Last Modified: April 2022

IMPORTANT POINTS.

1. OVERVIEW

Canna Pharma Suisse and its subsidiaries (collectively, “Fleerter,” “we,” “us,” “our”) respect your privacy and are committed to protecting the personal data we hold about you. If you have questions, comments, or concerns about this Privacy Notice or our processing of personal data, please see the bottom of this Privacy Notice for information about how to contact us. Fleerter is the data controller of the personal data collected, and is responsible for the processing of your personal data.

Fleerter is a social network which enables users to share their content; other users to enjoy content and for some to do both. We refer to those users who share content as “Creators” and those users who pay to view Creators’ content as “Fans”. This Privacy Notice explains our practices with respect to personal data we collect and process about you. This includes information we collect through, or in association with, our website located at fleerter.com, our services that we may offer from time to time via our website, our related social media sites (Twitter and Instagram), or otherwise through your interactions with us (the website, our social media pages, and services, collectively, the “Services”).

Please review the following to understand how we process and safeguard personal data about you. By using any of our Services, whether by visiting our website or otherwise, and/or by voluntarily providing personal data to us, you acknowledge that you have read and understand the practices contained in this Privacy Notice. This Privacy Notice may be revised from time to time, so please ensure that you check this Privacy Notice periodically to remain fully informed.

PERSONAL DATA WE COLLECT

• Categories of Personal Data We Collect
• How We Use Your Personal Data
• How We Obtain Your Personal Data
• Legal Bases for Processing
• Who We Share Your Personal Data With
• Personal Data We Share

YOUR RIGHTS REGARDING PERSONAL DATA

• Accessing, Modifying, Rectifying, and Correcting Collected Personal Data
• Your California Privacy Rights
• Your Nevada Rights
• Your European Union and UK Privacy Rights

YOUR CHOICES

• Communications Opt-Out
• Location Information
• Cookies and Web Tracking

PROTECTING PERSONAL DATA

RETENTION OF PERSONAL DATA

OTHER IMPORTANT INFORMATION ABOUT PERSONAL DATA AND THE SERVICES

• Identity Verification
• Payment Information
• Collection of Personal Data from Children
• Third-Party Websites and Services
• Business Transfer
• Do Not Track
• International Use

MODIFICATIONS AND UPDATES TO THIS PRIVACY NOTICE

APPLICABILITY OF THIS PRIVACY NOTICE

ADDITIONAL INFORMATION AND ASSISTANCE

2. PERSONAL DATA WE COLLECT

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal data”). In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not personal data. To the extent this data is stored or associated with personal data, it will be treated as personal data; otherwise, the data is not subject to this Privacy Notice.

a. Categories of Personal Data We Collect

1. The types of personal data we collect about you depends on your interactions with us and your use of the Services. In the past twelve (12) months, we collected the below categories of personal data from our users:
2. Identifiers such as a real name, alias, postal address, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
3. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)).
4. Characteristics of protected classifications under California or federal law.
5. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
6. Biometric information. Note: While we do not collect biometric information, if you choose to authenticate yourself through certain service providers we use, they may collect biometric information subject to their privacy policies, but we are never provided with access to that information.
7. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
8. Audio, electronic, visual, thermal, olfactory, or similar information.
9. Professional or employment-related information.

We will not collect additional categories of personal data other than those categories listed above. If we intend to collect additional categories of personal data, we will provide you with a new notice at or before the time of collection.

b. How We Use Your Personal Data

We strive to ensure that the content can be enjoyed by everyone, and to keep the content appropriate, tasteful and lawful. To do that, we collect and process your personal data for the following business and commercial purposes:

1. Developing, improving, operating, providing, predicting, or performing, including maintaining or servicing accounts, enhancing the Services and your experience with them, providing customer service, processing or fulfilling transactions, verifying your identity, and processing payments.
2. Communicating with you by email and text about the Services, verifying your identity, responding to support inquiries or, sharing information about the Services.
3. Auditing related to a current interaction with the user and concurrent transactions.
4. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
5. Debugging to identify and repair errors that impair existing intended functionality.
6. Undertaking internal research for technological development and demonstration.
7. Undertaking activities to verify or maintain the quality or safety of the Services owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the Services owned, manufactured, manufactured for, or controlled by us.
8. Complying with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, or for other purposes, as permitted or required by law.
9. Enforcing our Terms of Service and other usage policies.
10. As necessary or appropriate to protect the rights, property, and safety of our users, us, and other third parties.

