‍Personal information we collect

Information you provide to us.

·  Personal contact information, such as your first and last name, email and mailing addresses, company, title, company type, username, and phone number.

·  Transaction information, such as your billing address, purchase details, and payment information. We will not store your payment card details, as this information is provided directly to our third-party payment processor, Stripe. Please see below for additional details.

·  Registration information, such as information that may be related to a service or an account you register for.

·  Feedback or correspondence, such as how you heard about us, your primary PLC brand, and information you provide when you contact us with questions, feedback, product reviews, input a prompt in the CoPilot chat, or otherwise correspond with us.

·  Usage information, such as information about how you use the Services or engage in Networking Activities and interact with us, including information associated with any content you upload to the Websites or otherwise submit to us, and information you provide when you use any interactive features of the Services or engage in Networking Activities.

·  Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.

·  Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from third parties. We may maintain pages on social media platforms, such as Facebook, LinkedIn, Instagram, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources, and data providers.

Cookies and other information collected by automated means. We, our service providers, and our business partners may use cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies to automatically collect information about your interaction with our Services through your computer or mobile device, including:

·  Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, device identifier, browser type, screen resolution, IP address, and general location information such as city, state, or geographic area;

·  Online activity data, such as the website you visited before browsing to our website, and information about your use of and actions on our websites, including pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and 

·  Communications response data, such as whether you open emails we send you, and the links and other actions you take in response to the emails.

In addition to cookies that we may place on your computer or mobile device, cookies might also be placed on your computer or mobile device by third parties that we use to display or serve advertisements or to collect information in order to provide advertising-related services. In the course of serving advertisements, such third-party advertisers could place or recognize unique cookies on your browser. We may also combine information collected from cookies with information that you may provide, such as information provided in a form that you complete.

For the avoidance of doubt, the Services may use third-party service platforms (including to help analyze how users use the Services). These third-party service platforms may place cookies on your computer or mobile device. If you would like to disable “third party” cookies, you may be able to turn them off by going to the third party’s website.

Here are links to the main third-party platforms we use:

·  https://www.google.com/policies/privacy/

·  https://www.zoominfo.com/legal/privacy-policy#V.-Cookies-and-Similar-Technologies

·  https://www.linkedin.com/legal/cookie-policy

·  https://legal.hubspot.com/cookie-policy

·  https://embed.ly/legal/privacy

Finally, you should be aware that advertisers and other third parties may use their own cookies or action tags when you click on their advertisement or a link to their sites or services on or from the Services. This Privacy Policy does not govern the use of cookies or action tags or the use of your personal information by such third-party websites or services or providers of third-party advertising.

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How we use your personal information

Legal Bases. Pursuant to the European Data Protection Laws, legal bases for our processing your information may include (without limitation):

·  Where you have given consent to the processing, which consent may be withdrawn at any time without affecting the lawfulness of processing based on consent prior to withdrawal;

·  Where it is necessary to perform the contract we have entered into or are about to enter into with you (whether in relation to the provision of the Services, our Networking Activities, or otherwise);

·  Where it is necessary for us to comply with a legal obligation to which we are subject; and/or

·  Where it is necessary for the purposes of our legitimate interests (or those of a third party) in providing, improving, or marketing the Services or Networking Activities and your interests or fundamental rights and freedoms do not override those legitimate interests.

To operate our Services and engage in Networking Activities:

• Provide, operate, maintain, secure, and improve our Services and Networking Activities
• Fulfill a payment or return transaction initiated by you
• Provide information about our Services and Networking Activities
• Communicate with you about our Services and Networking Activities, including by sending you announcements, updates, security alerts, and support and administrative messages
• Understand your needs and interests, and personalize your experience with our Services, our Networking Activities and our communications
• Respond to your requests, questions, and feedback
• To send announcements and updates regarding the Services and Networking Activities, or, if applicable, about your billing account status. You will not be able to unsubscribe from these announcements and updates as they contain important information relevant to your use of the Services or engagement in Networking Activities and are necessary for the performance of our contract with you.

For research and development. To analyze and improve the Services and Networking Activities and to develop new products and services, including by studying use of our Services or engagement in Networking Activities.

Marketing. We, our service providers, and our third-party advertising partners may collect and use your personal information for marketing purposes:

• Direct marketing. Unless you opt out (to the extent permitted by applicable law), we may send you Copia-related direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
• Online Advertising. Note that information collected from cookies and other similar technologies (which may include device identifiers) may be used to send you online advertising for the Services or Networking Activities. In particular, information collected from cookies (including cookies placed by third-party vendors, such as Google and its partners) and other similar technologies (which may include device identifiers) may be used to deliver advertisements to users of our Services or individuals who may be interested in Networking Activities when such users are using other websites, including Facebook, LinkedIn, and YouTube. These third-party vendors may use cookies and/or device identifiers to serve ads based on your past usage to our Services or engagement in Networking Activities. You may opt out of a third-party vendor’s use of cookies and/or device identifiers for personalized advertising by visiting https://thenai.org/opt-out/.

To comply with law. As we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process (including to meet national security or law enforcement requirements), such as to respond to subpoenas or requests from government authorities.

With your consent. In some cases, we may specifically ask for your consent to collect, use, or share your personal information, such as when required by law.

For compliance, fraud prevention, and safety. To: (a) protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern our Website, Services, or Networking Activities; and (c) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. 

For analytics and to create anonymous data. We may also use personal information gathered to perform statistical analysis of user behavior or to evaluate and improve the Services and Networking Activities. We may link some of this information to other information for internal purposes or to improve your experience with the Services or Networking Activities. Furthermore, we may create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by removing information so that it can no longer be associated with you, and in which case we may use and/or disclose such anonymous information for our lawful business purposes. We use reasonable safeguards designed to minimize the risks associated with the process of anonymizing your information.

