Privacy Policy, Last Updated: October 28, 2024

This Privacy Policy ("Privacy Policy") describes the types of information Network Tree, Co. (collectively, "Company", "we", "us", or "our") collects, uses, and shares about you when you visit or use our website at www.networktree.app and all related products, services, features, tools, the Network Tree CRM mobile application (the "App"), web applications, and content offered by Company of when you otherwise contact or interact with us (collectively, the "Service"). The terms "you" and "your" refers to you, the user. If you are using the Service on behalf of a business, association, or other entity, “you” or “your” will also refer to such business, association, or other entity, unless the context clearly dictates otherwise. You agree that you are authorized to consent to these terms on behalf of such business, association, or other entity, and we can rely on this. This Privacy Policy also explains how Company may use and share your Personal Information (as defined in Section 1), as well as the choices available to you.

By using/continuing to use the Service, you acknowledge you have read and understand and agree to the collection, storage, use, and disclosure of your Personal Information as described in this Privacy Policy, and you agree to the Terms of Service which is incorporated by reference. If you do not agree, please do not use the service.

Our Terms and Conditions

Eligibility to Use the Service

To use the Service you must be, and represent and warrant that you are, at least the age of majority in your state, province or jurisdiction of residence and competent to agree to these terms; or if you are under the age of majority in your state, province or jurisdiction of residence, you represent and warrant that your parent or legal guardian has reviewed this Privacy Policy with you and accepts them on your behalf; parents or legal guardians are responsible for the activities of their minor dependents while using the Service.

Terms of Service

If you choose to access or use the Service, your access and use, and any dispute over privacy is subject to this Privacy Policy and our Terms of Service, including, but not limited to, limitations on damages and resolution of disputes.

1. Personal Information We Collect

Generally, we collect four (4) types of information about you: (A) information and content you give us directly; (B) information we obtain automatically when you use our Service; (C) demographic information; and (D) information we get about you from other sources. When we talk about “Personal Information” in this Privacy Policy, we are talking about any information collected in accordance with this section. Please see below for more information on each category.

A. Information and Content You Give Us Directly
B. Information We Obtain Automatically When You Use Our Service
C. Demographic Information

We may collect demographic, statistical, or other aggregate information that is about you, but individually does not identify you. Some of this information may be derived from Personal Information, but it is not Personal Information and cannot be tied back to you. Examples of such aggregate information include gender, age, and race.

D. Information We Get About You From Other Sources

We may receive information about you from other sources and add it to our information, including from third-party services and organizations who have the right to provide us with such information. We protect this information according to the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data. These sources may include: online and offline data providers, from which we obtain demographic, interest-based, and online advertising related data; publicly-available sources such as open government databases or social networks; and service providers who provide us with information, and updates to that information, based on their relationship with you. By gathering additional information about you, we can correct inaccurate information, enhance the security of your transactions, and give you product or service recommendations and special offers that are more likely to interest you.

2. How We Use Your Information

We may use the information we collect about you in a variety of ways, to provide our Service, for administrative purposes, and to market and advertise our Service and products.

A. We Use Your Personal Information to Provide Our Service

We may use your Personal Information to:

B. We Use Your Information for Administrative Purposes

We may use your Personal Information to:

C. We Use Your Information to Market and Advertise Our Service and Products

We may use your Personal Information to:

3. How We May Share or Disclose Your Information

We may share or disclose aggregated or anonymized information about our users to third parties for a variety of business purposes without any restrictions, including to provide our Service and/or to protect us or others. We may also share or disclose information in the event of a major business transaction such as a merger, sale, or asset transfer. The following circumstances describe in additional detail the ways we may share or disclose your Personal Information that we collect or that you provide under this Privacy Policy:

A. We Disclose Your Information to Provide Our Service
B. We May Disclose Your Information in the Event of a Merger, Sale or Other Asset Transfer

If we become involved in a merger, acquisition, financing due diligence, divestiture, restructuring, reorganization, bankruptcy, dissolution, sale, or transfer of some or all of our assets (whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding), or transition of the Service to another provider, your Personal Information may be sold or transferred to business entities or people involved in such process. Legal basis: Art. 6(1)f GDPR (legitimate interest).

C. We Disclose Your Information to Protect Us or Others

The Service do not share your Personal Information with any other users of the Service.