We will not use the personal data we collected for materially different, unrelated, or incompatible purposes without providing you with notice and obtaining your consent.

c. How We Obtain Your Personal Data

We collect your personal data from the following categories of sources:

• Directly from you. When you provide it to us directly to open an account and use the Services, or when you update the information in your account (see the “Accessing, Modifying, Rectifying, and Correcting Collected Personal Data” section below for more information).
• Automatically or indirectly from you. For example, through and as a result of your use of and access to the Services. We also collect IP addresses and browser types from the devices you use.
• From our service providers.

d. Legal Bases for Processing

We process personal data for, or based on, one or more of the following legal bases:

• Performance of a Contract. By using the Services, you have contracted with us through the Terms of Service, and we will process certain personal data to perform under that contract.
• Legitimate Interests. We may process personal data for our legitimate interests, including complying with any applicable law, rule or regulation, investigation or remedy; enforcing our Terms of Service; protecting our, our users' or others' rights, property and safety; and detecting and resolving any fraud or security concerns.
• Compliance with Legal Obligations and Protection of Individuals. We may process personal data to comply with our legal obligations, including as required by valid legal process, governmental request, and to protect those individuals who use our Services and others.

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing messages sent to you, or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, product or service experience, or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

THIRD-PARTY USE OF PERSONAL INFORMATION

Company may share your Personal Data with certain third parties as set forth below:

Third Party Vendors: We may share your information with third party vendors or service providers who help us provide our products or services or the Website, including database hosting and data processing services, and assist us in responding to requests by you for information that you request.

Parent Companies and Affiliates: We may share your information with a parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, "Affiliates"), provided that we require our Affiliates to honor this Privacy Policy.

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. We may also share Personal Data with potential buyers. Usually, information will be anonymized, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Related Companies: We may also share your Personal Data with our related companies for purposes consistent with this Privacy Policy.

Third Parties with Permission: We may share your information with third parties to whom you ask us to send your information.

Agents, Consultants, and Related Third Parties: Company, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Legal Requirements: Company may disclose yourPersonal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity or in connection with our own investigation of suspected or actual illegal activity, in which case we may (and you hereby authorize us to) disclose information without subpoenas or warrants served on us, (ii) protect and defend the rights or property of Company, (iii) act in urgent circumstances to protect the personal safety of users of the Website or the public, (iv) protect against legal liability including to resolve disputes, investigate problems, or enforce our customer contracts.

The Website may share your information with third parties when you explicitly authorize us to share your information. Additionally, the Website may use third-party service providers to service various aspects of the Website. Each third-party service provider's use of your personal information is dictated by their respective privacy policies. The Website currently uses the following third-party service providers:

• Google Analytics – this service tracks Website usage and provides information such as referring websites and user actions on the Website. Google Analytics may capture your IP address, but no other personal information is captured by Google Analytics.
• AWS Services – this service is used for delivery of email updates and newsletters. We store your name and email address for purposes of delivering such communications.
• CCBill – this service is used to serve our ecommerce platform. At no time is your banking information passed to the Website. We receive only information used for order fulfillment.
• MongoDB –this service is used to store all Content.

At this time, your personal information is not shared with any other third-party service providers. This list may be amended from time to time in the Website's sole discretion.

Except when required by law, Company will not sell, distribute, or reveal your email addresses or other personal information without your consent; however, Company may disclose or transfer personal information collected through the Website to third parties who acquire all or a portion of our business, which may be the result of a merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.

International transfers

We are based in the United States of America. We may process, store, and transfer the personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own. Where we do so, and where we are required to under local law, we will put in place appropriate mechanisms to ensure that your personal data receives an adequate level of protection where it is processed

If you are located in the European Economic Area (EEA) or United Kingdom (UK), your personal data may be processed outside of the EEA or UK, including, for example, in the United States, so processing of your personal data will involve a transfer of data outside the EEA or UK.

Whenever we transfer your personal data out of the EEA or UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU–US Privacy Shield

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or UK.

COOKIES

The Website uses cookies to store visitors' preferences,record user-specific information on what pages users access or visit,ensure that visitors are not repeatedly sent the same banner ads,customize content based on visitors' browser type or otherinformation that the visitor sends. Cookies may also be used by third-party services, such as Google Analytics, as described herein.

What are cookies?

A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a "device") by the web server so that a website can remember some information about your browsing activity on the Website.The cookie will collect information relating to your use of the Website, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at the Website via a link from third party site, the URL of the linking page.

