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Privacy Policy

Last Updated: June 25, 2022

Your privacy is very important to us and we take your privacy very seriously. This Privacy Policy describes how KNOWBL, Inc. (“Company”, “we”, “us”, or “our”) collects and uses the personal information you provide to us on our website and all other websites, mobile sites, applications, platforms and tools where this Privacy Policy appears or is linked, and through the use of our services, (collectively the “Site”). It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and around the globe, and we are responsible as “controller” of that personal information for the purposes of those laws.

By creating an account, providing information to us (by any means, whether in correspondence, via our Site, or otherwise), or continuing to use our services, you acknowledge that you have read, understood, and consent to be bound by this Privacy Policy.

If you do not agree with this PRIVACY Policy or our practices, you may not use our SITE. This PRIVACY Policy may change from time to time and your continued use of our SITE constitutes your acceptance of those changes. We encourage you to review this PRIVACY Policy periodically.

Personal Information We Collect About You. As used in this Privacy Policy, “personal information” means any information relating to an identified or identifiable individual. We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Category	Examples	Collected
Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	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. Some personal information included in this category may overlap with other categories.	Yes
Protected classification characteristics under California or federal law.	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).
Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data.	Physical location or movements.
Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information.	Current or past job history or performance evaluations
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Sensitive personal information	Personal information that reveals: (A) A person’s social security, driver’s license, state identification card, or passport number. (B) A person’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. (C) A person’s precise geolocation. (D) A person’s racial or ethnic origin, religious or philosophical beliefs, or union membership. (E) The contents of a person’s mail, email, and text messages unless the business is the intended recipient of the communication. (F) A person’s genetic data. The processing of biometric information for the purpose of uniquely identifying a consumer. Personal information collected and analyzed concerning a consumer’s health. Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.

This personal information is required to provide our Site and/or our services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing Site and/or our services to you.

Cookies and Other Tracking Technologies.

Cookies

Cookies are small text files of information stored by the Internet browser on your computer’s hard drive. We may use these cookies to collect browsing data to keep track of your preferences and profile information and to collect general usage and volume statistical information. Our cookies do not collect personal or confidential information and are not spyware.

There are a number of different types of cookies, however, our Site uses:

Essential – These cookies are necessary to the core functionality of our Site and some of its features, such as access to secure areas.
Performance and Functionality – These cookies are used to enhance the performance and functionality of our Site. For example, we may use these cookies so that we recognize you on our Site and remember your previously selected preferences. These could include what language you prefer and your geographic location. These cookies are nonessential to the use of our Site, however, without these cookies, certain functionality may become unavailable. A mix of first-party and third-party cookies are used.
Advertising – These cookies are used to make advertising messages more relevant to you. They prevent the same ad from continuously reappearing, ensure that ads are properly displayed for advertisers, and in some cases select advertisements that are based on your interests. Our Company sometimes shares online data collected through these cookies with our advertising partners. This means that when you visit another Site, you may be shown advertising based on your browsing patterns on our Site.
- Analytics and Customization –Our Company uses these cookies and technologies to analyze how the Site is accessed, used, or performing in order to improve your user experience and to maintain, operate and continually improve the Site. For example, we use Google Analytics on the Site to collect: page url/page title and user browser/system information, which includes browser type, referrer, language, java/flash support, IP address, and ad-serving data. For information on how Google Analytics collects and processes data, visit www.google.com/policies/privacy/partners/. To opt-out of Google Analytics, visit Google’s “How you can control the information collected by Google on these sites and apps” article available here.
- Social Media – These are cookies used to connect our Site to a third-party social media platform. For example, these cookies enable you to share our Site’s content through third-party social networks and other websites. They remember your details after the you sign in to a social media account from a website. These cookies may also be used for advertising purposes.
- Unclassified – These are cookies that have not yet been categorized. We are in the process of classifying these cookies with the help of their providers.

Web Beacons

Our Site contains electronic images known as web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our Site is used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns. We use a third party to gather information about how you and others use our Site. For example, we will know how many users access a specific page and which links they clicked on. We use this aggregated information to understand and optimize how our Site is used.

