Snapshot 96795

Document
Privacy policy
URL
https://teramot-documentation.s3.us-east-1.amazonaws.com/public/Teramot%20-%20Website%20Privacy%20Policy%201.1.pdf
Fetched
HTTP status
200
Content type
application/pdf
Fetch mode
pdf
Size
367945 bytes
SHA-256 (raw)
0eb7de2c6270e8eaf18a570b87118bc7e1a2718bdf4ea3abfa8024ac0f18faa7
SHA-256 (normalized text)
dc57fd91d7f36ede6a7420c3341dfb2476363ed057d86e0f4ac7275f61ccd31a

Normalized text

Scripts and page chrome removed; this is what change detection compares.

                                            Teramot Privacy Policy

  Last Updated: October 29, 2024

  Halley LLC (known as Teramot), together with its affiliates, and subsidiaries (“we,” “us,” “our”),
  is a global company that provides solutions that allow businesses to easily access their data to
  make informed decisions and stay ahead of the competition, helping them reach their full
  potential.

  Contents

  1.​ User​                                                                                       2

  2.​ Scope​                                                                                      2

  3.​ Personal Data We Collect​                                                                   2

  4.​ How We Use Personal Data​                                                                   4

  5.​ Disclosures of Personal Data​                                                               4

  6.​ International Data Transfer​                                                                5

  7.​ Legal Basis​                                                                                6

  8.​ Cookies and Other Tracking Mechanisms​                                                      7

  9.​ How Do We Keep Your Information Safe?​                                                      8

  10.​     How Long We Retain Your Personal Data​                                                 8

  11.​     Your rights as a data subject​                                                         8

  12.​     Personal Data of Minors​                                                               9

  13.​     External Links​                                                                        9

  14.​     California Notice at Collection and Privacy Rights​                                   10

  15.​     Brazilian Privacy Statement​                                                          15

  16.​     Will we make changes to this Policy?​                                                 15

  17.​     Contact us​                                                                           15

1.​      USER
  In short, by using our site, you agree to this privacy policy.

  By accessing our Site, contacting us, and/or using our services, you become a TERAMOT user
  (“you”, “user”) and acknowledge and accept the currently Last Updated version of this Privacy
  Policy (“Policy”), as published by us in our Site, as a binding agreement in relation to the use of
  your data.

  As a user, you acknowledge and agree to your obligation of reading this Policy in detail.
  Furthermore, you accept for any personal data you provide in our Site to be treated in accordance
  with this Policy. IF YOU DO NOT AGREE WITH THIS POLICY, PLEASE LEAVE THE
  WEBSITE.

2.​     SCOPE

  In short, here you’ll find the details on how we will process your personal data. We will always
  do it in compliance with the law. If we received your data from our customers or as part of an
  interview, different terms may apply.

  This Policy explains how we process personal data from you and other customers and visitors to
  our websites (“Sites”) and users of our services (“Services”) as a controller or business under
  applicable privacy laws.

  We are committed to handling your data responsibly and in compliance with all relevant data
  protection regulations, including US regulations, GDPR and your applicable national laws. If you
  are a California resident, please review our California Notice at Collection and Privacy Rights.

  When we collect personal data as a processor on behalf of business customers, we process
  personal data in accordance with our contract with them.

  This Policy does not apply to the personal data of employees or job applicants or to information
  that is exempt under applicable laws. We may provide additional notices when needed to clarify
  our privacy practices in specific circumstances.

3.​     PERSONAL DATA WE COLLECT

  In short, we collect the personal data you provide to us, the data we receive from third parties,
  and the data automatically collected when you access the Site.

  While the personal data we collect varies depending upon your use of our Site, our Services, and
  our interactions with you, we may collect personal data from you (that you voluntarily provide to
  us introducing it in the Site), from third-party sources, and automatically in the following
  circumstances:

3.1.​    Personal Data Collected Directly from You. We may collect the following personal data
         from you:

                   3.1.1.​ Contact Information. When you “Book a Call” with us or contact us for
                           support or other customer service requests, we maintain records of your
                          requests/ related communications. For example, when you use our
                          Contact section, we may collect details, including your name, country,
                          email address, and phone number. We usually won’t, but may also collect
                          your company, job title, and industry if you choose to provide them.

