Privacy Policy

updated

06/04/2024

Website and Application Privacy Policy

This privacy policy for POLLPAPA, INC. (“Company,” “we,” “us,” or “our“), describes the types of information we may collect or that you may provide and the policies for collecting, storing, using, protecting, and/or sharing (“process“) your information when you use our services (“Services“), such as when you:

• Visit our website at https://www.pollpapa.com, or any website of ours that links to this privacy notice;

• Download and use our mobile application (POLLPAPA), our Facebook application (POLLPAPA), or any other application of ours that links to this privacy notice; or

• Engage with us in other related ways, including any sales, marketing, or events.

This policy applies only to information we collect through our Services. This policy DOES NOT apply to information that:

• We collect offline or on any other Company applications or websites, including websites you may access through the Services, that do not link to this privacy notice; or

• You provide to or are collected by any third party.

These other websites, applications and third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

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Questions or concerns? Please read this privacy notice carefully to understand our policies and practices regarding your information and how we will treat it and your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. By using our Services, you agree to this privacy notice. This policy may change from time to time.

Your continued use of the Services after we revise this policy means you accept those changes, so please check the policy notice periodically for updates. If, after reading this privacy notice, you still have any questions or concerns, please contact us at support@pollpapa.com.

Summary of key points

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. You can also click hereto go directly to our table of contents.

What personal information do we process?When you visit, use, or navigate our Services, we may process personal information depending on how you interact with the Company and the Services, the choices you make, and the products and features you use. “Personal Information” shall mean any 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 device. Personal Information includes, but is not limited to, real names, aliases, postal addresses, unique personal identifiers, online identifiers, Internet Protocol addresses, email addresses, account names, social security numbers, driver’s license numbers, passport numbers, or other similar identifiers. Click hereto learn more.

Do we process any sensitive personal information?We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Click hereto learn more.

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Do we receive any information from third parties?We may receive information from public databases, marketing partners, social media platforms, and other outside sources. Click hereto learn more.

How do we process your information?We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Click hereto learn more.

In what situations and with which types of parties do we share personal information?We may share information in specific situations and with specific categories of third parties. Click hereto learn more.

How do we keep your information safe?We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot, and do not, guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Click hereto learn more.

What are your rights? Depending on where you are located geographically will dictate the applicable privacy law governing your specific rights regarding your personal information. Click hereto learn more.

How do you exercise your rights?The easiest way to exercise your rights is by contacting us at support@pollpapa.com. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what the Company does with any information we collect? Click hereto review the notice in full.

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Table of contents

1. What information do we collect?

1. How do we process your information?

1. What legal bases do we rely on to process your personal information?

1. When and with whom do we share your personal information?

1. What is our stance on third-party websites?

1. Do we use cookies and other tracking technologies?

1. How do we handle your social logins?

1. How long do we keep your information?

1. How do we keep your information safe?

1. Do we collect information from minors?

1. What are your privacy rights?

1. Controls for do-not-track features

1. Do California residents have specific privacy rights?

1. Do we make updates to this notice?

1. How can you contact us about this notice?

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16.  How can you review, update, or delete the data we collect from you?

1. What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or when you otherwise contact us.

Personal Information Provided by You.The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

1. names

1. phone numbers

1. email addresses

1. mailing addresses

1. usernames

1. passwords

1. contact preferences

1. contact or authentication data

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• billing addresses

• debit/credit card numbers

• gender

• household income

Sensitive Information.When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• information revealing race or ethnic origin

• information revealing political opinions

• information revealing religious or philosophical beliefs

• social security numbers or other government identifiers

• student data
• citizenship or immigration status
• genetic and biometric data
• precise geolocation

Social Media Login Data.We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.

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[b Application Data.] If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.

• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s camera, contacts, microphone, SMS messages, storage, social media accounts, calendar, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.

Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

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All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect through these technologies includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device

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event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).

• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

• Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and

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custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g., Facebook or Twitter), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account’s privacy settings.