In addition to cookies, the Website may use web beacons.Web beacons allow us to count the number of users who have visited or accessedthe Websiteand to recognize users by accessing our cookies. We may employ web beacons to facilitateWebsiteadministration and navigation, to track the actions of users ofthe Website, to compile aggregate statistics about Website usage and response rates, and to provide an enhanced online experience for visitors tothe Website. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened.A web beacon is often invisible because it is only 1 x 1 pixel in size with no color.A web beacon can also be known as a web bug, 1 by 1 GIF, invisible GIF, and tracker GIF.

What are the different types of cookies and how do we use them?

Essential - These are cookies which are essential for the running of the Website. Without these cookies, parts of the Website would not function.These cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes.

Examples of how we may use essential cookies include:

Setting unique identifiers for each unique visitor, so that Website numbers can be analyzed.

 

Functional – These cookies are used to remember your preferences on the Website and to provide enhanced, more personal features. The information collected by these cookies is usually anonymized, so we cannot identify you personally.Functional cookies do not track your internet usage or gather information which could be used for selling advertising.

 

Examples of how we may use functional cookies include:

Gathering data about visits to the Website , including numbers of visitors and visits, length of time spent on the Website, pages clicked on or where visitors have come from;

Eliminating the need for returning users to re-enter their login details.

 

Analytical Performance - Analytical performance cookies are used to monitor the performance of the Website, for example, to determine the number of page views and the number of unique users our Website has. We use this information to improve user experience or identify areas of the Website which may require maintenance.The information is anonymous (i.e. it cannot be used to identify you and does not contain personal information such as your name and email address) and it is only used for statistical purposes.

 

Examples of how we may use analytical cookies include:

Measuring users’ behavior;

Analyzing which pages are viewed and how long for and which links are followed to better develop the Website.

 

Third Party cookies - You may notice on some pages of the Website that Cookies have been set that are not related to us. When you visit a page with content embedded from, for example, YouTube or Facebook, these third party service providers may set their own cookies on your device. We do not control the use of these third party cookies and cannot access them due to the way that cookies work, as cookies can only be accessed by the party who originally set them. Please check the third party websites for more information about these cookies.

 

Users may, at any time, prevent the setting of cookies, by the Website, by using a corresponding setting of your internet browser and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. However, if you deactivate the setting of cookies in your Internet browser, not all functions of our Website may be entirely usable.

 

How can you manage or opt-out of cookies?

 

Cookies, including those which have already been set, can be deleted from your hard drive. You can also change the preferences/settings in your web browser to control cookies. In some cases, you can choose to accept cookies from the primary site, but block them from third parties. In others, you can block cookies from specific advertisers, or clear out all cookies. Deleting or blocking cookies may reduce functionality of the Website. To learn more about how to reject cookies, visit www.allaboutcookies.org or go to the help menu within your internet browser. If you experience any problems having deleted cookies, you should contact the supplier of your web browser.

 

Opting out of Analytical Performance Cookies

If you would like to opt out of Analytics cookies, please do so by clicking on the links below:

Google Analytics: https://tools.google.com/dlpage/gaoptout.

If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

 

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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

By law we have to keep basic information about our members and models (including Contact, Identity, Financial, and Transaction Data) for seven years after they cease being members or models for tax purposes or to comply with 18 U.S.C. § 2257.

In some circumstances you can ask us to delete your data, which will depend on the jurisdiction where you are located. In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

RIGHTS RELATED TO YOUR PERSONAL INFORMATION

Under laws in certain countries in which we operate, customers and other visitors to our Website from those countries have a right to access Personal Data about themselves, and to amend, correct or delete Personal Data that is inaccurate, incomplete or outdated We will, upon request, provide you with confirmation regarding whether we are processing Personal Data about you, consistent with applicable law. In addition, upon your request, we will take reasonable steps to correct, amend, or delete your Personal Data that is found to be inaccurate, incomplete or processed in a manner non-compliant with this Privacy Policy or applicable law, except where the burden or expense of providing access would be disproportionate to the risks to your privacy, where the rights of persons other than you would be violated or where doing so is otherwise inconsistent with applicable law. Unless prohibited by applicable law, we reserve the right to charge a reasonable fee to cover costs for providing copies of Personal Data that you request.

Please note that while any amendments, corrections or deletions will be reflected in active user databases (as updated within a reasonable period of time), we may retain all Personal Data for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.