Targeted Advertising

Targeted Advertising (also known as online behavioral advertising) uses information collected on an individual’s web browsing behavior such as the pages they have visited or the searches they have made. Third parties collect this information by placing or accessing cookies in your browser when you visit this Site, or other, websites. If you would like to learn more about the third party advertisers that may be aware of the fact that you visit the Site, and to understand your choices about having such advertisers’ cookies turned off, please visit http://www.aboutads.info/choices/, http://www.youronlinechoices.com/, or http://www.networkadvertising.org/.

How to Manage Cookies.

You have the right to decide whether to accept or reject certain cookies. You can set your browser not to accept cookies, and the above websites tells you how to remove cookies from your browser. However, in a few cases, some of our Site features may not function as a result. Essential cookies cannot be rejected, as they are strictly necessary to provide you with our Site.

Do Not Track

We do not track users across the web and therefore do not respond to web browser “do not track” signals.

We do not authorize third parties to collect personal information from your visit of the Site for third party use without the your consent.

Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone or post) about our Site and/or our services, including exclusive offers, promotions or new products and/or services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell or share it with other organizations outside our Company for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

Contacting us by using one of the methods listed in the “How to Contact Us” Section below; or
Using the “unsubscribe” link in emails or “STOP” number in texts.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our Site. However, we may also collect information:

From publicly accessible sources (e.g., property records);
Directly from a third party (e.g., sanctions screening providers);
From a third party with your consent (e.g., your bank, your employer);
From cookies on our Site; and
Via our IT systems, including automated monitoring of our Site and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.

How and Why We Use Your Personal Information. Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.,:

To comply with our legal and regulatory obligations;
For the performance of our contract with you or to take steps at your request before entering into a contract;
For our legitimate interests or those of a third party; or
Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide our Site and/or our services to you	For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or our Company	For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to: existing and former customers; third parties who have previously expressed an interest in our services; third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

We may also anonymize, aggregate or de-identify personal information so the end-product does not identify you or any other individual. For example, we may use this information to generate norms by industry, geography, level, etc., enable us to understand where our services are being utilized, conduct ongoing validation studies, compile reports, and improve the services. Such aggregated, anonymized or de-identified information is not considered personal information for purposes of this Privacy Policy and we may use it for any purpose.

Who We Share Your Personal Information With. We routinely share personal information with:

Our affiliates, including companies within the our Company’s group;
Service providers we use to help deliver our Site and our services to you;
Other third parties we use to help us run our business, such as marketing agencies or website hosts;
Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO or Investors in People accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party without your consent.

Personal Information We Sold or Disclosed for a Business Purpose. In the preceding 12 months, we have sold to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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;
Characteristics of protected classifications under California or federal law;
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
Biometric information;
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
Geolocation data;
Audio, electronic, visual, thermal, olfactory, or similar information;
Professional or employment-related information;
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA); and
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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;
Characteristics of protected classifications under California or federal law;
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
Biometric information;
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
Geolocation data;
Audio, electronic, visual, thermal, olfactory, or similar information;
Professional or employment-related information;
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA); and
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing our Site and/or our services to you. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly; or
To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Policy. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymize it.

Children and our Site.

Our Site is not directed to children, and you may not use our Site if you are under the age of 18. If you are under 18, do not use our services, access the Site, or provide any information about yourself including, without limitation, your name, address, email address or any screen name or user name you may use. If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, in compliance with the Children’s Online Privacy Protection Act, we will purge such information from our database and cancel the corresponding accounts. If you believe we may have any information from or about a child under 13, please see our “How to Contact Us” Section below. Please visit the FTC's website at www.ftc.gov for tips on protecting children's privacy online.

Keeping Your Personal Information Secure. We use reasonable and appropriate physical, technical, and administrative safeguards to protect your information from unauthorized use, access, loss, misuse, alteration, or destruction. We endeavor to protect the personal information we receive, gather and store, by such means as password protection, firewalls and other means. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also require that third party service providers acting on our behalf or with whom we share your information also provide appropriate security measures in accordance with industry standards. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Transmissions over the internet are never entirely secure and we cannot guarantee the security of information you submit via our Site while it is in transit over the internet. Any such transmission of information by you over the internet is at your own risk.

