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Cookie Policy

Cookies Policy
Updated May 17, 2022

Information we may collect indirectly.

We use browser cookies and similar tracking technologies(collectively, “Cookies”) to collect and store certain information when using,accessing, or interacting with our Portal Services.


Cookies are small files of information, usually stored onyour application, computer, or device, allowing our web servers or third-partyservices to recognize you. We store information that we collect through Cookiesto record your preferences, settings, and status for the Portal Services and toanalyze how you use the Portal Services. In some countries, including countriesin the European Economic Area (“EEA”), the information referenced above in thisparagraph may be considered personal information under applicable data protectionlaws. (More details below under the section entitled “Your Choices andRights.”)


With Cookies, we may, for example, collect information aboutthe type of device you use to access the Portal Services, the operating systemand version, your IP address, your general geographic location as indicated byyour IP address, your browser type, and data on your interaction with thePortal Services (such as search terms you enter or your frequency of usage,including your use across different websites and applications). We may alsocollect data regarding the functionality of our Portal Services, includingsystem-level metrics, to help us operate, maintain and improve the performanceand utilization of the Portal Services, to develop new features, protect the securityand safety of our Portal Services, and our customers, and to provide customersupport. We also use this data to develop aggregate analysis and businessintelligence that enable us to operate, protect, make informed decisions, andreport on the performance of our business.


Information we may collect from third-party sources.


We may receive information about you from third parties thathelp us update, expand, and analyze our records and prevent or detect fraud. Ifyou choose to link our Portal Services to a third-party account, we willreceive information about that account, such as your authentication token fromthe third-party account, to authorize linking. Please note that the informationwe may receive is governed by the third party’s privacy settings, policies,and/or procedures.


We may also collect information from social media platformsthat share information about how you interact with our social media content.Further, we may also receive publicly-available information about you from ourthird-party partners and combine it with data about you.


How We Use the Information We Collect

We use the information we collect in various ways,including:


provide, operate, and maintain our Portal Services;

improve, personalize, and expand our Portal Services;

understand and analyze how you use our Portal Services;

develop new products, services, features, and functionality;

communicate with you (either directly or through one of ourpartners) to provide customer service, to provide updates, and otherinformation relating to the Portal Services;

market or promote our Portal Services (including maintainingour list of contacts or assessing the effectiveness of our events, promotionalcampaigns, and publications);

understand how people use our Portal Services, including bygenerating and analyzing statistics;

support User Token business purposes, including dataanalysis; invoicing, detecting, preventing, and responding to actual orpotential fraud, illegal activities, or intellectual property infringement; and


comply and enforce applicable regulations and agreements,including enforcing our Terms of Service or other legal rights, or as requiredby applicable laws and regulations or requested by any judicial process orgovernmental agency.

The above uses may involve information that has beenaggregated so that the data is no longer capable of identifying an individual.We may also use this aggregated data to generate and commercialize insights.


How We May Share the Information, We Collect

We may share the personal information we collect We may also share the information we collect in various ways,including the following:


Other Users. We may share your information with Certifiers,Relying upon Parties, and other Users on the Marketplace Platform and elsewherein the Portal;


Employees and Contractors of User Token. Our employees andcontractors may be given access to any information we collect via our PortalServices. Our employees and contractors are required to keep this informationconfidential and are not permitted to use it for any purposes other than toenable you to use the Portal Services or deal with requests you submit to us.


Vendors and Service Providers. We may share information withthird-party vendors and service providers that provide services on our behalfto allow them to assist us in

1. providing our Portal Services,

2. promoting and/or marketing our Portal Services or otherservices or products, and

3. providing you with information, such as productannouncements, software updates, and special offers.


Advertising. We work with third-party advertising partnersto show you ads that we think may interest you. These advertising partners mayset and access their cookies, pixel tags, and similar technologies on ourPortal Services, and they may otherwise collect or have access to informationabout you which they may collect over time and across different onlineservices. Some of our advertising partners are members of the NetworkAdvertising Initiative or the Digital Advertising Alliance. To learn more aboutthese programs, or opt out of personalized ads, visit the Digital AdvertisingAlliance’s Self-Regulatory Program for Online Behavioral Advertising.


Third-Party Partners. We also share information about Userswith third-party partners to receive additional publicly-available informationabout you;


Information We Share When You Sign Up Through a Referral. Ifyou sign up for an Account through a referral from a friend, we may shareinformation with your referrer to let them know that you used their referral tosign up;


Analytics. We use analytics providers such as GoogleAnalytics. Google Analytics uses cookies to collect non-identifyinginformation. Google provides some additional privacy options regarding itsAnalytics cookies.


Business Transfers. Information may be disclosed andotherwise transferred to any potential acquirer, successor, or the assignee aspart of any proposed merger, acquisition, debt financing, sale of assets, orsimilar transaction, or in the event of insolvency, bankruptcy, or receivershipin which information is transferred to one or more third parties as one of ourbusiness assets;


As Required By Law and Similar Disclosures. We may alsoshare information to


1. satisfy any applicable law, regulation, legal process, orgovernmental request;

2. enforce this Privacy Policy and our Terms of Service,including investigation of potential violations hereof or thereof;

3. detect, prevent, or otherwise address fraud, security, ortechnical issues;

4. respond to your requests; or

5. protect our rights, property or safety, our users, andthe public.

This includes exchanging information with other companiesand organizations for fraud protection and spam/malware prevention;


With Your Consent. We may share information with yourconsent;


Aggregate Information. As legally permissible, we may useand share information about Users with our partners in aggregated orde-identified forms that cannot reasonably be used to identify you.


