Privacy Policy

Able Digital NA LLC ("we" or "us") provide this policy to inform you of our personal information handling practices for personal information we collect from those who contact us by phone or email and visitors to our website http://able.digital, and our web and mobile sites operated by us that link to this policy ("site" or "sites").

This policy (together with our Terms of Use, Cookie Policy and any other documents referred to in it) sets out the basis on which any personal data, personally identifiable information, or personal information (“personal data”) we collect from you, or that you provide to us, through our sites will be processed by us. This policy does not cover any personal data we collect offline or that we process as a service provider for clients.

Residents of the European Economic Area, the United Kingdom, or Switzerland, see our EEA+ Supplemental Data Protection Law Disclosures to this policy below.

California residents, see our California Consumer Privacy Act Privacy Policy below.

Residents of Brazil, see our Brazil Supplemental Data Protection Law Disclosures to this policy below.

Local laws may provide for various data subject rights that provide individuals with the right to request access to their personal data, correction of their personal data that is in the possession or under the control of Able.Digital, and withdrawal of consent to process their personal data. This list is not exhaustive and may vary by local law and jurisdiction.

When you contact us, or make an inquiry, via our site, your data will be collected and controlled by Able Digital NA LLC (a US corporation incorporated under the laws of the State of Delaware and based at 1000 North West Street Ste 1200, Wilmington, DE 19801) who will share that data with our relevant affiliate company to which your inquiry, or request, relates ("Relevant Able.Digital Company" you can find a list of all Relevant Able.Digital Companies at the end of this document). For example, if you inquire about engaging Able Digital UK Ltd (a UK incorporated company) then your personal data may be shared with Able Digital UK Ltd for these purposes. In such event both Able Digital NA LLC and the Relevant Able.Digital Company may be considered controllers of your data under applicable law (for example, the General Data Protection Regulation 2016/679 and its implementing national legislation and the UK GDPR (the "Privacy Legislation")). We and the Relevant Able.Digital Company may also share your personal data with our other parties from time to time for the purposes set out in this privacy policy.

For your information:

• inquiries relating to our European business are generally handled by Able Digital UK Ltd, a company incorporated and registered in England and Wales whose registered office is at 30 Moorgate, London, EC2R 6DA;

• inquiries relating to our Canadian business are generally handled by Able.Digital CA ULC, a Canadian unlimited liability company formed under the laws of New Brunswick whose registered office is at 85 Charlotte Street, Fredericton, New Brunswick E3B 1M7;

• inquiries relating to our U.S. business are generally handled by Able Digital NA LLC, a corporation incorporated under the laws of the State of Delaware and based at 1000 North West Street Ste 1200, Wilmington, DE 19801;

• inquiries relating to our Brazil business are generally handled by Able.Digital BR Ltda. a duly incorporated company under the laws Brazil and based at Rua das Olimpíadas, 205, 4 Andar, Vila Olímpia, São Paulo SP 04551-000, Brazil;

unless we notify you otherwise.

Information we collect about you

We will collect and process the following data about you:

• Information you give to us. This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you request information about our services, and when you report a problem with our site.

The information you give us may include your name, address, e-mail address and phone number, and other information that you choose to provide. Providing such personal data is voluntary. However, without providing such personal data, we will not be able to provide you with information or services you request from us. You will know what personal data you provide because you will actively submit it to us.

• Information we collect about you. In addition to the personal data that you actively provide, for us to monitor and maintain the performance of the sites and to analyze trends, usage and activities in connection with the sites, to measure the effectiveness of advertising we serve to you, and to deliver relevant advertising to you, the sites may automatically collect, process and store certain information from you, to the extent permitted and under the conditions set out under applicable law:

• technical information, including the domain and host name from which you access the Internet, the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone and country setting, browser plug-in types and versions, operating system and platform; and

• information about your site visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

• Information we receive from other sources. We are working closely with third parties (including, for example, marketing services and recruitment agencies) that may provide us with additional information about you.

If we are unable to collect this information, this may affect the provision of the services you have requested from us.

