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Privacy Policy

Position², Inc. takes your privacy seriously, and is strongly committed to protecting your privacy through our compliance with this policy (the “Privacy Policy”) in providing our websites (the “Sites”) and the services available through the Sites (the “Position² Services”). This Privacy Policy describes our collection and use of information, including personally identifiable information (“PII”), that Position² may collect from you or that you may provide to us, whether via the Sites, through the Position² Services or otherwise, and our practices for collecting, using, maintaining, protecting and disclosing that information.

This Privacy Policy applies to information that we collect:

In connection with your access and use of the Sites and the Position² Services.
In email, text and other electronic messages sent through or in connection with the Sites and the Position² Services
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.

Except as required by applicable law, this Privacy Policy does not apply to information collected by any third party, including through any application or content (including payment facilitation and advertising) that may link to or be accessible from or through the Sites and the Position² Services. For California residents: See information related to your rights in the section of this Privacy Policy titled “California Residents.” For residents of the European Economic Area: See information related to your rights in the section of this Privacy Policy titled “European Residents”. Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to visit, access, register for an account or use the Sites and the Position² Services. By visiting, accessing, registering for an account or using the Sites and the Position² Services, you agree to this Privacy Policy.

POLICY CHANGES

Position² may amend this Privacy Policy at any time at its sole discretion without prior notice to you. However, it is our policy to post any changes we make to our Privacy Policy on this page, with a notice that it has been updated upon visiting the Sites or by logging into your account. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring that we have an up-to-date active and deliverable email address for you. Your continued use of the Sites and the Position² Services after we make changes is deemed to be your acceptance of those changes, so we encourage you to review this Privacy Policy regularly for any changes.

INFORMATION COLLECTION AND USE

We collect several types of information from and about visitors to the Sites and users of the Position² Services, including information:

By which you may be personally identified, or PII, such as your name, e-mail address, biographical information, professional title, employment history, phone number and other identifiers by which you may be contacted online or offline;
That is about you but individually does not identify you, such as your IP address, geographic location and other information about your internet connection, the equipment you use to access the Sites or the Position² Services and general usage details; and
That is about your company, such as its name, website, products, services, pricing or other information relating to marketing and promotions.

We collect this information:

Directly from you when you provide it to us or give us access to your accounts or systems.
Automatically, as you navigate through or use the Sites, the Position² Services or the websites, products or services offered by our partners or affiliates, through the use of cookies, browser detection and other tracking technologies.

Information such as IP address, certain cookies, data, and technical information about your computer, is collected automatically, and some PII is only collected when you enter it manually on our web pages.

The information we collect on or through the Sites or the Position² Services may include:

Information that you provide by filling in forms or using interactive features available on the Sites or through the Position² Services. This includes information provided at the time of registering for an account or requesting further services. We may also ask you for information for use in our promotional or marketing materials or when you report a problem with the Sites or the Position² Services.
Records and copies of your correspondence (including e-mail address), if you contact us.
If you provide us access to your CRM systems, we may have access to personal contact information you have received from your customers or potential customers, provided that you have obtained consent from your customers or potential customers to provide access to such information. This information will be treated as your PII.

When you register for an account with us through the Sites or the Position² Services, we will ask you for PII. For the purposes of this Privacy Policy, PII includes:

Public or non-public information about you or your company, including without limitation, your name, address, email address, phone number, credit card and other billing information (if applicable);
Data relating your usage of Position² products and services; and
Any other information collected by Position² that is not otherwise publicly available.

As you navigate through and interact with the Sites and the Position² Services, we may also use automatic data collection technologies to collect certain information about your sessions, devices, browsing actions and patterns, including:

Details of your visits to the Sites or use of the Position² Services, including traffic data, location data, logs and other communication data and the resources that you access and use on the Sites or the Position² Services; and
Information about your device and internet connection, including your IP address, operating system and browser type.

Certain non-identifying information would be considered a part of your PII if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered non-identifying information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your PII with non-identifying information and/or aggregate it with information collected from other users to attempt to provide you with a better experience, to improve the quality and value of the Position² Services and to analyze and understand how our Sites are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions in accordance with this Privacy Policy.

We use your PII (in some cases, in conjunction with your non-identifying information) mainly to provide the Sites and the Position² Services to you and to administer your inquiries.

Position² may also use PII for other purposes, including without limitation to:

Correspond with you, such as to provide you with notices about your account or changes to the Sites or the Position² Services;
Provide aggregated (anonymous) data to our partners and affiliates;
Provide the requested information, products and services to you;
Process financial payments from you;
Engage in product and market research;
Develop product enhancements and new products or services;
In any other ways we may describe when you provide the information; and
For any other purpose with your consent.

We do not store any of your financial information including billing and credit card information. Your financial information is processed by secure, third party services and maintained in accordance with such third parties’ privacy policies.

