Servicer, for example where your prior interactions with a Servicer suggest you may be interested in a particular type of service.

Use of Interest-Based Data. We sometimes make inferences about the type of services you may be interested in. We may use these inferences to help target advertising or customize recommendations to you, including on behalf of Servicers. We may do this on an aggregated or generalized basis.

Other Purposes. If we intend to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time the Personal Data is collected or we will obtain your consent subsequent to such collection but prior to such use.

Aggregated Personal Data. In an ongoing effort to understand and serve our Users better, we often conduct research on our customer demographics, interests and behavior based on Personal Data and other information that we have collected. This research is typically conducted on an aggregate basis only that does not identify you. Once Personal Data is in an aggregated form, for purposes of this Privacy Policy, it becomes Non-Personal Data.

Staying Signed in. When you sign in to your account on our Services, we give you the option to stay signed in to your account for certain amount of time. If you are using a public or shared cellular device, we encourage you not to choose to stay signed in. You or any other user of the cellular device/browser you signed in on will be able to view and access most parts of your account and take certain specific actions during this signed in period without any further authorization. If you are using a public or shared cellular device, you should sign out and/or clear your cookies when you are done using our Services to protect your account and your personal information.

How We Disclose and Transfer Your Personal Data. We are not in the business of selling your Personal Data. We consider this information to be a vital part of our relationship with you. Therefore, we will not sell your Personal Data to third parties, including third party advertisers. There are certain circumstances in which we may disclose, transfer or share your Personal Data with certain third parties without further notice to you, as set forth in this Privacy Policy.

Google, Social Media and Other Third Party Connections. Connecting Your InnerPal Account to Social Media Services. You can connect your InnerPal account to your accounts on third party services like Google, in which case we may collect, use, disclose, transfer and store/retain information relating to your account with such third party services in accordance with this Privacy Policy.

Legal Requirements. We may disclose your Personal Data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services, (d) act in urgent circumstances to protect the personal safety of Users of the Services or the public, or (e) protect against legal liability.

Security. We take commercially reasonable steps to help protect and secure the information it collects and stores about InnerPal Users. All access to the Site is encrypted using industry-standard transport layer security technology (“TLS”). When you enter sensitive information (such as tax identification number), we encrypt the transmission of that information using secure socket layer technology (“SSL”). We also use HTTP strict transport security to add an additional layer of protection for our InnerPal Users. But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Thus, while we strive to protect your Personal Information, InnerPal cannot ensure and does not warrant the security of any information you transmit to us.

We retain your Personal Data for as long as necessary to provide you with our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. If you have an account with us, we will typically retain your Personal Data for a period not less than thirty (30) days after you have requested that your account is closed. Data protection law provides you with rights in respect of Personal Data that we hold about you, including the right to request a copy of the Personal Data, request that we rectify, restrict or delete your Personal Data, object to profiling and unsubscribe from marketing communications. Registered InnerPal Users may update their choices regarding the types of communications you receive from us through your online account. You also may opt-out of receiving marketing emails from us by following the opt-out instructions provided in those emails. Please note that we reserve the right to send you certain communications relating to your account or use of the Service (for example, administrative and service announcements) via email and other means and these transactional account messages may be unaffected if you opt-out from receiving marketing communications. You may opt-out of receiving text messages by replying “STOP” to any text message received. Registered InnerPal Users who access the Service by using an InnerPal Website may, with permission, receive push notifications. Similarly, registered InnerPal Users who access the Service by using certain desktop browsers may, with permission, receive push notifications. Notification preferences can be modified in the settings menu for the Website or the applicable browser. All Users may request access to or correction of any Personal Information we have about them or close their account and/or request deletion of all Personal Information we have about them. In certain jurisdictions, Users may have certain rights with regard to their Personal Information. We will honor User requests to the extent we can reasonably do so and as required by law, but some information will remain on the Services, such as information you posted publicly. Upon request InnerPal will provide you with information about whether we hold any of your personal information. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. You may access, correct, or request deletion of your personal information by making updates to that information or by contacting InnerPal through your online account. If your information is deleted, then your account may become deactivated. If your account is deactivated or you ask to close your account, you will no longer be able to use the Service. If you would like to close your account in our system, you can do so through the InnerPal Service (once you have logged in, visit settings / user settings, and then click on the close my account link). We will use commercially reasonable efforts to honor your requests for deletion; however, certain information will actively persist on the Service even if you close your account, including information in your messages you posted to the Service. In addition, the rights described above may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information we are required by law to keep or have compelling legitimate interests in keeping (such as for fraud prevention purposes). Your Personal Information may remain in our archives and information you update or delete, or information within a closed account, may persist internally for our administrative purposes, to the extent permitted by law. In addition, we typically will not remove information you posted publicly through or on the Service. Bear in mind that neither you nor InnerPal can delete all copies of information that has been previously shared with others on the Service.