Information collected when you use our Facebook application(s). We, by default, access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends,

check-ins, and likes, and you may choose to grant or deny us access to each individual permission.

Review of Social Media Privacy Settings

In recognition of the interconnected nature of social media and your use of our Services, we encourage all users to review and adjust their privacy settings on their social media accounts to ensure a level of privacy that is comfortable for them. If you choose to interact with POLLPAPA, INC. through social media platforms, it is important to understand that the information shared or made public can be accessed by us in accordance with your privacy settings on those platforms. To manage and protect your personal information effectively, we recommend regularly reviewing the privacy settings and policies of your social media accounts to control the information you share and with whom it is shared.

2. How do we process your information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and

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to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts.We may process your information so you can create and log in to your account, as well as keep your account in working order.

• To deliver and facilitate delivery of services to the user.We may process your information to provide you with the requested service.

• To enable user-to-user communications.We may process your information if you choose to use any of our offerings that allow for communication with another user.

• To request feedback.We may process your information when necessary to request feedback and to contact you about your use of our Services.

• To deliver targeted advertising to you.We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.

Opt-Out of Targeted Advertising

In recognition of your privacy rights and preferences, POLLPAPA, INC. provides you with the option to opt-out of receiving targeted advertising based on your personal information and activity. If you prefer not to receive personalized ads that are tailored to your interests and activities, you may opt out by following the steps provided below:

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1. Visit our Privacy Preferences page: Navigate to [Privacy Preferences Link] to access your privacy settings.

1. Select “Advertising Preferences”: Within the Privacy Preferences section, find the option labeled “Advertising Preferences” and click on it.

1. Opt-Out of Targeted Advertising: You will see an option to opt out of receiving targeted advertising. Select this option to indicate your preference not to receive personalized advertisements.

1. Save Your Preferences: After selecting your preference, ensure to save your changes. Your preferences will be updated immediately, and you will no longer receive targeted advertisements from us.

Please note that opting out of targeted advertising does not mean you will no longer see advertisements from POLLPAPA, INC. Rather, the advertisements may not be as relevant to your interests. Additionally, we may still use your information for other purposes as outlined in our Privacy Policy, such as to provide the services you have requested.

Your privacy is of utmost importance to us, and we are committed to respecting your choices. If you have any questions or need further assistance with your advertising preferences, please contact us at support@pollpapa.com.

• To protect our Services.We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

• To identify usage trends.We may process information about how you use our Services to better understand how they are being used so we can improve them.

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• To save or protect an individual’s vital interest.We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

1. What legal bases do we rely on to process your information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

As such, we may rely on the following legal bases to process your personal information:

1. Consent.We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent).You can withdraw your consent at any time. Click hereto learn more.

1. Performance of a Contract.We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

1. Legitimate Interests.We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

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• Develop and display personalized and relevant advertising content for our users

• Analyze how our services are used so we can improve them to engage and retain users

• Diagnose problems and/or prevent fraudulent activities

• Understand how our users use our products and services so we can improve user experience

• Legal Obligations.We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

• Vital Interests.We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
• Exceptional Cases. We may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

• For investigations and fraud detection and prevention

• For business transactions provided certain conditions are met

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• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

• For identifying injured, ill, or deceased persons and communicating with next of kin

• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

• If the collection is solely for journalistic, artistic, or literary purposes

• If the information is publicly available and is specified by the regulations

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

4. When and with whom do we share your personal information?

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In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties“) who perform services for us or on our behalf and require access to such information to do that work. The categories of third parties we may share personal information with are as follows:

• Affiliate Marketing Programs

• Communication & Collaboration Tools

• Data Analytics Services

• User Account Registration & Authentication Services

[These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. However, these third parties are required to comply with our data protection policies and standards.]

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.]

We also may need to share your personal information in the following situations:

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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.