Cookies

To the extent permitted under applicable law, our site uses cookies and similar technologies to distinguish you from other users of our site and enable us and third parties to automatically collect information about how you access and use our sites, and about the device you use to access our sites. This helps us to provide you with a good experience when you browse our site and also allows us to customize and improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy. Some web browsers include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. You can make certain choices about cookies and similar technologies to communicate your choice not to be tracked online in our privacy preference center. But we may not respond to DNT signals. As no uniform technology standard for recognizing and implementing DNT signals has been finalized yet, we may not be able to respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

Uses made of the information

When personal information is processed, all technologies available to Able.Digital and its partners and service providers are used, which may include generative AI tools. We use information held about you in the following ways:

• Information you give to us. To the extent permitted under applicable law, we will use this information:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;

• to provide you with information about other goods and services we offer that are similar to those that you have already purchased or inquired about, when permitted by applicable law;

• to provide you, or permit selected third parties to provide you (where you have consented to such sharing when required by applicable law), with information about goods or services we feel may interest you. We will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you, or where you have consented to this, or where we can otherwise lawfully do so.

• to notify you about changes to our service; and

• to ensure that content from our site is presented in the most effective manner for you and for your computer.

• Information we collect about you. To the extent permitted under applicable law, we will use this information:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;

• as part of our efforts to keep our site safe and secure;

• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and

• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

• Information we receive from other sources. To the extent permitted under applicable law, we will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Disclosure of your informatio

‍To the extent permitted under applicable data protection law, we may share your personal data with:

• Any member of our group, which means our subsidiaries. You can find a list of the Relevant Able.Digital Companies below.

Selected third parties including:

• service providers who act as our data processor who are subject to contractual obligations to implement technical and organizational security measures to safeguard the personal data and to process the personal data only as instructed. These third-party service providers assist us in assessing our information security controls, maintaining our site, analyzing our site traffic, and in providing services and information to us and to users of our site;

• advertisers and advertising networks that require the data to select and serve relevant advertisements to you and others. We may provide advertisers and advertising networks with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target;

• analytics and search engine providers that assist us in the improvement and optimization of our site;

To the extent permitted by applicable data protection law, we will also disclose your personal data to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.

• If we or our subsidiaries, or substantially all of the assets of any of the foregoing, is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or request of law enforcement, or in order to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of us or our subsidiaries, our employees, customers, or others.

Overseas Disclosures

• Your personal data may be disclosed to employees, representatives, or other third parties operating outside of the country you are based who work for, or are engaged by us or our subsidiaries in other countries, including the USA and in other countries that we operate, and to our service providers who may be located outside of the country you are based, including the USA and in other countries that we operate. We note that these persons and third parties may also store, transfer or access personal data outside of the country you are based in.

In disclosing your personal data overseas, we will take such steps as are reasonable in the circumstances to require that overseas recipients protect your personal data in accordance with applicable laws. For any further information on the safeguards we adopt to ensure the protection of your personal data, you can contact us using the contact details indicated below.

Contacts and Complaints

• We rely on personal data provided by you. In order to ensure that personal data provided to us is current, complete and accurate, please update us if there are any changes to the personal data provided to us.

Questions, comments or requests regarding this privacy policy are welcomed and should be addressed to the VP, Information Security and Governance at privacy@able.digital or by mail at Able Digital NA LLC, 1000 North West Street Ste 1200, Wilmington, DE 19801. Similarly, if you have any complaints about our privacy management practices, you can contact us at the same details. You may also have a right to raise your complaint with the relevant privacy regulator in your jurisdiction.

Changes to our privacy policy

‍We may make changes to this notce, including material changes, from time to time. We will inform you of any changes to the processing activities described in this notice before we start that new processing.

EEA+ Supplemental Data Protection Law Disclosures

Able Digital NA LLC provides to residents of the European Economic Area, Switzerland and the United Kingdom (EEA+) the following disclosures to supplement the Website Privacy Policy.

Data Controller: The data controller is Able Digital NA LLC, a US corporation incorporated under the laws of the State of Delaware and based at 1000 North West Street Ste 1200, Wilmington, DE 19801.