Where Your Personal Information is Held. Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

Some of these third parties may be based outside the country where we originally collected your personal information. For more information, including on how we safeguard your personal information when this occurs, see below: “International Transfers of Personal Information”.

International Transfers of Personal Information. To bring you our Site it is sometimes necessary for us to share your personal information outside the country where we originally collected your personal information, e.g.:

With our offices in the United States;
With your and our service providers located throughout the world; or
Where there is an international dimension to the services we are providing to you.

These transfers may be subject to special rules under local data protection law.

These outside do not have the same data protection laws as the country where we originally collected the personal information. In particular, you are advised that the United States of America uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. If you are located outside the United States, we will only transfer your personal information if:

- you provide your explicit consent;
- the country to which the personal information will be transferred has been granted an appropriate adequacy decision by the local supervisory authority; or
- we have put in place appropriate safeguards in respect of the transfer, for example we have entered into the appropriate standard contractual clauses and required additional safeguards with the recipient, or the recipient is a party to binding corporate rules approved by a supervisory authority.

Our Company headquartered in the United States and utilizes service providers both in the United States and throughout the world. As such, our Company and our service providers may transfer your personal information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.

Where the laws of your country allow you to do so, by using the Site or our services, you consent and authorize our Company to transfer, store, and use all such information in the United States of America and any other country where we operate which may not offer an equivalent level of protection to that required in the country where you reside and to the processing of that information by us on its servers located in the United States of America as described in this Privacy Policy. If you do not want your personal information transferred to the United States of America and any other country where we operate, please do not submit any information to us or use our services.

If you would like further information, please contact us (see “How To Contact Us” below).

Third Party Websites.

If, in your interactions with the Site, you are linked or directed to, or click on, a third party website, we cannot control what information you may provide to that party or on that website, and we are not responsible for how that party may use or disclose any information you may provide to them. This is not as an endorsement by us of any third party website, content that may be offered on such third party website, or of any products or services provided by such third party. We do not control, nor are we responsible for, such third party website, product or service offerings. As such, we urge that you exercise caution before providing them with your personal information and to review the third party’s privacy policy for information on its data processing practice.

You should contact the site administrator for such third party website if you have any complaints, claims, concerns or questions regarding such third party website or its privacy practices.

Your Rights Under the CCPA. You may have the right under the California Consumer Privacy Act of 2018 (CCPA), the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know: The categories of personal information we have collected about you; The categories of sources from which the personal information is collected; Our business or commercial purpose for collecting or selling personal information; The categories of third parties with whom we share personal information, if any; and The specific pieces of personal information we have collected about you.
Personal Information Sold, Shared, Disclosed, or Used for a Business Purpose	In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link here: [URL].
Right to Limit Use and Disclosure of Sensitive Personal Information.	You have the right to opt-out of the use and disclosure of your sensitive personal information for anything other than supplying requested goods or services. To opt-out of the use and disclosure of your personal information, visit our homepage and click on the Limit the Use of My Sensitive Personal Information link here: [URL].
Right to Correction	You have the right to request correction of inaccurate personal information maintained by us about you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Right to Deletion	Subject to certain exceptions set out by statute, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers to delete your personal information from their records.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you; or Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please:

Call us, toll-free, at [toll-free phone number]; or
Email us at [contact information].

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

In connection with your request, you will need to provide us with:

Enough information to identify you (e.g., your full name, address, and customer or matter reference number); and
A description of what right you want to exercise and the information to which your request relates.

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

Changes to This Privacy Notice. This privacy notice was published on the date “Last Updated” above.

We may change this Privacy Policy from time to time. Changes to this Privacy Policy will be made by updating this page. Please visit this Privacy Policy regularly to read the current version.

How to Contact Us. Please contact us by post, email or telephone if you have any questions about this Privacy Policy or the information we hold about you.

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