Limit the Personal Data You Provide. You can browse the Services without providing any Personal Data (other than Automatic Data to the extent it is considered Personal Data under applicable laws) or with limiting the Personal Data you provide. If you choose not to provide any Personal Data or limit the Personal Data you provide, you may not be able to use certain functionality of the Services.

Personal Data Provided to Others. This Privacy Policy does not apply to any Personal Data that you provide to another User or visitor through the Services or through any other means.

Third Party Links. This Privacy Policy applies only to the Services. The Services may contain links to other Websites not operated or controlled by us (the "Third Party Sites"). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Third Party Privacy Practices. This privacy notice addresses only our use and handling of personal information we collect from you in connection with providing you our Services. If you disclose your information to a third party, or visit a third party Website via a link from our Services, their privacy notices and practices will apply to any personal information you provide to them or they collect from you. We cannot guarantee the privacy or security of your personal information once you provide it to a third party and we encourage you to evaluate the privacy and security policies of your trading partner before entering into a transaction and choosing to share your personal information. This is true even where the third parties to whom you disclose personal information are bidders, buyers or sellers on our site.

Children - Children's Online Privacy Protection Act. We do not knowingly collect Personal Data from children under the age of eighteen (18). If you are under the age of eighteen (18), please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data through the Services without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Data to us through the Services, please contact us and we will endeavor to delete that information from our databases.

Google Analytics. We use Google Analytics to analyze the use of our Website. Google Analytics gathers information about Website use by means of cookies. The information gathered relating to our Website is used to create reports about the use of our Website. Google's privacy policy is available at: https://www.google.com/policies/privacy/. We use this data to analyze trends, gather demographic information, and cooperate with law enforcement activities.

International Privacy Laws. If you are visiting the Services from outside the United States, please be aware that you are sending information (including Personal Data) to the United States where our servers are located. That information may then be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how it is stored by us. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your Personal Data will at all times continue to be governed by this Privacy Policy.

Modifications. We reserve the right, in our sole discretion, to update or modify this Privacy Policy at any time (collectively, "Modifications"). Modifications to this Privacy Policy will be posted to the Site with a change to the "Updated" date at the top of this Privacy Policy. In certain circumstances InnerPal. may, but need not, provide you with additional notice of such Modifications, such as via email or with in-Service notifications. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was updated on the date indicated above. Your continued use of the Services following the effectiveness of any Modifications to this Privacy Policy constitutes acceptance of those Modifications. If any Modification to this Privacy Policy is not acceptable to you, you should cease accessing, browsing and otherwise using the Services.

Dispute Resolution. If you have a complaint about InnerPal's privacy practices you should contact us. We will take reasonable steps to work with you to attempt to resolve your complaint in accordance with the “Terms” incorporated with these policies.

The EU General Data Protection Regulation (GDPR) for EEA, SWITZERLAND AND UK ONLY. The GDPR requires InnerPal. and Servicers using the Service to provide Users with more information about the processing of their Personal Data. The GDPR requires us to tell you about the legal ground we're relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data for the purposes set out above will typically be because:

• You provided your consent; it is necessary for our contractual relationship;
• The processing is necessary for us to comply with our legal or regulatory obligations;
• And/or the processing is in our legitimate interest as a service platform.

Nevada & California Residents. Certain residents may opt out of the sale of “personally identifiable information”. “Personally identifiable information” includes first and last name, address, email address, phone number, or an identifier that allows a specific person to be contacted either physically or online. We do not engage in such activity; however, if you are a Nevada or California resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under law by emailing us. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

Transfers of Personal Data. As InnerPal. is a global company, we may need to transfer your Personal Data outside of the country from which it was originally provided. This may be intra-group or to third parties that we work with who may be located in jurisdictions outside the EEA, Switzerland and the UK which have no data protection laws or laws that are less strict compared with those in Europe. Whenever we transfer Personal Data outside of the EEA, Switzerland or the UK, we take legally required steps to make sure that appropriate safeguards are in place to protect your Personal Data.

Change of Ownership. If we are subject to a merger or acquisition with/by another company, we may share information with them in accordance with our global privacy standards. Should such an event occur, we will require that the new combined entity follow this privacy notice with respect to your personal information. If we intend to handle your personal information for any purposes not covered in this privacy notice, you will receive prior notification of the processing of your personal information for the new purposes.

Contact Us. If you have a question or a complaint about this privacy notice, our global privacy standards, or our information handling practices, you can reach us at:

Email - Support@InnerPal.com

Wecare@InnerPals.com