                  3.1.2.​ Usernames and Passwords.

                  3.1.3.​ Communications. We collect the information you provide, such as
                          contact information and records of our communications.

                  3.1.4.​ Usage Data. your geographical location, usage sessions, time spent on
                          the Site, frequency of use, etc.

                  3.1.5.​ Transaction and Billing Information. We collect information when you
                          purchase a product or service from us (though we do not store any
                          payment details).

                  3.1.6.​ Surveys. When you fill out a survey, we collect your response, which,
                          depending on the type of survey, may include contact information and
                          your satisfaction with a product or Service.

                  3.1.7.​ Events. We also collect personal data related to your registration for and
                          participation in events we host or sponsor.

                  3.1.8.​ Sweepstakes, contests, and promotions. If you participate in
                          sweepstakes, contests, and promotions that we offer, we might collect
                          your name, age, country of residence, email address, and other
                          registration information related to contests, sweepstakes, and promotions.
                          In some jurisdictions, we must disclose the winners' names and other
                          personal information.

                  3.1.9.​ Image/video recording and transcripts. Your image may be captured
                          and/or recorded on video security/monitoring systems when you enter
                          our premises, captured during marketing or public filming
                          events/sessions, and/or audio-video recording and transcription during
                          meetings.

                 3.1.10.​ Other Information. We may collect other personal data that you consent
                          to or would reasonably expect based on the nature of the circumstances.

3.2.​   Personal Data Collected from Third Parties. We may collect personal data about you
        from third-party sources such as public databases, advisors and agents, affiliates and
        subsidiaries, Internet service providers, operating systems and platforms, data brokers and
        analytics providers, advertising and marketing companies, business partners, clients, social
        media platforms, or other third parties.
3.3.​    Personal Data Collected Automatically. When you visit our Sites or Services, we and third
         parties may collect personal data, including through the use of cookies, pixel tags, and other
         similar technologies such as:

                   3.3.1.​ Device and Browsing Information. When you visit our Site, we may
                           collect information that may be considered personal data under certain
                           laws, such as IP address (a number that permits us to identify your
                           device), browser type, domain names, access times, date/time stamps,
                           operating system, language, device type, unique or online identifier,
                           Internet service provider, referring and exiting URLs, clickstream data,
                           and similar device and browsing information.

                   3.3.2.​ Activities and Usage. We also collect activity information related to
                           your use of the Site, such as information about links clicked, searches
                           conducted, features used, items viewed, time spent on certain pages, your
                           interactions with us, log file information, and other activity and usage
                           information.

                   3.3.3.​ Location Information. We may also collect or derive general location
                           information about you, such as through your IP address.

  For more information please review Section 8: Cookies and Other Tracking Mechanisms.

4.​     HOW WE USE PERSONAL DATA

  In short, we process your personal data to provide, improve and administer our Services,
  communicate with you, for security and fraud prevention, and to comply with the Law. We may
  also process your information for other purposes with your consent.

  Generally, we use personal data for the following purposes:

4.1.​    Providing Services and Support. To provide and operate our Site and Services,
         communicate with you about your use of the Services, provide troubleshooting and
         technical support, respond to your inquiries, fulfill your orders and requests, communicate
         with you, and for similar service and support purposes.

4.2.​    Diagnosis. To identify any potential problems (i.e., connectivity issues) that may arise on
         the Site and affect the Services.

4.3.​    Communications. To respond to your questions and fulfill your orders and requests; to
         send you communications that you have requested or that may interest you; and to notify
         you of changes to our Services.

4.4.​    Analytics and Improvement. To better understand how you access and use the Site and
         Services, and our other products and offerings, and for other research and analytical
         purposes, such as to evaluate and enhance our Site and Services and business operations, to
         develop our Site and Services and features, and for internal quality control and training
         purposes. This includes supporting and developing AI-assisted data processing solely for
         analysis, with no human involvement in data.

 4.5.​   Customization and Personalization. To tailor content, we may send or display it on the
         Site and Services, including offering location customization and personalized help and
         instructions, and to personalize your experiences otherwise.