WhenweuseGoogleMapsPlatformAPIs.We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). To find out more about Google’s Privacy Policy, please refer to this link. We use certain Google Maps Platform APIs to retrieve certain information when you make location-specific requests. A full list of what we use information for can be found in this section and in the previous section titled “HOWDOWEPROCESSYOURINFORMATION?“. We obtain and store on your device (“cache”) your location for two (2) months. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document. The Google Maps Platform APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Economic Area (EU countries, Iceland, Liechtenstein, and Norway) or the United Kingdom, please take a look at our Cookie Notice.

Affiliates.We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

Other Users.When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

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1. What is our stance on third-party websites?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

1. Do we use cookies and other tracking technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use

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such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

1. How do we handle your social logins?

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform. If you log in using Facebook, we may also request access to other permissions related to your account, such as your friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

1. How long do we keep your information?

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In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process from accidental loss and from unauthorized access, disclosure, modification or unauthorized destruction. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot, and do not, guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is

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at your own risk. You should only access the Services within a secure environment.

We may transfer, store and process your information in countries other than your own. Our servers are primarily located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information in the United States and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all reasonable measures to protect your personal information in accordance with this privacy notice and applicable law.

If you are a resident of Russia, your data that we process and store with your consent, is processed and stored within our databases located in Russia in compliance with the Data Protection Act, Federal Law No. 152 FZ of 27 July 2006. Please be aware that your information may be, with notice to and consent from the Roskomnadzor, transferred to and stored by us in our facilities and by those third parties with whom we may share your personal information in the United States and other countries.

10. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

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We do not knowingly collect or solicit data from or market to, nor are the Services intended for, children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to delete such data from our records within 72 hours. If you believe we have any data from or about a child under age 18, please contact us at support@pollpapa.com.

11. What are your privacy rights?

In Short: In some states, such as California, or regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

You may exercise certain rights under applicable data protection laws regarding your personal data processed by the Company. In some states (like California) and regions like the EEA, UK, and Canada, you have additional rights regarding our use of your personal information. These rights may include the right: (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make any of the above such requests by contacting us through the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below, in

which case we will make every effort to comply with your request within 30 days.

We will consider and act upon any request in accordance with applicable data protection laws.

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If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details

here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html.

If you are located in Switzerland, the contact details for the data protection authorities are available

here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us through the contact details provided in the section “HOW CAN YOUCONTACT US ABOUT THIS NOTICE?” below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages that we send, or by contacting us using the details provided in the section “HOW CAN YOUCONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

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Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Retention of Information

In Short: We retain your personal information for as long as necessary to fulfill the purposes described in this privacy notice, comply with our legal obligations, resolve disputes, and enforce our agreements.

We only keep your personal information for as long as it is required for the purposes set out in this privacy notice and to satisfy our legal and contractual obligations. Beyond this period, we will securely delete or anonymize your personal information, unless we are legally allowed or required to maintain certain personal information, including situations such as the following:

1. If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute, we will retain the necessary personal information until the issue is resolved;

1. Where we are required to retain the personal information for our legal, tax, audit, and accounting obligations, we will retain the necessary personal information for the period required by applicable law; and

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3. Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.

After it is no longer necessary for us to retain your personal information, we will dispose of it in a secure manner according to our data retention and deletion policies.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

If you have questions or comments about your privacy rights, you may email us at support@pollpapa.com.

12. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

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13. Do California residents have specific privacy rights?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and (2) every individual who is domiciled in

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the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category          Examples                   Collecte d

A. Identifiers

Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

YES

B. Personal information categories listed in the California Customer Records statute

Name, contact information, education, employment, employment history, and financial information

YES

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C. Protected classification characteristics under California or federal law

Gender and date of birth          YES

D. Commercial information

Transaction information, purchase history, financial details, and payment information

YES

E. Biometric information

Fingerprints and voiceprints       YES

F. Internet or other similar network activity

Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

G. Geolocation data   Device location

H. Audio, electronic, visual, thermal, olfactory, or similar information

Images and audio, video or call recordings created in connection with our business activities

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I. Professional or employment-related information

Business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us

J. Education Information

Student records and directory information

K. Inferences drawn from other personal information

Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

YES

We may also collect other personal information outside of these categories instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;

• Participation in customer surveys or contests; and

• Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

POLLPAPA LLC collects and shares your personal information through:

• Targeting cookies/Marketing cookies

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• Social media cookies

• Beacons/Pixels/Tags

More information about our data collection and sharing practices can be found in this privacy notice.