Legal Bases for Processing under European Union and United Kingdom law: Legal bases for the processing of your personal data by Able Digital NA LLC are:

(i) performance of a contract, where we have entered into a contract with you and need to process your personal data to fulfil our contractual obligations to you (Art. 6 (1) lit. b GDPR/UK GDPR),

(ii) our legitimate interests (Art. 6 (1) lit. f GDPR/UK GDPR) for the transfer of your personal data within the group of companies which are the following: for internal administrative and support purposes,

(iii) compliance with a legal obligation to which Able.Digital is subject (Art. 6 (1) lit. c GDPR/UK GDPR), for example if we are required by law to disclose personal data to law enforcement agencies, or governmental authorities,

(iv) our legitimate interests for the purposes of exercising our legal rights or defending legal claims,

(v) our legitimate interests (Art. 6 (1) lit. b GDPR/UK GDPR) for the transfer of your personal data in connection with a transfer of all or part of our organization or assets which are the following: the orderly transition of all or part of our business,

(vi) our legitimate interests to protect and defend the rights or property of us or third parties, including enforcing agreements, policies and terms of use, and in an emergency including to protect the safety of our employees or any person which are the following: to protect the property, rights, and safety of any person and to prevent fraud. Information on the balancing test is available upon request,

(vii) your consent to the processing (art. 6 (1) lit. a GDPR/UK GDPR) for marketing and advertising purposes, as required by applicable laws.

Recipients in Third Countries: The personal data that we collect or receive about you may be transferred to and processed by recipients that are located inside or outside the EEA+ and which are not recognized from an EEA+ law perspective as providing for an adequate level of data protection. These third parties are generally cloud hosting and internet service providers, operating systems and platform providers, and certain technology partners. When interacting with our site or contacting Able Digital NA LLC, you transfer personal data to the United States. And Able Digital NA LLC may transfer your personal data to the UK, Canada, Ireland, Switzerland. Transfers from Switzerland to the UK, Canada and Ireland do not require additional safeguards. Transfers from Switzerland to the US and Brazil are based on your consent. To the extent your personal data are transferred to countries that do not provide for an adequate level of data protection from an EU or UK law perspective, we will base the respective transfer on appropriate safeguards (Art. 46 GDPR/UK GDPR), such as standard data protection clauses adopted by the European Commission, and any supplementary measures as necessary in order to adequately protect your personal data. You can ask for a copy of such appropriate safeguards by contacting us as set out in the contact section.

Period of Data Storage: Your personal data will be retained for as long as necessary to provide you with the services requested, which in most cases does not exceed 5 years from the date of collection of the data. When Able.Digital no longer needs to use your personal data to comply with contractual obligations, we will remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it, unless we need to keep your information, including personal data, to comply with statutory retention periods e.g. for tax purposes for a legally prescribed time period thereafter, or if we need it to preserve evidence within statutes of limitation. With regard to personal data collected through cookies or similar technologies, details are provided in the Cookies Policy.

Data Subject Rights Under applicable law, you may have the following rights in relation to your personal data. These may be limited under applicable data protection law.

(i) Right to request from us access to personal data: You have the right to confirm with us whether your personal information is processed, and if it is, to request access to that personal information including the categories of personal information processed, the purpose of the processing and the recipients or categories of recipients. You have the right to obtain a copy of the personal data undergoing processing. However, this is not an absolute right and the interests of other individuals may restrict your right of access.

(ii) Right to rectification: You have the right to obtain from us rectification of inaccurate or incomplete personal information concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

(iii) Right to erasure of your personal data (right to be forgotten): You have the right to ask us to erase personal data concerning you.

(iv) Right to restriction of processing: In limited circumstances, you have the right to request that we restrict processing of your personal data.

(v) Right to data portability: You may have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that personal data to another entity without hindrance from us.

(vi) Right to object: Under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling, by us and we can be required to no longer process your personal data.

Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal data will no longer be processed for such purposes by us.

(vii) Right to provide guidelines: For France specifically, you have the right to provide us with guidelines as to the processing of your personal data after your death, either directly or via a trusted third-party.

You also have the right to lodge a complaint with a supervisory authority and you can contact the authority when the exercise of your rights is subject to delay, restriction or exclusion by the data controller. If you have declared your consent for any personal data processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. You can exercise your rights by contacting us as set out in the contact section.

Failure to Provide Personal Data: Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the services you have requested from us. In this case, we may have to cancel the provision of the relevant services to you, in which case we will notify you.

Relevant Able.Digital Companies	Address	Email
Able Digital NA LLC	1000 North West Street Ste 1200, Wilmington, DE 19801	privacy@able.digital
Able Digital CA LP	85 Charlotte Street, Fredericton, New Brunswick E3B 1M7	privacy@able.digital
Able Digital BR Ltda	Rua das Olimpíadas, 205, 4 Andar, Vila Olímpia, São Paulo SP 04551-000, Brazil	privacy@able.digital
Able Digital UK Ltd	30 Moorgate, London, EC2R 6DA United Kingdom	privacy@able.digital

Brazil Supplemental Data Protection Law Disclosures

1. Sensitive data.

Able.Digital does not proactively collect sensitive data from users. Should it become necessary to collect such data in the future, we will request your explicit consent before proceeding with the collection of any sensitive personal data, in accordance with Article 11 of the Lei Geral de Proteção de Dados (LGPD).