AUTOMATIC DATA COLLECTION TECHNOLOGIES

We use cookies as a means for automatically collecting information about you through your interaction with the Sites and Position² Services. If you do not accept cookies, however, you may not be able to use all portions of the Sites or all functionality of the Position² Services. Position² may set and access cookies on your computer or device, or use web beacons on Position2’s websites, including the Sites, and third-party websites. A cookie is a small data file that certain websites write to your hard drive when you visit them, for record-keeping purposes. You can control and/or delete cookies from being placed on your computer – for details, see aboutcookies.org. First, we utilize persistent cookies to save your registration ID and login password for future logins to the Sites and Position² Services. Second, we utilize session ID cookies to enable certain features of the Sites, to better understand how you interact with the Sites and to monitor aggregate usage by Position² users and web traffic routing on the Sites. Unlike persistent cookies, session cookies are deleted from your computer or device when you log off from the Sites and Position² Services and then close your browser. Third-party advertisers on the Sites may also place or read cookies on your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do this, however, you may have to manually adjust some preferences every time you visit our page/site and some services and functionalities may not work. Please note that we do not respond to “do not track” requests.

DISCLOSURE OF INFORMATION

We may disclose aggregated information about our users, including our registered users, without restriction. Position² does not sell, rent, license or share PII with non-affiliated companies or individuals, except as described in this Privacy Policy. Personnel and Service Providers. We may employ third-party companies and individuals to facilitate our Sites and the Position² Services, to provide the Position² Services on our behalf, to perform Site-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Sites’ features) or to assist us in analyzing how our Sites and Position² Services are used. We also engage third parties to display our advertising to you on websites or services operated by those third parties. Our personnel and the third parties who have access to your PII only have such access to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. For example, any employees or consultants that are given access to your PII are subject to a confidentiality agreement as protective of your rights as this Privacy Policy. We also have agreements with our third-party advertising partners that contain confidentiality and data security obligations. Compliance with Laws and Law Enforcement. Position² may cooperate with government and law enforcement officials and private parties to enforce our agreement(s) with you and comply with the law or legal process. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Position² or any third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity. Business Transfers. Position² may sell, transfer or otherwise share some or all of its assets, including your PII, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. We may also disclose PII for any other purpose disclosed by us when you provide the information, or with your consent.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the information you provide to us. We have created mechanisms to provide you with the following control over your information:

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

CALIFORNIA RESIDENTS

This notice applies solely to California residents (“consumers”):

Position² adopts this notice to comply with the California Consumer Privacy Act of 2018 (the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.

This notice relates to information that identifies, relates to, describes, references, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer, household or device (“personal information”). Personal information does not include:

publicly available information from government records;
de-identified or aggregated consumer information; or
information excluded from the CCPA's scope, including personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), the Driver’s Privacy Protection Act of 1994, the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or the California Confidentiality of Medical Information Act (CMIA).

We collect, use and share your personal information in the same manner, from the same sources and for the same purposes as set out in this Privacy Policy.

We collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples Collected

A. 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

B. 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

C. 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). NO

D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES

E. 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. NO

F. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. YES

G. Geolocation data. Physical location or movements. YES

H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO

I. Professional or employment-related information. Current or past job history or performance evaluations. YES

J. 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. NO

K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you notice.

We do not sell any personal information and have not made any sales in the last twelve (12) months. However, we may share your personal information with a third party for a business purpose. When we share personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We disclosed the following categories of personal information to the following categories of third parties within the last twelve (12) months:

Category Examples Disclosed Third party Recipient(s)

(e.g. Google, Facebook, Bing, Hubspot)

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Some personal information included in this category may overlap with other categories.
YES Service providers;
Position² Personnel;
(e.g. Google, Facebook, Bing, Hubspot)

D. Commercial information.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES Position² Personnel

F. Internet or other similar network activity.Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. YES Service providers;
Position² Personnel;
(e.g. Google, Facebook, Bing, Hubspot)

G. Geolocation data. Physical location or movements. YES

H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO

I. Professional or employment-related information. Current or past job history or performance evaluations. YES Position² Personnel

J. 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. NO

YOUR CCPA RIGHTS

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This Section describes your CCPA rights and explains how to exercise those rights.