You authorize us to use and disclose any new or modified information that you provide in accordance with this Privacy Policy, and you agree that we are under no obligation to delete or modify information that you have previously chosen to provide us as to which you have not instructed us to take such action. Please remember, however, that if we have already disclosed some of your Personal Data to third parties, we cannot access that Personal Data any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.

We may retain your Personal Data to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our contracts, and take other actions otherwise permitted by law.

Opt-out

If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personal information, such as passwords, social security numbers, or bank account information, to us by email. You may "opt out" of receiving future commercial email communications from us by clicking the "unsubscribe" link included at the bottom of most emails we send, or as provided below; provided, however, we reserve the right to send you transactional emails such as customer service communications.You may also notify us at privacy@fleerter.com to be removed from our mailing list.

Access– You may request access to the personal information we have about you by submitting a request to privacy@fleerter.com.

Amend– You may contact us at privacy@fleerter.com to amend or update your personal information.

Forget – In certain situations, you may request that we erase or forget your Personal Data. To do so, please submit a request to privacy@fleerter.com. Please note that we may need to retain certain information for recordkeeping purposes or to complete transactions, or when required by law.

 

CALIFORNIA RESIDENTS

California Residents: Pursuant to the California Consumer Privacy Act of 2019 ("CCPA"), you have certain rights with respect to your personal information. For the purposes of this section, personal information is used as defined in the CCPA. Company reserves the right to verify all requests made pursuant to the CCPA.

 

Access and Disclosure

 

You may make a verifiable request that we disclose the categories of personal information we have collected about you, the categories of sources of the personal information we collected about you, the business or commercial purpose for collecting or selling the personal information, the categories of third parties with whom we share your personal information, our use of the personal information and if the personal information was disclosed or sold to third parties, including the categories of personal information sold or disclosed. You also have the right to make a verifiable request for a copy of the personal information collected about you for the twelve (12) months prior to the date of your request. We have not sold any categories of personal information in the last twelve (12) months. Please note that we are not required to:

• Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information.

Deletion Request Rights

You have the right to request that Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the personal information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. 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 the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

No Discrimination

We will not discriminate against you for exercising any of your CCPA 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.

Exercising Your Rights

To exercise the access, disclosure and deletion rights described above, please submit a verifiable request to us by emailingprivacy@fleerter.com, Attn: CCPA.

You may only make a verifiable request for access or disclosure twice within a twelve (12) month period. You may also make a verifiable consumer request on behalf of your minor child. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

To respond to your request or provide you with personal information, Company must verify your identity or your authority to make the request. We will only use personal information provided in a verifiable request to verify the requestor's identity or authority to make the request. For instructions on exercising sale opt-out rights, please refer to the Do Not Sell My Personal Information Page.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by e-mailing us at privacy@fleerter.com. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

Timing

We will respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

 

LEGAL BASES FOR PROCESSING DATA UNDER THE GENERAL DATA PROTECTION REGULATION ("GDPR")

We are responsible as a "controller" of your Personal Data under the GDPR and below are the types of lawful basis that we will rely on to collect and process your Personal Data:

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at privacy@fleerter.com.
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal or regulatory obligation means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.
• Consent means where you have consented to a certain use of your Personal Data.
• Vital Interest means processing your Personal Data to protect the vital interests of the data subject or another natural person.

How to File a GDPR Complaint

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

Your Canadian privacy rights

We comply with Canadian Federal and Provincial privacy laws and regulations, including the Personal Information Protection and Electronic Documents Act.

We will only use your personal information for the purposes intended and as detailed in this policy unless we have obtained your consent to use it for other purposes.

Residents of Canada are notified that the personal data they provide to Gatsby is stored in its databases outside of Canada, including in the United States, and may be subject to disclosure to authorized law enforcement or government agencies in response to lawful demand under the laws of that country.

You may withdraw your consent to our personal data collection, use, or disclosure, subject to legal and contractual restrictions

You have the right to complain about our personal data handling practices.

If you need to contact us about your personal data or believe that we have violated your privacy rights, please contact us at privacy@fleerter.com .You may visit www.priv.gc.ca for more information about your privacy rights.

Accessing and Correcting Your Personal Information

You can access, review, and change your personal data by logging in the website and visiting your account profile page.

You may also send us an email at privacy@fleerter.com to request access to, correct, or delete any personal data that you have provided to us. We cannot delete your personal data except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or negatively affect the information’s accuracy.