2. Your rights in connection with personal information

Under the LGPD, you are entitled to certain rights in relation to your personal data. These include:

• Right of Access: You have the right to confirm whether we process your personal data and to request access to that data. Upon request, we will provide details about the categories of data processed and the purposes for which they are processed.

• Right to Rectification: If your personal data is inaccurate or incomplete, you have the right to request that we correct or update the information.

• Right to Deletion: You may request the deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected or if you withdraw your consent.

• Right to Data Portability: Where applicable, you have the right to request a copy of your personal data in a structured, commonly used, and machine-readable format.

• Right to Information about Shared Data: You can request information about any third parties with whom we have shared your personal data.

• Right to Withdraw Consent: You have the right to withdraw your consent to the processing of your personal data at any time. We will honor such requests to the extent required by the LGPD.

• Right to Object to Processing: In certain situations, you may object to the processing of your personal data, particularly if processing is based on a legitimate interest or for marketing purposes.

To exercise any of your rights, please contact us at privacy@able.digital. Your requests will be handled in compliance with applicable Brazilian laws, and we will provide information on the identification documents required, the timeline for our response, and how we will deliver the information (ie: electronically or in physical format).

California Consumer Privacy Act Policy

These disclosures are provided by Able Digital NA LLC (“Company”) and applies solely to residents of the State of California (“consumers” or “you”) with respect to personal information Company processes as a business. Any terms defined in the California Consumer Privacy Act of 2018, as amended from time to time, including by the California Privacy Rights Act of 2020 and its implementing regulations (“CCPA”) have the same meaning when used in these disclosures. These disclosures do not reflect our collection, use, or disclosure of California residents’ personal information, or data subject rights, where an exception or exemption under the CCPA applies.

1. Notice at Collection

We have set out below categories of personal information about California residents we collect online and/or at Able.Digital events. We do not sell or share for cross context behavioral advertising any personal information of California residents. The California Consumer Privacy Act Privacy Policy is in section 2 of these disclosures.

Category of personal information	Retention Time
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Specifically, name, address, e-mail address, technical information, including the domain and host name from which you access the Internet, the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone and country setting, browser plug-in types and versions, operating system and platform.	Your personal information will be retained for as long as necessary for the purposes for which it was collected, which in most cases do not exceed 5 years, plus any additional time periods necessary for the compliance with laws, exercise or defense of legal rights, and archiving, back-up, and deletion processes.
Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information, but excluding publicly available information that is lawfully made available to the general public from federal, state, or local government records. (The categories of personal information described in the California Customer Records Act (Cal. Civ. Code § 1798.80(e)) Specifically: phone number	Your personal information will be retained for as long as necessary for the purposes for which it was collected, which in most cases do not exceed 5 years, plus any additional time periods necessary for the compliance with laws, exercise or defense of legal rights, and archiving, back-up, and deletion processes.
Commercial information, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Specifically, services you purchased and services you considered.	Your personal information will be retained for as long as necessary for the purposes for which it was collected, which in most cases do not exceed 5 years, plus any additional time periods necessary for the compliance with laws, exercise or defense of legal rights, and archiving, back-up, and deletion processes.
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. Specifically: technical information, including the domain and host name from which you access the Internet, the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone and country setting, browser plug-in types and versions, operating system and platform; information about your site visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page	Your personal information will be retained for as long as necessary for the purposes for which it was collected, which in most cases do not exceed 5 years, plus any additional time periods necessary for the compliance with laws, exercise or defense of legal rights, and archiving, back-up, and deletion processes.
Geolocation data. Specifically: location you provide to us.	Your personal information will be retained for as long as necessary for the purposes for which it was collected, which in most cases do not exceed 5 years, plus any additional time periods necessary for the compliance with laws, exercise or defense of legal rights, and archiving, back-up, and deletion processes.
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Specifically: predictions of characteristics, behavior, attitudes, interests, and preferences.	Your personal information will be retained for as long as necessary for the purposes for which it was collected, which in most cases do not exceed 5 years, plus any additional time periods necessary for the compliance with laws, exercise or defense of legal rights, and archiving, back-up, and deletion processes.
A consumer’s social security, driver’s license, state identification card, or passport number Specifically, social security, driver’s license, passport, and other identification numbers and copies of documentation.	Your personal information will be retained for as long as necessary for the purposes for which it was collected, which in most cases do not exceed 5 years, plus any additional time periods necessary for the compliance with laws, exercise or defense of legal rights, and archiving, back-up, and deletion processes.
A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. Specifically, bank account and other payment details	Your personal information will be retained for as long as necessary for the purposes for which it was collected, which in most cases do not exceed 5 years, plus any additional time periods necessary for the compliance with laws, exercise or defense of legal rights, and archiving, back-up, and deletion processes.
A consumer’s precise geolocation. Specifically, precise geolocation of devices assigned to you	Your personal information will be retained for as long as necessary for the purposes for which it was collected, which in most cases do not exceed 5 years, plus any additional time periods necessary for the compliance with laws, exercise or defense of legal rights, and archiving, back-up, and deletion processes.
The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication. Specifically, electronic communications	Your personal information will be retained for as long as necessary for the purposes for which it was collected, which in most cases do not exceed 5 years, plus any additional time periods necessary for the compliance with laws, exercise or defense of legal rights, and archiving, back-up, and deletion processes.
The processing of biometric information for the purpose of uniquely identifying a consumer. Specifically, facial recognition and other biometrics information within certain Able.Digital events.	Your personal information will be retained for as long as necessary for the purposes for which it was collected, which in most cases do not exceed 5 years, plus any additional time periods necessary for the compliance with laws, exercise or defense of legal rights, and archiving, back-up, and deletion processes.