 4.6.​   Marketing and Advertising. We aim to send you information about our services, such as
         offers, promotions, newsletters, and any other information that you sign up to receive, as
         well as to manage, analyze, measure, and improve our advertising campaigns.

 4.7.​   Planning and Managing Events. For event planning and management, including
         registration, attendance, connecting you with other event attendees, and contacting you
         about relevant events and Services.

 4.8.​   Research and Surveys. To administer surveys and questionnaires, such as for market
         research or customer satisfaction purposes.

 4.9.​   Sweepstakes, contests, and promotions. To facilitate your participation in sweepstakes,
         contests, and promotions, including communicating with you about your involvement in the
         sweepstake, contest, or promotion.

4.10.​   Security and Protection of Rights. To protect the Site and Services and our business
         operations; to prevent and detect fraud, unauthorized activities and access, and other
         misuse; where we believe necessary to investigate, prevent, or act regarding illegal
         activities, suspected fraud, situations involving potential threats to the safety or legal rights
         of any person or third party, or violations of our terms or this Policy.

4.11.​   Legal Proceedings and Obligations. We must comply with the law and our legal
         obligations, respond to legal processes, and deal with legal proceedings. For that reason, we
         will store any information collected from you for as long as necessary and will use the
         information you provided if requested by courts or national or international state entities
         that request it.

4.12.​   Exercise of Data Protection rights. We will process and analyze your data in relation to
         any relevant requests we receive to exercise your (or other user’s) Right of Access, Right to
         Rectification, Right to Erasure (Right to be Forgotten), Right to Restriction of Processing,
         Right to Data Portability, Right to Object, Right to Not Be Subject to Automated
         Decision-Making and Profiling, and any other rights applicable under the relevant
         regulations.

4.13.​   General Business and Operational Support. Accounting, auditing, compliance,
         recordkeeping, and legal functions are related to the administration of our general business.

4.14.​   Other Uses. As authorized by you.
5.​     DISCLOSURES OF PERSONAL DATA

  In short, we may share information in specific situations described in this section and/or with the
  following third parties.

  In general, we disclose and make available personal data to third parties in the following ways:

5.1.​    Corporate Affiliates. We may disclose personal data to corporate affiliates as part of our
         global business operations and for purposes and uses that are consistent with this Policy.

5.2.​    Processors and Service Providers. We may disclose personal data to our service providers
         who perform services on our behalf, such as IT service providers, hosting providers, email
         service providers, chatbot providers, call centers, etc.

5.3.​    Third Parties, Platforms, and Services. We may disclose or make personal data available
         to third-party platforms and providers that we use to provide or make available certain
         features or portions of the Site and Services or as necessary to respond to your requests.

5.4.​    Marketing & Advertising Networks. We may share information you provide us with
         advertising networks, search engines, social media platforms, sponsors, and/or traffic
         measurement services, who use this data to improve and measure our ads' effectiveness and
         serve targeted ads to you on third-party websites and platforms. For more information,
         including how to opt out of interest-based advertising, see Section 8: Cookies and Other
         Tracking Mechanisms and Section 11: Your Rights As A Data Subject below.

5.5.​    Third-Party Analytics Providers. We may also engage third-party analytics companies to
         collect information about how you access and use our Site and Services, improve them, and
         for other research and analytical purposes.

5.6.​    Compliance, governance, and legal requirements. We may disclose personal data to
         comply with legal and compliance obligations and to respond to legal processes related to
         legal proceedings. For example, we may disclose personal data in response to subpoenas,
         court orders, and other lawful requests by regulators and law enforcement. We may also
         disclose information, including personal data, related to litigation and other legal claims or
         proceedings, for our internal accounting, auditing, compliance, recordkeeping, and legal
         functions. In addition, we may disclose the names of sweepstakes and contest winners in
         accordance with applicable law.

5.7.​    Business Transfers. We may disclose personal data as part of commercial transactions
         (e.g., mergers, acquisitions, bankruptcy, or other similar business transactions) and in
         contemplation of such transactions (e.g., due diligence).

5.8.​    Business partners. We may disclose your personal data with partners who are co-hosting
         or organizing an event with us, or that we understand in good faith that may offer you
         relevant products, services, or promotions.