4. Your Privacy Choices and Rights

You have certain choices and rights with respect to your privacy. For example, you may be able to opt out of receiving marketing messages from us, make choices regarding cookies, and exercise other privacy rights under applicable law.

A. Mechanisms to Control Your Information

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

B. Accessing and Correcting Your Information

In accordance with applicable law, you may have the right to:

If you would like to exercise any of these rights, you may send us an email to request access to, correction of or removal of any Personal Information that you have provided to us. We will process such requests in accordance with applicable law.

The following are additional Consumer Privacy Rights:

C. State Your Specific Privacy Rights

A number of states require us to provide residents of those states with additional information and rights. Please see below for a list of those states and the state-specific disclosures.

D. Your Rights to Appeal

If you are dissatisfied with the refusal of Company to take action in accordance with the exercise of your rights in the "Accessing and Correcting Your Information" section above, you may request reconsideration by Company, by sending a written request for reconsideration to the mailing address found in the "Contact Information" section below. Within sixty (60) days (or such shorter period of time as required by applicable law) of Company’s receipt of such written request for reconsideration, Company shall inform you in writing (at the address indicated in your initial written request) of any action taken or not taken in response to your request for reconsideration, including a written explanation of the reasons for the decision. In addition, if your request for reconsideration is denied, you have the right to appeal to the applicable supervisory authority in your jurisdiction of residence (see subsection (E) below and the state-specific privacy notices for more information).

E. Complaints to Data Protection Authority

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

5. How We Protect Your Information

We have implemented safeguards reasonably designed to secure your Personal Information. Such safeguards include the implementation of various technical, physical, administrative and organizational security measures intended to reduce the risk of loss, misuse, unauthorized access, disclosure, or modification of your information. All information you provide to us is hosted and stored on Amazon Web Services (AWS).

The safety and security of your information is also dependent on you. If we have given you (or where you have chosen) a password for access to certain parts of the Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

While we have employed security technologies and procedures to assist safeguarding your Personal Information, no system or network can be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Service.

6. International Transfer of Personal Information

If you provide Personal Information through the Service, you acknowledge and agree that such Personal Information may be transferred from your current location to the offices and servers of Company and the other third parties referenced in this Privacy Policy (e.g., AWS) located in the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of such laws, where applicable.

7. Personal Information Retention Period

We keep your information for the length of time needed to carry out the purpose outlined in this Privacy Policy and to adhere to our policies on keeping records (unless a longer period is needed by law). Our records policies reflect applicable laws. We will retain and use your information to the extent necessary to manage your relationship with us, personalize and improve your overall customer experience, and to comply with our legal obligations. Where we retain data, we do so in accordance with our record retention policies and any limitation periods and records retention obligations that are imposed by applicable law.

8. Cookies and Other Technologies
A. Description of the Technologies

We as well as third parties that provide the content, advertising, or other functionality on the Service may use Technologies to automatically collect information through your use of the Service. The following describes some of these Technologies we may use for this automatic data collection:

B. Our Use of the Technologies

We may also use these technologies for security purposes, to facilitate navigation, to display information more effectively, and to better serve you with more tailored information, as well as for website administration purposes, e.g., to gather statistical information about the usage of our websites in order to continually improve the design and functionality, to understand how users use our websites, and to assist us with resolving questions regarding use of the websites.

C. Mechanisms to Control Cookies and Other Technologies

You may be able to set your browser to reject cookies and certain other technologies by adjusting the appropriate settings in your browser. Each browser is different, but many common browsers have preferences that may be adjusted to allow you to either accept or reject cookies and certain other technologies before they are set or installed, or allow you to remove or reject the use or installation of certain technologies altogether. We recommend that you refer to the “Help” menu in your browser to learn how to modify your browser settings. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of the Service may become inaccessible or may not function properly.