We use non-sensitive personal information about website visitors:

• To monitor and maintain the performance of the sites and to analyze trends, usage and activities in connection with the sites

• To measure the effectiveness of advertising we serve to you;

• As part of our efforts to keep our site safe and secure;

• To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

• To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them;

• To deliver relevant advertising to you;

• To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;

• To provide you with information about other goods and services we offer that are similar to those that you have already purchased or inquired about;

• To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. We will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you, or where you have consented to this, or where we can otherwise lawfully do so;

• To notify you about changes to our service;

• To ensure that content from our site is presented in the most effective manner for you and for your computer;

• To provide you with certain experiences during a client or other marketing event; and

• To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

We use sensitive personal information about our website visitors:

• To perform the services or provide the goods reasonably expected by our website visitors;

• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information, including in or via our premises, computers, software, networks, communications devices, and other similar system;

• To resist malicious, deceptive, fraudulent or illegal actions directed at us and to prosecute those responsible for those actions;

• To ensure the physical safety of natural persons;

• For short-term, transient use;

• To perform services on behalf of us;

• To verify or maintain the quality or safety of our services and products;

• To improve, upgrade, or enhance our services and products;

• For purposes that do not infer characteristics about the consumer; and

• To perform functions that are required under laws that apply to us.

2. California Consumer Privacy Act Privacy Policy

Our Personal Information Handling Practices in 2022

We have set out below categories of personal information about California residents we have collected, and as applicable disclosed, for a business purpose in the preceding 12 months. The table is followed by a description of the purposes for which we collected personal information. In the preceding 12 months we did not sell or share for cross context behavioral advertising, the personal information of California residents.