5.9.​    Other Disclosures. We may disclose your personal data for other purposes, which we will
         notify you of and/or obtain your consent when required.
5.10.​    Aggregate and/or Deidentified Data. We may use and disclose aggregate, deidentified,
          and other non-identifiable data related to our business and the Services for quality control,
          analytics, research, development and other purposes. Where we use, disclose, or process
          deidentified data we will maintain and use the information in deidentified form and not to
          attempt to reidentify it except where permitted by law.

 6.​     INTERNATIONAL DATA TRANSFER

   In short, we may transfer, store, and process your information in countries, other than your own.

   Our servers are located in the United States. If you are accessing our Site from a different country,
   please be aware that your information may be transferred to, stored by, and processed by us in our
   facilities and in the facilities of the third parties with whom we may share your personal
   information (see Section 5: Disclosures of Personal Data above),

   Given our international presence, your personal data may be transferred within and out of the
   European Economic Area (EEA). Any international transfers of your personal information will
   comply with applicable laws and regulations regarding personal data protection and complying
   with all legal confidentiality and security obligations. Your personal data will not be shared with
   any third parties that do not have authorization for their processing.

   To efficiently provide services, some of our service providers (data processors) are located in
   countries outside the EEA, or if they are located in the EEA, they may share information with
   entities outside the EEA.

   When we transfer personal data outside of the EEA, to be processed by companies hired by us or
   our affiliates or subsidiaries, we will comply with the EU General Data Protection Regulation and
   all applicable data transfer regulations. Specifically, all data transfers will comply with
   appropriate safeguards.

 7.​     LEGAL BASIS

   In short, we only process your personal information when we believe it is necessary and we have
   a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to
   comply with laws, to provide you with services to enter into or fulfill our contractual obligations,
   to protect your rights, or to fulfill our legitimate business interests.

   If you are located in the EU or UK, this section applies to you.

   We are entitled to use your personal data based on (i) our legitimate interest, such as for research
   and development, to market and promote our Services, to protect our legal rights and interests, to
   comply with our obligations to provide a service under a contract, to the extent that your interests
   or your fundamental rights are not overridden; (ii) your consent to do so for a specific purpose; or
   (iii) to process your data to comply with a legal obligation.

   In legal terms, we are generally the "data controller" under European data protection laws of the
   personal information described in this Policy, since we determine the means and/or purposes of
  the data processing we perform. This Policy does not apply to the personal information we
  process as a "data processor" on behalf of our customers. In those situations, the customer with
  that we provide services and with whom we have entered into a data processing agreement is the
  "data controller," responsible for your personal information, and we merely process your
  information on their behalf in accordance with your instructions. If you want to know more about
  our customers' privacy practices, you should read their privacy policies and direct any questions
  you have to them.

  If you are located in Canada, this section applies to you.

  We may process your information if you have given us specific permission (i.e., express consent)
  to use your personal information for a specific purpose, or in situations where your permission
  can be inferred (i.e., implied consent). You can withdraw your consent at any time.

  In some exceptional cases, we may be legally permitted under the applicable law to process your
  information without your consent, including, for example if it is clearly in your interest and your
  consent cannot be obtained in a timely way, for investigations and fraud detection and prevention,
  if it is contained in a witness statement and the collection is necessary to assess, process, or settle
  an insurance claim, etc.)

8.​   COOKIES AND OTHER TRACKING MECHANISMS

  In short, we may use cookies and other tracking technologies to collect and store your
  information.

  We and other third parties use cookies, pixel tags, and other similar tracking mechanisms to
  automatically collect information about browsing activity, device type, and similar information
  within our Site and Services.

  We use this information to, for example, analyze and understand how you access, use, and
  interact with our Site and Services; to identify and resolve bugs and errors in our Site and
  Services; to assess, secure, protect, optimize, and improve the performance of our Site and
  Services; for marketing, advertising, measurement and analytics purposes; and to personalize
  content on our Site and Services.

  We may also deidentify or aggregate such information to analyze trends, administer our Site and
  Services, and gather broad demographic information for aggregate uses and for any other lawful
  purpose.