You have the right to request that we disclose to you certain information about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (discussed below), we will disclose to you:

the categories of personal information we have collected about you;
the categories of sources for the personal information we have collected about you;
our business or commercial purpose for collecting or selling that personal information;
the categories of third parties with whom we sell or share that personal information;
the specific pieces of personal information we have collected about you (also called a data portability request); and
if we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (i) sales, identifying the personal information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

You also have the right to request that we delete any of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (discussed below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your request to delete your personal information if it is necessary for us or our service providers to maintain your personal information in order to:

complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you;
detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
debug to identify and repair errors that impair existing intended functionality;
exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent;
enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
to comply with a legal obligation; or
otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
- calling us at 800-725-5507
- emailing us at privacy@position2.com with the subject line heading of “CCPA Consumer Privacy Request.”
- sending us a request by regular mail to:
  Position², Inc.
  2880 Lakeside Drive, STE 131
  Santa Clara, CA 95054
provide sufficient information that allows us to reasonably verify that you are the person about whom we have collected personal information or an authorized agent, which may include:
- the email address we have on file for you;
- the billing or corporate address; and
- the first and last name of at least one authorized user or contact.
describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or the authority to make the request and confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Once we receive a verifiable consumer request from you, we will confirm receipt within 10 days and we endeavor to respond to you within 45 days of receiving the verifiable consumer request. If we require more time, we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding our receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We will not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We do not sell your personal information. However, we want to make sure that you are aware of all of your consumer rights under the CCPA, which includes the right to opt-out of the sale of your personal information. Under the CCPA, if you are 16 years of age or older, you have the right to direct a business, at any time, not to sell your personal information (the “right to opt-out”). If you are under the age of 16, you (or your parent or guardian if you are 13 years or younger) are required to provide affirmative authorization (the “right to opt-in”) to the sale of your personal information. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

We will not discriminate against you for exercising your California Consumer Privacy Act rights. Unless permitted by the CCPA, we will not:

deny you goods or services;
charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
provide you a different level or quality of goods or services; or
suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

EUROPEAN RESIDENTS

We recognize that the European Economic Area (“EEA”) has established strict protections regarding the handling of certain PII that we may receive from visitors of the Sites or users of the Position² Services in the EEA, including requirements to provide adequate protection of such information outside of the EEA. Where we collect PII relating to individuals in the EEA, it will be transferred to our servers within the United States or Canada.

Under European data protection law, in certain circumstances, you may have the following rights:

the right to request access to any PII that we hold about you as well as related information, including the purposes for processing the information, the recipients or categories of recipients with whom the information has been shared, where possible, the period for which the information will be stored, the source of the information, and the existence of any automated decision making;
the right to obtain without undue delay the rectification of any inaccurate PII that we hold about you;
the right to request that PII held about you be deleted;
the right to prevent or restrict processing of your PII; and
the right to request the transfer of PII directly to a third party where this is technically feasible.

Where the processing of your PII is based on your previously given consent, you have the right to withdraw your consent at any time. You may also have the right to object to the processing of your PII on grounds relating to your particular situation.

We will collect, use and share PII in the same manner and for the same purposes as set out in this Privacy Policy.

In order to exercise your data protection rights, please contact us at privacy@position2.com. We take each request seriously and will comply with your request to the extent required by applicable law. For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file.

We will not be able to respond to a request if we no longer hold your PII. If you feel that you have not received a satisfactory response from us, you may consult with the data protection authority in your country.

By choosing to visit the Sites, use the Position² Services or provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the State of California and the United States of America. You also agree to abide by any dispute resolution mechanisms or limitations on damages contained in our Terms of Use, or other agreements that we have with you.

LINKS TO THIRD PARTY WEBSITES

The Sites and the Position² Services may contain links to other websites. Your use of websites to which the Site link is subject to the terms of use and privacy policies located on such third-party websites.

SECURITY

Position² is very concerned with safeguarding your information. We employ administrative, physical, procedural and electronic safeguards designed to protect your information from unauthorized access. For example, we use firewalls to protect our networks, we control and monitor access to our facilities, networks and systems, and we require all employees and vendors to enter into non-disclosure agreements. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your “personal data” (as defined in applicable state statutes on security breach notification) to you via email, through conspicuous posting on the Sites or as otherwise required by the applicable statue in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Sites or Position² Services, you are responsible for keeping your password confidential and not disclosing it to any other individual or individuals for all time the username and password is related to your Position² account. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your PII, we cannot guarantee the security of your PII transmitted to or through the Sites or the Position² Services. Any transmission of PII is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites or the Position² Services. Position² may transfer PII and other information to the United States and/or other countries, for storage, processing, and use by Position² and its affiliates.

ACCESSING AND DELETING YOUR INFORMATION

You can access and change certain PII by logging into your account. You can also request that Position² delete your PII by giving Position² notice at the email address delete@position2.com. However, if you, or your company, are using any Position² products and services, such requests will not be honored during the term of any such use. We may also refuse to accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect.

CHILDREN’S PRIVACY

Our Sites and the Position² Services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Sites or the Position² Services, or through any of their features, register for an account for the Position² Services or provide any information about yourself to us, including your name, address, telephone number, email address, or any username you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at delete@position2.com.

CONTACT INFORMATION

If you have any questions or comments about this Privacy Policy, or our privacy practices, please contact us at:
Position², Inc.
2880 Lakeside Drive, STE 131
Santa Clara, CA 95054