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‍How we share your personal information

Outside Contractors. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate our Services and Networking Activities (collectively, “Outside Contractors”) in connection with customer support, hosting, analytics, email delivery, marketing, and database management services. In the course of providing products or services to us, these Outside Contractors may have access to information collected through the Service, including your information. We use reasonable efforts to ensure that these Outside Contractors are capable of protecting the security of your information.

Please note in particular that the Services use Google Analytics, including its data reporting features. Information collected by Google Analytics includes but is not limited to web metrics. For information on how Google Analytics collects and processes data, please see the site “How Google uses data when you use our partners’ sites or apps”, currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google’s website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.

Advertising partners. We may provide personal information to third parties, including where such personal information is combined with similar information of other users of the Services or individuals who engage in Networking Activities. For example, we might inform third parties regarding the number of unique users who use the Services or engage in Networking Activities, the demographic breakdown of our users of the Services or individuals who engage in Networking Activities, or the products and/or services purchased using the Services and the vendors of such products and services. In addition to the above, when users use our Services, third parties (including without limitation third-party advertisers and commercial partners) may directly collect information about our users’ online activities over time and across different websites. The third parties to which we may provide or who may independently directly collect information may include potential or actual advertisers, providers of advertising products or services (including vendors, analytics services providers, and website tracking services), affiliates and other actual or potential commercial partners, and other similar parties. In addition, we may share your personal information with third party advertising companies for the interest-based advertising purposes described above.

For compliance, fraud prevention and safety. We may disclose your personal information if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process. We may disclose personal information in special circumstances when we have reason to believe that disclosing this personal information is necessary to identify, contact or bring legal action against someone who may be violating a contract with us, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our users, the Services, Networking Activities, or the general public.

Business transfers. We may sell, transfer, or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Affiliates. We may disclose your personal information to our Corporate Affiliates.

‍Your choices 

In this section, we describe the rights and choices that may be available to you. 

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Access or update your information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at contact@copia.io. You may continue to receive Services-related and other non-marketing emails.

Cookies & browser web storage. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Services may not work properly. Similarly, your browser settings may allow you to clear your browser web storage. 

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Rights Under the European Data Protection Laws. Under certain circumstances and in compliance with the European Data Protection Laws, you may have the right to:

·  Request access to your personal information (commonly known as a ‘subject access request’). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;

·  Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate personal information we hold about you corrected;

·  Request erasure of your personal information. This enables you to ask us to delete or remove your personal information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove all of your personal information in certain circumstances;

·  Object to processing of your personal information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground;

·  Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information, for example, if you want us to establish its accuracy or the reason for processing it;

·  Request the transfer of your personal information to another party; and

·  Lodge a complaint with the relevant supervisory authority (as defined in the European Data Protection Laws). If you have any complaints about the way we process your personal information, please do contact us. Alternatively, you may lodge a complaint with the supervisory authority which is established in your country.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact contact@copia.io.

Such updates, corrections, changes, and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

You should be aware that it may not be technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your personal information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, your personal information stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.

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Payment Processing

In addition, we would like you to be aware that we use an Outside Contractor for payment, analytics, and other business services. This Outside Contractor may collect personal information including via cookies and similar technologies, including when you make a payment through the Services or otherwise interact with our Outside Contractor that handles billing and payment card processing. The personal information such Outside Contractor collects may include transactional data and identifying information about devices that connect to its services. Our Outside Contractor uses this information to operate and improve the services it provides to us, including for fraud detection, loss prevention, authentication, and analytics related to the performance of its services. You can learn more about that Outside Contractor and read its privacy policy at https://stripe.com/privacy.

Other sites 

Our Website may contain links to other sites operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages that are not associated with us. We do not control third party sites and we are not responsible for their actions. Other sites may follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other sites you use.

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Security practices

We use reasonable organizational, technical, and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration, and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information. In the event that we are required to notify you about a situation involving your personal information, we may do so by email or telephone to the extent permitted by law.\

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Retention

We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it or as otherwise permitted by applicable law.

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To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of that personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

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International transfers

Information collected on the Services or via our Networking Activities may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and the Services and Networking Activities may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such information. To the extent required by applicable law: whenever we transfer your personal information to third parties (as described in this Privacy Policy) located in an Inadequate Jurisdiction, we ensure a similar degree of protection is afforded to it; we may use specific contracts approved by the European Commission (accessible at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj) or the UK Information Commissioner’s Office (accessible at https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/international-data-transfer-agreement-and-guidance/), as applicable, which give personal information the same protection it has in the European Economic Area or the United Kingdom, as applicable, under the European Data Protection Laws; and if we rely on another basis to transfer your personal information to an Inadequate Jurisdiction, we will keep you updated or contact you if required. Please contact us if you want further information on the specific mechanisms used by us when transferring your personal information to an Inadequate Jurisdiction.

Children  

Our Website, Services, and Networking Activities are not intended for children, and we do not collect personal information from them. We define “children” as follows:

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Residents outside of Europe: anyone under 13 years old; and

Residents of Europe: anyone under 16 years old, or the age needed to consent to the processing of personal information in your country of residence.

If we learn we have collected or received personal information from a child without verification of parental consent, we will delete the information. If you believe we might have any information from or about a child, please contact us at contact@copia.io.

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Changes to this Privacy Policy

We may revise this Privacy Policy from time to time. We will not make changes that result in significant additional uses or disclosures of your personal information without allowing you to “opt in” to such changes. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your personal information, for which your opt-in is not required. We encourage you to check this page periodically for any changes. If any non-significant changes to this Privacy Policy are unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using the Services or engaging in our Networking Activities.

How to contact us

Please direct any questions or comments about this Privacy Policy or our privacy practices to contact@copia.io.