  “Cookies” are alphanumeric identifiers used for tracking purposes. Some cookies allow us to
  make it easier for you to navigate, while others are used to enable a faster log-in process, support
  the security and performance of the Site, or allow us to track activity and usage data within the
  Site and across websites.

  “Pixel tags” (sometimes called web beacons or clear GIFs) are tiny graphics with a unique
  identifier, similar in function to cookies. We may use these tracking technologies to understand
  users’ activities, help manage content, and compile usage statistics, and in emails to let us know
   when they have been opened or forwarded so we can track response rates and gauge the
   effectiveness of our communications.

   Third Party Analytics. We use third-party tools, such as Google Analytics, which are operated
   by third-party companies to evaluate usage of our Site. These third-party analytics companies use
   cookies, pixels, and other tracking technologies to collect usage data about our Site to provide us
   with reports and metrics that help us evaluate usage of our Site, improve our Site, and enhance
   performance and user experience.

   To learn more about Google’s privacy practices, please review the Google Privacy Policy at
   https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics
   Opt-out Browser Add-on to prevent your data from being used by Google Analytics at
   https://tools.google.com/dlpage/gaoptout.

 9.​   HOW DO WE KEEP YOUR INFORMATION SAFE?

   In short, we aim to protect your personal information through a system of organizational and
   technical security measures, however, there is always a risk.

   We have implemented appropriate and reasonable technical and organizational security measures
   designed to protect the security of any personal information we process. However, despite our
   safeguards and efforts to secure your information, no data transmission over the Internet can be
   guaranteed to be 100% secure. As a result, while we strive to protect your personal data, we
   cannot guarantee or warrant the security of any information collected through our Site and
   Services. You use our Site and Services and provide us with your personal data at your own risk.

10.​   HOW LONG WE RETAIN YOUR PERSONAL DATA

   In short, we keep your information for as long as necessary to fulfill the purposes outlined in this
   Policy unless otherwise required by law.

   Your personal data will be retained until it is no longer needed to fulfill the purposes and uses for
   which it was collected, as outlined in this Policy. If you request we delete your personal data from
   our databases, please note that we may still retain it as necessary to comply with our legal
   obligations and regulatory requests, resolve disputes, and enforce our agreements.

   For information received from our clients, we generally (unless otherwise agreed directly with
   them) reserve the right to retain it for a period of 10 years and/or until the purpose for processing
   it is completed. After the specified period, we will destroy the Personal Data.

11.​   YOUR RIGHTS AS A DATA SUBJECT

   In short, depending on your state of residence in the US or in some regions, such as the
   European Economic Area (EEA), United Kingdom(UK), Switzerland, and Canada, you have
   rights that allow you greater access to and control over your personal information. You may
   review, change, or terminate your account at any time, depending on your country, province, or
   state of residence.
   You may exercise your Right of Access, Right to Rectification, Right to Erasure (Right to be
   Forgotten), Right to Restriction of Processing, Right to Data Portability, Right to Object, Right to
   Not Be Subject to Automated Decision-Making and Profiling, and any other rights applicable
   under the relevant regulations by sending a letter to our address as outlined below (Section 5:
   Disclosures of Personal Data) or by emailing our Data Privacy Officer, Federico Ceccatto
   [federico@teramot.com].

   In case we need to verify your identity, we may require you to send us a copy of a valid
   government-issued identification document.

   If you consider your request has not been properly responded to, you may file a complaint with
   the competent authority. However, we recommend that prior to filing any complaint with the
   competent authority, you reach out to our Data Protection Officer by sending an email
   to [privacy@teramot.com] in order to review the specific situation and try, if possible, to find an
   amicable and efficient solution.​

12.​   PERSONAL DATA OF MINORS

   In short, we provide a general audience Site. The Site is not designed for minors, and they must
   refrain from using the Site. We do not knowingly collect personal data from minors.

   This Site is not directed at minors, and if minors gain access to it, their use must be supervised by
   their parents, guardians, or legal representatives.