You can opt out from the selling of your personal information by disabling cookies in Cookie Preference Settings and clicking on the Do Not Sell My Personal Information link on our homepage.

You may contact us by email at support@pollpapa.com, by visiting https://www.pollpapa.com, or by referring to the contact details at the bottom of this notice.

If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that the agent has been validly authorized to act on your behalf.

Authorized Agent Process

To facilitate the submission of requests by authorized agents on behalf of data subjects, POLLPAPA, INC. has established the following clear and streamlined process:

1. Submission of Authorization Proof: Authorized agents must submit proof of their authorization to act on behalf of the data subject. This proof may be in the form of a power of attorney, a written consent signed by the data subject, or a court order granting the agent authority to act on the data subject’s behalf.

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1. Verification of Data Subject’s Identity: In addition to the proof of authorization, the authorized agent is required to provide information necessary to verify the identity of the data subject they represent. This may include the data subject’s full name, email address, and any other relevant information previously provided to POLLPAPA, INC.

1. Contact Information of Authorized Agent: Authorized agents must provide their full name, address, phone number, and email address to ensure POLLPAPA, INC. can communicate effectively with them regarding the request.

1. Submission Method: Authorized agents are requested to submit the proof of authorization and any other required documentation via email to support@pollpapa.com, with the subject line “Authorized Agent Request.” Alternatively, documents can be sent by post to POLLPAPA, INC., 9S Peachtree Street, Norcross, GA, 30071, United States.

1. Review and Response: Upon receipt of the request and all necessary documentation, POLLPAPA, INC. will review the submission to ensure completeness and validity. POLLPAPA, INC. may contact the authorized agent for additional information if necessary. Once the review is complete, POLLPAPA, INC. will proceed with the processing of the request in accordance with applicable data protection laws and inform the authorized agent of the outcome.

POLLPAPA, INC. is committed to ensuring the privacy rights of all data subjects and provides this process to support the submission of requests by authorized agents in a secure and efficient manner.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each

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service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” your personal information.

POLLPAPA, INC. has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

• Category A. Identifiers, such as contact details like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.

• Category B. Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history, and financial information.

• Category C. Characteristics of protected classifications under California or federal law, such as gender or date of birth.

• Category E. Biometric information, such as fingerprints and voiceprints.

• Category F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.

• Category G. Geolocation data, such as device location.

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• Category H. Audio, electronic, visual, and similar information, such as images and audio, video, or call recordings created in connection with our business activities.

• Category I. Professional or employment-related information, such as business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us.

• Category J. Education information, such as student records and directory information.

• Category K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?“.

POLLPAPA LLC has sold the following categories of personal information to third parties in the preceding twelve (12) months:

• Category B. Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history, and financial information.

The categories of third parties to whom we sold personal information are:

• Ad Networks

• Affiliate Marketing Programs

• Data Analytics Services

• Retargeting Platforms

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• Social Networks

• User Account Registration & Authentication Services

• Product Research Companies

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information;

• the categories of personal information that we collect;

• the purposes for which the collected personal information is used;

• whether we sell your personal information to third parties;

• the categories of personal information that we sold or disclosed for a business purpose;

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• the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and

• the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights We will not discriminate against you if you exercise your privacy rights.

Verification process

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 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 will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

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Other privacy rights

• You may object to the processing of your personal information.

• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.

• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

To exercise these rights, you can contact us by email at support@pollpapa.com, by visiting https://www.pollpapa.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

14. Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

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15. How can you contact us about

this notice?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at support@pollpapa.com, or by post to: POLLPAPA LLC, 9S Peachtree street Norcross, GA, 30071, United States

16. How can you review, update, or delete the data we collect from you?

Review, update, or delete your personal information, please send us an email at PollPapa Support

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