Category of personal information	We collected such personal information to use for the following business or commercial purposes:	We have collected such personal information from the following categories of sources:	We shared such personal information with the following categories of third parties:
Non Sensitive Personal Information
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Specifically, name, address, e-mail address, technical information, including the domain and host name from which you access the Internet, the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone and country setting, browser plug-in types and versions, operating system and platform.	To monitor and maintain the performance of the sites and to analyze trends, usage and activities in connection with the sites, to measure the effectiveness of advertising we serve to you, and to deliver relevant advertising to you.	Directly from the California resident, cookies or lead generation service providers.	Cloud hosting and internet service providers, government entities, operating systems and platform providers, and certain technology partners.
Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information, but excluding publicly available information that is lawfully made available to the general public from federal, state, or local government records. (The categories of personal information described in the California Customer Records Act (Cal. Civ. Code § 1798.80(e)) Specifically: phone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	To monitor and maintain the performance of the sites and to analyze trends, usage and activities in connection with the sites, to measure the effectiveness of advertising we serve to you, and to deliver relevant advertising to you; to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us; to provide you with information about other goods and services we offer that are similar to those that you have already purchased or inquired about; to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. We will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you, or where you have consented to this, or where we can otherwise lawfully do so; to notify you about changes to our service; to ensure that content from our site is presented in the most effective manner for you and for your computer; to administer payroll, taxes, pensions, and benefits for workers.	Directly from the California resident, cookies or lead generation service providers.	Cloud hosting and internet service providers, government entities, operating systems and platform providers, and certain technology partners.
Characteristics of protected classifications under California or federal law.	To comply with anti-discrimination laws and government reporting obligations and to help ensure equal employment opportunities.	Directly from the California resident.	IT and security staff as well as external vendors; employees of other departments and outside third parties, including, but not limited to (i) employees in our HR, internal audit, compliance and legal departments; (ii) information technology service providers, and (iii) external advisors (law firms, auditors, etc.) or public authorities (for instance, in the course of investigations or mergers or acquisitions). We may also disclose personal information to government officials on demand.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Specifically, services you purchased and services you considered.	To monitor and maintain the performance of the sites and to analyze trends, usage and activities in connection with the sites, to measure the effectiveness of advertising we serve to you, and to deliver relevant advertising to you; to provide you with information about other goods and services we offer that are similar to those that you have already purchased or inquired about; and to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. We will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you, or where you have consented to this, or where we can otherwise lawfully do so.	Directly from the California resident.	Certain technology partners.
Biometric information.	For authentication and security purposes.	Directly from the California resident.	IT and security staff as well as external vendors; employees of other departments and outside third parties, including, but not limited to (i) employees in our HR, internal audit, compliance and legal departments; (ii) information technology service providers, and (iii) external advisors (law firms, auditors, etc.) or public authorities (for instance, in the course of investigations or mergers or acquisitions). We may also disclose personal information to government officials on demand.
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. Specifically, technical information, including the domain and host name from which you access the Internet, the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone and country setting, browser plug-in types and versions, operating system and platform; information about your site visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page	To monitor and maintain the performance of the sites and to analyze trends, usage and activities in connection with the sites, to measure the effectiveness of advertising we serve to you, and to deliver relevant advertising to you; to provide you with information about other goods and services we offer that are similar to those that you have already purchased or inquired about; to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. We will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you, or where you have consented to this, or where we can otherwise lawfully do so; and to ensure that content from our site is presented in the most effective manner for you and for your computer.	Through our use of cookies.	IT and security staff as well as external vendors; employees of other departments and outside third parties, including, but not limited to (i) employees in our HR, internal audit, compliance and legal departments; (ii) information technology service providers, and (iii) external advisors (law firms, auditors, etc.) or public authorities (for instance, in the course of investigations or mergers or acquisitions). We may also disclose personal information to government officials on demand.
Geolocation data. Specifically, location you provide to us, location based on your IP address.	To provide connectivity	Directly from the California resident, cookies or lead generation service providers.	IT and security staff as well as external vendors; employees of other departments and outside third parties, including, but not limited to (i) employees in our HR, internal audit, compliance and legal departments; (ii) information technology service providers, and (iii) external advisors (law firms, auditors, etc.) or public authorities (for instance, in the course of investigations or mergers or acquisitions). We may also disclose personal information to government officials on demand.
Audio, electronic, visual, thermal, olfactory, or similar information. Specifically, complaints received in audio recordings (ie:, telephone calls)	To provide you with certain experiences during a client or other marketing event; and to respond to complaints	Directly from the California resident.	IT and security staff as well as external vendors; employees of other departments and outside third parties, including, but not limited to (i) employees in our HR, internal audit, compliance and legal departments; (ii) information technology service providers, and (iii) external advisors (law firms, auditors, etc.) or public authorities (for instance, in the course of investigations or mergers or acquisitions). We may also disclose personal information to government officials on demand.
Professional or employment-related information.	To evaluate your qualifications and fit for the role, maintain recruitment records, ensure compliance with legal requirements and conduct other employment-related activities.	Directly from the California resident.	IT and security staff as well as external vendors; employees of other departments and outside third parties, including, but not limited to (i) employees in our HR, internal audit, compliance and legal departments; (ii) information technology service providers, and (iii) external advisors (law firms, auditors, etc.) or public authorities (for instance, in the course of investigations or mergers or acquisitions). We may also disclose personal information to government officials on demand.