   The Site is only allowed for those who are of legal age to enter into contracts and are not legally
   restrained or in any way prohibited from exercising legal acts, rights, and/or obligations. Given
   this, minors are not allowed to access the Site nor to provide any Personal Data or any other type
   of information

13.​   EXTERNAL LINKS

   In short, we are not responsible for the safety of any information that you share with third parties
   that we may link to or who advertise on our Site.

   Our Sites and Services could contain links to third-party websites or features. Access to and use
   of such linked websites or features is not governed by this Policy but by the privacy policies of
   those third parties. We are not responsible for the information practices of such third parties,
   including their collection of your personal data. You should review the privacy policies and terms
   for any third-party websites before proceeding to those websites or using those features.

14.​   CALIFORNIA NOTICE AT COLLECTION AND PRIVACY RIGHTS

   In short, these terms that apply to you if you are a California resident.

   This section of the Policy (the “California Privacy Notice”) provides additional information for
   California residents and describes our information practices pursuant to applicable California
   privacy laws, including the California Consumer Privacy Act and the regulations issued thereto,
   each as amended (the “CCPA”).

   In this section, “Personal Information” means information that identifies, relates to, describes, is
   reasonably capable of being associated with, or could reasonably be linked, directly or indirectly,
   with a particular California resident or household. This section does not address or apply to our
   handling of publicly available information or Personal Information that is otherwise exempt under
   the CCPA.

14.1.​   Categories of Personal Information Collected and Disclosed. The following table
         identifies the categories of Personal Information we may collect about you (and may have
         collected in the prior 12 months), as defined by the CCPA, as well as the categories of third
         parties to whom we may disclose this information for a business or commercial purpose.
         Depending on how you use the Services, we may collect and disclose the following
         categories of Personal Information. For more information, please see Section 4: How We
         Use Personal Data & Section 5: Disclosures of Personal Data above.

   Personal Information Collected                             Third Party Disclosures for
                                                              Business or Commercial Purposes
   Categories               Description

   Identifiers              Includes name, alias, address,        ●​ advisors and agents
                            unique personal identifier,
                                                                  ●​ government entities and law
                            online    identifier, Internet
                                                                     enforcement
                            Protocol (IP) address, email
                            address,       or      similar        ●​ affiliates and subsidiaries
                            information.
                                                                  ●​ advertising networks

                                                                  ●​ data analytics providers

                                                                  ●​ social networks

                                                                  ●​ internet service providers

                                                                  ●​ operating      systems        and
                                                                     platforms

                                                                  ●​ business customer/client

                                                                  ●​ others as permitted or
                                                                     required by law (such as
                                                                     disclosures of sweepstake and
                                                                     contest winners)
                       Also includes identifiers such    ●​ advisors and agents
                       as passport number, drivers’
                                                         ●​ government entities and law
                       license or local identification
                                                            enforcement
                       card number.
                                                         ●​ affiliates and subsidiaries

                                                         ●​ others as permitted            or
                                                            required by law

Categories of Personal Includes records containing       ●​ advisors and agents
Information Described Personal Information, such as
                                                         ●​ government entities and law
in Cal. Civ. Code § name,        product     reviews,
                                                            enforcement
1798.80                address and telephone number.
                                                         ●​ affiliates and subsidiaries

                                                         ●​ internet service providers

                                                         ●​ operating      systems        and
                                                            platforms

                                                         ●​ business customer/client

                                                         ●​ others as permitted            or
                                                            required by law

Commercial             Includes products or Services     ●​ advisors and agents
Information            purchased,    obtained,     or
                                                         ●​ government entities and law
                       considered,     or       other
                                                            enforcement
                       purchasing or use histories or
                       tendencies.                       ●​ affiliates and subsidiaries

                                                         ●​ advertising networks

                                                         ●​ data analytics providers

                                                         ●​ social networks

                                                         ●​ internet service providers

                                                         ●​ operating      systems        and
                                                            platforms

                                                         ●​ business customer/client

                                                         ●​ others as permitted            or
                                                            required by law
Internet    or    Other Includes information regarding   ●​ advisors and agents
Electronic     Network your use of our Site such as
                                                         ●​ government entities and law
Activity Information    browsing history, clickstream
                                                            enforcement
                        data, search history, and
                        information          regarding   ●​ affiliates and subsidiaries
                        interaction with our Sites,
                        advertisements,      including   ●​ advertising networks
                        access logs and other activity
                                                         ●​ data analytics providers
                        information related to the use
                        of our Services.                 ●​ social networks