D. Third Party Technologies

This Privacy Policy covers the use of cookies by Company and does not cover the use of tracking technologies by any third parties. The Service may contain links, content, advertising, or references to other websites or applications run by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you interact with their content on the Service, such as customer recruitment vendors using Web beacons and cookies on our registration pages, to payment processors using technologies for payment verification. The information they collect may be associated with your Personal Information or they may collect information about your online activities over time and across different websites. Please be aware that we do not control these third parties' tracking technologies or when and how they may be used. Therefore, Company does not claim nor accept responsibility for any privacy policies, practices, or procedures of any such third party. We encourage you to read the privacy statements and terms and conditions of linked or referenced websites you enter. We do not endorse, screen, or approve, and are not responsible for the practices of such third parties or the content of their application or website. Providing Personal Information to third-party websites or applications is at your own risk. If you have any questions about an ad or other targeted content, you should contact the responsible provider directly.

E. Google and Other Analytical Providers

The Service may use Google Analytics (including Firebase, an analytics service provider by Google), which use cookies and similar technologies to collect and analyze information about use of the Service and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going here, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available here. Additionally, we may use the following additional service providers to monitor and analyze the use of the Service: (i) Sentry, real-time error tracking (see their Privacy Policy here: https://sentry.io/privacy/); (ii) Amplitude, product-analytics platform (see their Privacy Policy here: https://amplitude.com/privacy); (iii) Intercom, a conversational relationship platform (see their Privacy Policy here; and/or (iv) Customer.io, marketing platform for sending targeted and automated emails, push notifications and SMS messages (see their Privacy Policy here: https://customer.io/legal/privacy-policy).

9. Children Using or Accessing the Service

We are especially committed to protecting the privacy of children. Company’s Service are directed at a general audience over the age of eighteen (18) and are not intentionally targeted to children, and Company does not knowingly collect personal information directly from children under the age of thirteen (13) (“Child”). If we learn that we have inadvertently collected or received Personal Information from a Child, we will use reasonable efforts to immediately remove such information, unless we have a legal obligation to keep it. If you are a parent or legal guardian and think your Child has given us information without your consent, please contact us via the information found in the "Contact Information" section below.

10. Changes to Our Privacy Policy

We reserve the right to update this Privacy Policy from time to time in order to reflect, changes to our practices or for other operational, legal, or regulatory reasons. When we do update this Privacy Policy, we will post the updates and changes on our website. We may elect to notify you of material changes by mail, email, posting of modified Privacy Policy, or some other similar manner. However, it is your responsibility to check our website regularly for changes to this Privacy Policy. Your continued use of or access to the Service following the posting of any changes to this Privacy Policy constitutes acceptance of those changes.

11. Third Party Websites and Applications

Our Service may offer links to websites or applications that are not run by us but by third parties. These third-party services, websites or applications are not controlled by us, and may have privacy policies that differ from our own. We encourage our users to read the privacy policies and terms and conditions of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the practices of such third parties or the content of their application or website. Providing Personal Information to third-party websites or applications is at your own risk.

12. Contact Information

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by email at: hello@networktree.app.

California Privacy Notice

California law requires us to disclose certain information related to our privacy practices. This California Privacy Notice (the “CA Notice”) supplements the information contained in the Network Tree, Co. Privacy Policy (the “Privacy Policy”) and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA), and California Privacy Rights Act of 2020 (CPRA) (together, the “CCPA”) and any terms defined under the CCPA have the same meaning when used in this CA Notice. Capitalized terms used but not defined herein shall have the respective meanings set forth in the Privacy Policy. As used in this CA Notice only, “personal information” has the meaning set forth in the CCPA.

To understand our privacy practices, you should refer to our Privacy Policy in addition to this supplement applicable to California residents.

1. Categories of Personal Information Collected and Disclosed

The CCPA provides California residents with the right to know what categories of personal information covered businesses have collected about them and whether such businesses have disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve (12) months. This information can be found in the table below:

 Category of Personal Information CollectedCategory of Third Parties Personal Information is Disclosed to for a Business Purpose
1 - Identifiers. A real name, postal address, Internet Protocol address, email address, or other similar identifiers.Service providers, Marketing and advertising partners
2 - Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, address, telephone number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.Service providers, Marketing and advertising partners
3 - Internet or other electronic network activity. Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.Service providers, Marketing and advertising partners
4 - Professional or employment-related information. Collect the employment information of employees of Company and job applicants, including contents of job applications, employee personnel records, and employee communications.Service providers, Marketing and advertising partners
5 - Business-to-Business related information. Personal Information of an individual acting in a business capacity for our customers, to provide our Service to such customer.Service providers, Marketing and advertising partners
6 - Geolocation data. As described above, we may collect your IP address automatically when you use our Service. We may be able to determine your general location based on your device’s IP address.Service providers, Marketing and advertising partners
2. "Sales" or "Sharing" of Personal Information Under the CCPA