If you delete your User Contributions or Model Content from the website, copies of your User Contributions or Model Content may remain viewable in cached and archived pages or might have been copied or stored by other website users.

Do Not Track policy

Do Not Track (“DNT”) is a privacy preference that you can set in your browser. DNT is a way for you to inform websites and services that you do not want certain information about your webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information we collect and that is why we provide you the ability to opt out. But we do not recognize or respond to any DNT signals as the Internet industry works toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. For more information, visit www.allaboutdnt.com.

Alternative Dispute Resolution

Arbitration

As the exclusive means of initiating adversarial proceedings to resolve any dispute arising out of the Website, this agreement, or the subject matter of this agreement, a party may demand that any such dispute be resolved by arbitration administered by the Arbitration Resolution Services, Inc. (ARS) (or a similar online dispute resolution provider if ARS is not available) in accordance with its rules available at www.arbresolutions.com, and each party hereby consents to any such dispute being so resolved. The arbitrator, and not any federal, state, or local court or agency, will have exclusive authority to resolve all disputes arising out of or relating to the interpretation, enforceability, or formation of this agreement, including any claim that all or any part of this agreement is void or voidable. Each party will be responsible for paying any filing, administrative, and arbitrator fees associated with the arbitration. The arbitrator may grant whatever relief that would be available in a court at law or in equity, except that the arbitrator must not award punitive or exemplary damages, or damages otherwise limited or excluded in this agreement. The arbitrator’s award will include costs of arbitration, reasonable legal fees, and reasonable costs for expert and other witnesses. Judgment on any award rendered in any such arbitration may be entered in any court having jurisdiction. Unless required by law, neither a party nor an arbitrator will disclose the existence, content, or results of any arbitration under this agreement without the advance written consent of both parties.

Injunctive Relief

The parties acknowledge that breach by either party of the obligations under this agreement could cause irreparable harm for which damages would be an inadequate remedy. Nothing in this section will prevent either party from seeking injunctive or other equitable relief from the courts for matters related to data security, intellectual property, or unauthorized access to the Website, in each case without posting a bond or other security and without proof of actual money damages in connection with the claim.

Recovery of Expenses

In any proceedings between the parties arising out of or relating to the subject matter of this agreement, the prevailing party will be entitled to recover from the other party, besides any other relief awarded, all expenses that the prevailing party incurs in those proceedings, including legal fees and expenses. For purposes of this section, “prevailing party” means, for any proceeding, the party in whose favor an award is rendered, except that if in those proceedings the award finds in favor of one party on one or more claims or counterclaims and in favor of the other party on one or more other claims or counterclaims, neither party will be the prevailing party. If any proceedings are voluntarily dismissed or are dismissed as part of settlement of that dispute, neither party will be the prevailing party in those proceedings.

Jury Trial Waiver

Each party hereby waives its right to a trial by jury in any proceedings arising out of, or relating to the subject matter of, this agreement. Either party may enforce this waiver up to and including the first day of trial.

Class Action Waiver

All claims must be brought in the parties’ individual capacity, and not as a plaintiff or class member in any purported class or representative proceeding, and, unless the Company agrees otherwise, the arbitrator will not consolidate more than one person’s claims. Both parties acknowledge that each party is waiving the right to participate in a class action.

Limitation on Time to Bring Claims

A party will not bring a claim arising out of or relating to the Website or this agreement more than one year after the cause of action arose. Any claim brought after one year is barred.

LINKS TO OTHER WEBSITES This Privacy Policy applies only to the Website. The Website may contain links to other websites not operated or controlled by Company (the "Third-Party Sites"). The policies and procedures described here do not apply to the Third-Party Sites. The links from the Website do not imply that Company endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

OTHER TERMS AND CONDITIONS Your access to and use of the Website may also be subject to any separate agreements or terms and conditions you have signed or agreed to with Company. Please refer to those agreements as needed.

Regardless of any other provision in this Privacy Policy, we reserve the right to disclose any personally identifiable or non-personally identifiable information about you to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Website, or other users; or (d) protect, in an emergency, the health and safety of our customers or the general public. This includes exchanging information with third parties and organizations in connection with credit risk reduction and fraud protection.

The Website may change from time to time. As a result, at times it may be necessary for Company to make changes to this Privacy Policy. Company reserves the right to update or modify this Privacy Policy at any time. Please review this policy periodically, and especially before you provide any Personal Data. Your continued use of the Website after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

CONTACT INFORMATION

At any time, please contact us at privacy@fleerter.com for questions related to this Privacy Policy.