                                                         ●​ internet service providers

                                                         ●​ operating      systems        and
                                                            platforms

                                                         ●​ business customer/client

                                                         ●​ others as permitted            or
                                                            required by law

Geolocation Data        Includes general location        ●​ advisors and agents
                        information about a particular
                                                         ●​ government entities and law
                        individual or device
                                                            enforcement
                        ​
                                                         ●​ affiliates and subsidiaries

                                                         ●​ internet service providers

                                                         ●​ operating      systems        and
                                                            platforms

                                                         ●​ others as permitted            or
                                                            required by law

Audio,       Electronic, Includes audio, electronic,     ●​ advisors and agents
Visual, Thermal, or visual, thermal, olfactory, or
                                                         ●​ government entities and law
Similar Information      similar information such as,
                                                            enforcement
                         photographs and images (e.g.,
                         that you provide us) and call   ●​ affiliates and subsidiaries
                         recordings (e.g., of customer
                         support calls).                 ●​ others as permitted            or
                                                            required by law
Characteristics         of Includes characteristics of       ●​ advisors
Protected                  protected classifications under
                                                             ●​ government entities and law
Classifications            California and federal laws
                                                                enforcement
                           such as date of birth, gender,
                           national origin, citizenship.     ●​ affiliates and subsidiaries

                                                             ●​ internet service providers,
                                                                operating    systems   and
                                                                platforms

                                                             ●​ data analytics providers

                                                             ●​ others as permitted            or
                                                                required by law

Profiles and Inferences Includes inferences drawn            ●​ advisors and agents
                        from       other       Personal
                                                             ●​ government entities and law
                        Information that we collect to
                                                                enforcement
                        create a profile reflecting an
                        individual’s preferences             ●​ affiliates and subsidiaries

                                                             ●​ advertising networks

                                                             ●​ data analytics providers

                                                             ●​ social networks

                                                             ●​ internet service providers

                                                             ●​ operating      systems        and
                                                                platforms

                                                             ●​ business customer/client

                                                             ●​ others as permitted            or
                                                                required by law

Sensitive         Personal Includes precise geolocation,     ●​ advisors and agents
Information                passport number, driver’s
                                                             ●​ government entities and law
                           license or identification card
                                                                enforcement
                           number, age and gender.
                                                             ●​ affiliates and subsidiaries

                                                             ●​ internet service providers
                                                                ●​ others as permitted           or
                                                                   required by law

14.2.​   Sale and Sharing of Personal Information. Additionally, the CCPA defines "sale" as
         disclosing or making available to a third-party Personal Information in exchange for
         monetary or other valuable consideration, and “sharing” includes disclosing or making
         available Personal Information to a third party for purposes of cross-contextual behavioral
         advertising.

                   While we do not disclose Personal Information to third parties in exchange for
                   monetary compensation, we may disclose the following categories of Personal
                   Information: identifiers, profiles and inferences, and internet or other electric
                   network activity information to third-party advertising networks, analytics
                   providers, and social networks for purposes of marketing and advertising.

                   We do not sell or share Sensitive Personal Information, nor do we sell or share
                   any Personal Information about individuals who we know are under sixteen (16)
                   years old.

14.3.​   Sources of Personal Information. As further described in Section 3: Personal Data We
         Collect, we collect Personal Information from the following sources: directly from you;
         advertising networks; data analytics providers; social networks; internet service providers;
         operating systems and platforms; affiliated entities; and government entities.

14.4.​   Retention. We retain the Personal Information we collect only as reasonably necessary for
         the purposes described above or otherwise disclosed to you at the time of collection. We
         retain Personal Information as necessary to comply with our tax, accounting and
         recordkeeping obligations, to provide you with the services you have requested, as well as
         an additional period of time as necessary to protect, defend or establish our rights, defend
         against potential claims, and comply with our legal obligations. In some cases, rather than
         delete your Personal Information, we may deidentify or aggregate it and use it in
         compliance with the CCPA.