California residents have the right to opt out of the “sale” or “sharing” of their personal information to third parties. The CCPA defines “sale” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer’s personal information to a third party for monetary or other valuable consideration (which may be considered “sales” under the CCPA even if no money is exchanged). The CCPA defines “sharing” to mean sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer’s personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration. We have not "sold" or “shared” any personal information with third parties in the preceding twelve (12) months.

3. Other California Consumer Privacy Rights

California residents have additional rights regarding their personal information. This section describes those additional rights and explains how to exercise those rights.

Multi State Privacy Notice

To understand our privacy practices, you should refer to our Privacy Policy in addition to this supplement.

1. Sharing/Disclosing Personal Data

The VCDPA, CPA, CTPDA, UCPA, TDPSA, OCPA and MTCDPA requires covered businesses to provide residents of their respective states with the right to know the categories of “personal data” (as defined under applicable law) covered businesses shared with /disclosed to third parties and the categories of third parties with whom such personal data has been shared / disclosed. Residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana can find this information below:

Residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana may have additional rights under relevant privacy laws, including under the Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act (“CPA”), Connecticut Data Privacy Act (“CTDPA”), Utah Consumer Privacy Act (“UCPA”) Texas Data Privacy and Security Act (“TDPSA”), Oregon Consumer Privacy Act (“OCPA”) and Montana Consumer Data Privacy Act ("MTCDPA"), as applicable. The following additional information is required to be provided by covered businesses under applicable state laws. This Multi-State Privacy Notice (the “Multi-State Notice”) supplements the information contained in the Network Tree, Co. Privacy Policy (the “Privacy Policy”) and applies solely to all visitors, users, and others who reside in the States of Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana ("consumers" or "you"). We adopt this notice to comply with relevant privacy law. Capitalized terms used but not defined herein shall have the respective meanings set forth in the Privacy Policy.

Category of Personal Data SharedCategory of Third Parties Personal Data is Shared With / Disclosed to
1. A real name, Internet Protocol address, email address, or other similar identifiers.Service provides, Adverting/Marketing partners
2. Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.Service provides, Adverting/Marketing partners
3. As described above, we may collect your IP address automatically when you use our Service. We may be able to determine your general location based on your device’s IP address.Service provides, Adverting/Marketing partners
2. "Sales" or Processing for Targeted Advertising

Residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana have the right to opt-out of the “sale” of their personal data to third parties or the processing of their personal data for targeted advertising (see the  section above). For purposes of this paragraph the definition of “targeted advertising”, “sale”, “sell” or “sold” has the meaning set forth in applicable privacy law. However, please note, in accordance with applicable privacy law certain specific exceptions to “sale” and/or “targeted advertising” may apply, including the disclosure of personal data to a processor that processes personal data on behalf of a controller. If a consumer wishes to exercise their right to opt-out of the sale of personal data or processing of personal data for targeted advertising, they may do so by following this link. [Note to draft: Insert link.] We have not “sold” or processed for targeted advertising personal data in the preceding twelve (12) months.

3. State-Specific Rights to Opt-Out
4. Connecticut Right to Appeal a Denied Appeal

If you are a resident of the State of Connecticut and your request for reconsideration of Notable’s refusal to take action in accordance with the exercise of your rights in the "Accessing and Correcting Your Personal Information" section of the Privacy Policy is denied, you have the right to file a complaint with the Connecticut Office of the Attorney General by visiting the “File a Compliant” page here or contacting the Consumer Assistance Unit at 860-808-5420.

Nevada Privacy Notice

Nevada law requires us to provide all visitors, users, and others who reside in the State of Nevada ("you") certain additional privacy rights. This Nevada Privacy Notice (the “NV Notice”) supplements the information contained in the Network Tree, Co. Privacy Policy (the “Privacy Policy”) and applies solely to you. If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to sell or license that Personal Information, even if your Personal Information is not currently being sold. If you would like to exercise this right, please contact us via the information found in the "Contact Information" section of the Privacy Policy.