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).	To evaluate your qualifications and fit for the role, maintain recruitment records, ensure compliance with legal requirements and conduct other employment-related activities.	Directly from the California resident.	IT and security staff as well as external vendors; employees of other departments and outside third parties, including, but not limited to (i) employees in our HR, internal audit, compliance and legal departments; (ii) information technology service providers, and (iii) external advisors (law firms, auditors, etc.) or public authorities (for instance, in the course of investigations or mergers or acquisitions). We may also disclose personal information to government officials on demand.
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Specifically, predictions of characteristics, behavior, attitudes, interests, and preferences	To provide you with information about other goods and services we offer that are similar to those that you have already purchased or inquired about; to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. We will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you, or where you have consented to this, or where we can otherwise lawfully do so; and to ensure that content from our site is presented in the most effective manner for you.	Directly from the California resident, cookies or lead generation service providers.	IT and security staff as well as external vendors; employees of other departments and outside third parties, including, but not limited to (i) employees in our HR, internal audit, compliance and legal departments; (ii) information technology service providers, and (iii) external advisors (law firms, auditors, etc.) or public authorities (for instance, in the course of investigations or mergers or acquisitions). We may also disclose personal information to government officials on demand.
Sensitive Personal Information
A consumer’s social security, driver’s license, state identification card, or passport number Specifically, social security, driver’s license, passport, and other identification numbers and copies of documentation	For authentication purposes and to comply with tax and immigration law.	Directly from the California resident.	IT and security staff as well as external vendors; employees of other departments and outside third parties, including, but not limited to (i) employees in our HR, internal audit, compliance and legal departments; (ii) information technology service providers, and (iii) external advisors (law firms, auditors, etc.) or public authorities (for instance, in the course of investigations or mergers or acquisitions). We may also disclose personal information to government officials on demand.
A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. Specifically, bank account and other payment details	To pay your compensation or process your payments.	Directly from the California resident.	IT and security staff as well as external vendors; employees of other departments and outside third parties, including, but not limited to (i) employees in our HR, internal audit, compliance and legal departments; (ii) information technology service providers, and (iii) external advisors (law firms, auditors, etc.) or public authorities (for instance, in the course of investigations or mergers or acquisitions). We may also disclose personal information to government officials on demand.
A consumer’s precise geolocation. Specifically, precise geolocation of devices assigned to you	To provide connectivity, find you in an emergency, investigate legal issues, and retrieve lost or stolen devices.	From the device.	IT and security staff as well as external vendors; employees of other departments and outside third parties, including, but not limited to (i) employees in our HR, internal audit, compliance and legal departments; (ii) information technology service providers, and (iii) external advisors (law firms, auditors, etc.) or public authorities (for instance, in the course of investigations or mergers or acquisitions). We may also disclose personal information to government officials on demand.
A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership.	To comply with anti-discrimination laws and government reporting obligations and to help ensure equal employment opportunities.	Directly from the California resident.	IT and security staff as well as external vendors; employees of other departments and outside third parties, including, but not limited to (i) employees in our HR, internal audit, compliance and legal departments; (ii) information technology service providers, and (iii) external advisors (law firms, auditors, etc.) or public authorities (for instance, in the course of investigations or mergers or acquisitions). We may also disclose personal information to government officials on demand.
The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication. Specifically, electronic communications	For purposes of quality control, training, and compliance with law and company policies.	From monitoring systems.	IT and security staff as well as external vendors; employees of other departments and outside third parties, including, but not limited to (i) employees in our HR, internal audit, compliance and legal departments; (ii) information technology service providers, and (iii) external advisors (law firms, auditors, etc.) or public authorities (for instance, in the course of investigations or mergers or acquisitions). We may also disclose personal information to government officials on demand.
The processing of biometric information for the purpose of uniquely identifying a consumer. Specifically, facial recognition and other biometrics information	To provide you with certain experiences during a client or other marketing event and for authentication and security purposes.	Directly from the California resident.	IT and security staff as well as external vendors; employees of other departments and outside third parties, including, but not limited to (i) employees in our HR, internal audit, compliance and legal departments; (ii) information technology service providers, and (iii) external advisors (law firms, auditors, etc.) or public authorities (for instance, in the course of investigations or mergers or acquisitions). We may also disclose personal information to government officials on demand.
Personal information collected and analyzed concerning a consumer’s health.	To provide work-related accommodations, to provide health and insurance benefits to workers and dependents, or to manage absences from work; to comply with county orders, laws, and health and safety needs, and monitor and improve workplace safety and ergonomics efficiency.	Directly from the California resident.	IT and security staff as well as external vendors; employees of other departments and outside third parties, including, but not limited to (i) employees in our HR, internal audit, compliance and legal departments; (ii) information technology service providers, and (iii) external advisors (law firms, auditors, etc.) or public authorities (for instance, in the course of investigations or mergers or acquisitions). We may also disclose personal information to government officials on demand.
Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.	To comply with anti-discrimination laws and government reporting obligations and to help ensure equal employment opportunities.	Directly from the California resident.	IT and security staff as well as external vendors; employees of other departments and outside third parties, including, but not limited to (i) employees in our HR, internal audit, compliance and legal departments; (ii) information technology service providers, and (iii) external advisors (law firms, auditors, etc.) or public authorities (for instance, in the course of investigations or mergers or acquisitions). We may also disclose personal information to government officials on demand.