Legal Basis for Using Personal Information

Our legal basis for collecting and using personalinformation will depend on the information concerned and the specific contextin which we collect it.


However, we usually collect and use your personalinformation only when doing so:

1. It is needed to perform our contractual or legalobligations to you.

2. It is in our legitimate interests and not overridden byyour rights.

3. It is done with your consent.

We have a legitimate interest in operating our PortalServices and communicating with you as necessary to provide these PortalServices, for example, when responding to your queries, improving our platform,undertaking marketing, or detecting or preventing illegal activities.


If we ask you to provide personal information to comply witha legal requirement or to perform our contractual obligations with you, we willmake this clear at the appropriate time. We will advise you whether theprovision of your personal information is mandatory, which includes thepossible consequences of not providing your personal information.


You may withdraw any consent you have granted to use yourpersonal information by contacting us through the information we provide underthe section entitled “Contact Us” below. When required by applicable law, wewill rely on your consent for direct marketing and to collect information fromyour device or computer.


How We Protect and Store The Information We Collect

We deploy administrative, technical, and physical safeguardsdesigned to comply with applicable legal requirements and safeguard theinformation that we collect.


However, no information system can be 100% secure, so wecannot guarantee the absolute security of your information. Moreover, theinformation you transmit over networks that we do not control, including theInternet and wireless networks, may be compromised.


The Portal Services are controlled and operated We may store the information we collect in the EEA or othercountries where our service providers or we have facilities. We may transferinformation to countries outside of your country of residence, with dataprotection laws and regulations that differ from those in your country.


We retain personal information we collect from you where wehave an ongoing legitimate business need to do so (for example, to provide youwith a service you have requested or comply with applicable legal, tax, oraccounting requirements).


We retain the information we collect for no longer than isreasonably necessary to fulfill the purposes for which we collect the data andto comply with our legal obligations.


Third-party Services And Content

Our Portal Services may include integrated content (such asvideo materials) or links to content or services provided by third parties(such as on outside websites). This Privacy Policy does not address the thirdparties’ privacy, security, or other practices that provide such content orservices. We are not responsible for these third parties privacy policiesand/or practices, and we encourage you to carefully review their privacypolicies and terms of service.


We engage third parties that support the operation of ourPortal Services, such as analytics providers. These third parties may usetechnologies to track your online activities over time and across differentwebsites and online platforms.


Your Choices And Rights

You have choices and certain rights that can affect thecollection and sharing of your information.


Your Choices


Choices that can affect the collection and sharing of yourinformation include the following:


You can use some of the features of the Portal Serviceswithout an Account, thereby limiting the type of information that we collect;


You may unsubscribe from receiving certain promotionalemails from us. If you wish to do so, follow the instructions found at the endof the email or contact us through the information we provide under the sectionentitled “Contact Us” below. Even if you unsubscribe to these types of emails,we may still contact you for informational, transactional, account-related, orsimilar purposes;


Many browsers have an option for disabling cookies, whichmay prevent your browser from accepting new cookies or enable selective use ofcookies. If you choose not to accept cookies, some features of our PortalServices may no longer work for you. Further, you might continue to receiveadvertising material that is not tailored to your interests. Some devices allowyou to control this via your device settings.


Your Rights


Subject to local law, you may have certain rights regardingthe information that we have collected. If you would like to discuss orexercise the rights you may have, you may contact us through the information weprovide under the section entitled “Contact Us” below. We encourage you tocontact us to update or correct your information if it changes or if youbelieve that any information we have collected about you is inaccurate oroutdated. You can also ask us to see what personal information we hold about you,to erase your personal information, and you may tell us if you object to ouruse of your personal information. In some jurisdictions, you may have a rightto complain to your local data protection authority.


Your Data Protection Rights Under the General DataProtection Regulation (“GDPR”)


If you are a resident of the EEA, you have the followingdata protection rights, which you may exercise at any time by contacting usthrough the information we provide under the section entitled “Contact Us”below:


You may access, correct, update, or request deletion of yourpersonal information;


You may object to the processing of your personalinformation, ask us to restrict the processing of your personal information, orrequest portability of your data;


You have the right to opt-out of the marketingcommunications we send you. You can exercise this right by clicking on the“unsubscribe” or “opt-out” link in the marketing emails we send you or bycontacting us to opt-out of other forms of marketing;


If we have collected and processed your personal informationwith your consent, you can withdraw your consent. Withdrawing your consent willnot affect the lawfulness of any processing of personal information weconducted before your withdrawal, nor will it affect the processing of yourpersonal information conducted in reliance on lawful processing grounds otherthan consent;


You have the right to complain to a data protectionauthority about our collection and use of your personal information. Please getin touch with your local data protection authority for more information.


We respond to all requests we receive from individualswishing to exercise their data protection rights in accordance with applicabledata protection laws.


Children Under Thirteen


User Token is not directed to children under the age ofthirteen, and User Token will never knowingly collect personal information fromchildren under thirteen. If you are under the age of thirteen, you must askyour parent or guardian for permission to use our Portal Services.


Changes to This Privacy Policy

We may update this Privacy Policy periodically, and weencourage you to review this page periodically. If we make any material changesin the way we collect, use, and/or share the personal information you have provided,we will notify you by posting notice of the changes clearly and conspicuously.


How to Contact Us

The data controller of your personal information isUserToken


If you would like to contact us, please email us . We welcome your inquiries and comments.