14.5.​   Purposes for Collecting, Using, Disclosing, and Processing Personal Information. As
         more fully described in the Section 4: How We Use Personal Data, we collect, use, and
         otherwise process the above categories of Personal Information to provide our Services to
         you, respond to and fulfill your requests, as otherwise directed or consented to by you, and
         for the following business and commercial purposes: to provide Services and support,
         communications, analytics and improvement, customization and personalization, marketing
         and advertising, events, research and studies, security and the protection of rights, legal
         proceedings and obligations, and general business and operational support.

14.6.​   Sensitive Personal Information. We do not use or disclose of Sensitive Personal
         Information beyond the purposes authorized by the CCPA.
 14.7.​   California Residents Rights. The CCPA provides you with certain rights regarding your
          Personal Information. Please note that these rights are subject to certain conditions and
          exceptions.

 14.8.​   Right to Know/Request Access. With respect to the Personal Information we have collected
          about you in the prior twelve (12) months, you have the right to know:

                   14.8.1.​ The categories of Personal Information we collected about you;

                   14.8.2.​ The categories of sources from which we collected your Personal
                            Information;

                   14.8.3.​ The business or commercial purposes for collecting, selling, or sharing
                            your Personal Information;

                   14.8.4.​ The categories of third parties to whom we have disclosed your Personal
                            Information; and

                   14.8.5.​ The specific pieces of your Personal Information we have collected.

 14.9.​   Right to Delete. You have the right to request we delete your Personal Information.

14.10.​   Right to Correct. You have the right to request that we correct inaccuracies in your
          Personal Information.

14.11.​   Right to Opt-Out of Sales and Sharing. You have the right to opt-out of “sales” and
          “sharing” of your Personal Information, as those terms are defined under the CCPA.

14.12.​   Right to Limit Use of Sensitive Personal Information. We do not engage in uses or
          disclosures of “Sensitive Personal Information” that would trigger the right to limit use of
          Sensitive Personal Information under the CCPA.

14.13.​   Right to Non-Discrimination. We will not discriminate against you for exercising any of
          the rights described in this section.

14.14.​   Exercising Your Rights. If you are a California resident and would like to exercise your
          CCPA rights, you may do so via any of the methods described below:

                    Calling us at 1-800-921-2240

                    Emailing us at [privacy@teramot.com]

14.15.​   Verification. Before responding to your request, we must first verify your identity using the
          Personal Information you recently provided to us. We will take steps to verify your request
          by matching the information you provided with the information we have in our records. In
          some cases, we may request additional information in order to verify your identity, or
          where necessary to process your request. If we are unable to verify your identity after a
          good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

14.16.​   Authorized Agents. You may designate someone as an authorized agent to submit requests
          and to act on your behalf. Authorized agents will be required to provide proof of their
          authorization. We may also require that the relevant consumer directly verify the authorized
          agent's identity and authority.

 15.​     BRAZILIAN PRIVACY STATEMENT

    In short, these terms that apply to you if you are a located in Brazil resident.

    Data collected and/or processed in Brazil, or other data processed in relation to people and/or
    Services located in Brazil, shall be also subject to the provisions of Brazilian General Data
    Protection Law (Law nr. 13.709/2018 – Lei Geral de Proteção de Dados Pessoais or LGPD). Any
    requests regarding data protection in Brazil shall be directed to the email [privacy@teramot.com].
    Our person “in charge” (encarregado, in accordance with Art. 41, §1º, LGPD) is Federico
    Ceccatto.

 16.​     WILL WE MAKE CHANGES TO THIS POLICY?

    In short, Yes, update this notice as necessary to stay compliant with relevant laws.

    If we change or update our Policy, we will post those changes on this page. Your continued use of
    the Site and Services is subject to our most up-to-date Policy, posted here. If we make any
    material changes, we may notify you by means of a notice on our Site.

 17.​     CONTACT US

    In short, contact us at [privacy@teramot.com]

    For us, your data privacy is very important. If you have questions or concerns regarding the way
    in which your personal data is being processed or this Policy, please email us at
    [privacy@teramot.com] or via the contact information below:​
    Halley LLC. [25SW 9th St, Suite 406, Miami, FL, 33130].