We used sensitive personal information about consumers for the following business or commercial purpose:

• To perform the services or provide the goods reasonably expected by consumers;

• To resist malicious, deceptive, fraudulent or illegal actions directed at us and to prosecute those responsible for those actions;

• To ensure the physical safety of natural persons;

• For short-term, transient use;

• To perform services on behalf of us;

• To verify or maintain the quality or safety of our services and products;

• To improve, upgrade, or enhance our services and products;

• For purposes that do not infer characteristics about the consumer; and

• To perform functions that are required under laws that apply to us.

We do not have actual knowledge that we sell or share for cross context behavioral advertising, the personal information of California residents under 16 years of age.

CCPA Rights

As a California resident, you have the following rights under the CCPA:

• The right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you. You may only exercise your right to know twice within a 12-month period.

• The right to delete personal information that we have collected from you, subject to certain exceptions.

• The right to correct inaccurate personal information that we maintain about you.

• The right to opt-out of the sale or sharing of your personal information by us. We do not sell or share for cross-context behavioral advertising any of the categories of personal information that we collect about California residents.

• The right to limit our use and disclosure of sensitive personal information to purposes specified in subsection 7027(m) of the California Consumer Privacy Act Regulations. We do not use or disclose sensitive personal information for purposes other than those specified in subsection 7027(m) of the California Consumer Privacy Act Regulations.

• The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, in violation of California Civil Code § 1798.125, including an employee's, applicant's, or independent contractor's right not to be retaliated against for the exercise of their CCPA rights.

How to Exercise CCPA Rights

‍Methods of Submission and Instructions: To submit a request to exercise your rights to know, delete or correct, please call our toll-free phone number +18554674501 or submit an email request to privacy@able.digital and include “California Request to [Know, Delete or Correct]” in the subject line.

Verification: Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may designate an authorized agent by taking the steps outlined under "Authorized Agent" further below. In your request or in response to us seeking additional information, you, or your authorized agent, must provide sufficient information to allow us to reasonably verify that you are, in fact, the person whose personal information was collected which will depend on your prior interactions with us and the sensitivity of the personal information being requested. We will ask that you provide certain information to verify your identity, such as a code sent to an email address we may have on file for you. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. If you do not provide enough information for us to reasonably verify your identity, we will not be able to fulfill your request. We will only use the personal information you provide to us in a request for the purposes of verifying your identity and to fulfill your request. If we deny your request, we will explain why.

Authorized Agents: You can designate an authorized agent to make a request under the CCPA on your behalf if:

• The authorized agent is a natural person or a business entity and the agent provides proof that you gave the agent signed permission to submit the request; and

• You directly confirm with Company that you provided the authorized agent with permission to submit the request.

If you use an authorized agent to submit a request to exercise your right, please have the authorized agent take the following steps in addition to the steps above:

• Mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf to 1000 North West St Ste 1200, Wilmington, DE 19801 United States; and

• Provide any information we request in our response to your email to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4121 to 4130, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

Contact Us

If you have any questions or comments about these disclosures or our practices, please contact us at:

Email address: privacy@able.digital

Postal address:
Able Digital NA LLC
1000 North West Street, Ste 1200
Wilmington, DE 19801
United States

Last Updated: 1 January 2024