At AllVoices Holding Co, (“AllVoices,” “we,” or “us”) your privacy is important to us. This Privacy Policy is designed to explain how we collect, use, and disclose information in connection with our website (“the Site”) and the Employee Feedback Management Platform (“Platform”). The terms “AllVoices,” “we,” and “us” include AllVoices and our affiliates and subsidiaries.

Through the Platform, AllVoices provides employees with an outlet for reporting whistleblower, compliance, and other feedback about their employer. AllVoices forwards these reports to the respective employer even when we do not have a relationship with that business. In these instances, AllVoices is responsible for the personal information we collect. By using the Site or Platform (together, the “Services”), you agree to the terms and conditions of this Privacy Policy. Beyond the Privacy Policy, your use of the Services is also subject to our Terms of Service.

Allvoices also provides the Platform services directly to business customers who purchase our services. When business customers engage us to provide our reporting services to their employees, we collect their information and that of other individuals, including Incident Information and Company Information (as defined below), through our Platform available on this Site, and we principally use this information as a service provider on the respective companies’ behalf and at their direction to provide our services on the Platform.  Please see the Information We Collect as a Service Provider section below for information on our use and disclosure of personal information when we act as a service provider.

Information You Provide Us

When you use the Services, we collect information from you such as:

• Telephone number.
• Incident Information: We collect information regarding the incident you witnessed or experienced, including the type of incident (e.g., sexual advances, subtle bias, culture issues, illegal acts); whether you experienced the incident firsthand or witnessed it happening to someone else; and when the incident occurred.
• Company Information: We collect information about the company at which the incident occurred, including the name of the company; the office and department in which the incident occurred; how often you have experienced or witnessed an incident at the company, and your status at the company at the time of the incident.
• Demographic Information: We may collect information about the person subject to the incident.
• Communications: If you contact us directly, we may receive additional information about you. For example, when you chat or email our Customer Support Team, we will receive your email address, the contents of a message or attachments that you may send to us, and other information you choose to provide.

If you choose to provide any additional information to us in connection with your report, we collect that information as well.

We also collect personal information from our business customer contacts and administrators, including name, business contact information, and account login information.

We also collect information about prospective business customers who are interested in our employee feedback and reporting products and services. When you request a demonstration or seek information about our products and services, we collect your email address, company name, company size, and position title.

Information We Collect Automatically From Your Use of the Site

When you visit or use our Site, such as for reporting whistleblower, compliance, and other feedback about a company, we and our third-party service providers may collect information from you through automated means, such as cookies, web beacons, and web server logs. By using the Site, you consent to the placement of cookies, beacons, and similar technologies in your browser in accordance with this Privacy Policy. The information collected in this manner includes IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, and information about the usage of our Site.

We may use this information, for example, to ensure that the Site functions properly, to determine how many users have visited certain pages, or to prevent fraud. We use IP address to derive your approximate location.

We use analytics providers such as Google Analytics, which use cookies and similar technologies to collect and analyze information about use of the Site and report on activities and trends. The services may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

We also may use network advertisers to serve advertisements on unaffiliated websites and other media (e.g., social networking platforms). This enables us and these network advertisers to target advertisements to you for products and services in which you might be interested, including our own. Ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These cookies and other technologies are governed by each entity's specific privacy policy, not this one. We may provide these parties with information, including personal information about you, as part of our advertising efforts.

Users may opt out of many ad networks. For example, you may go to the Digital Advertising Alliance ("DAA") Consumer Choice Page for information about opting out of interest-based advertising and choices regarding information used by DAA member companies. You may also go to the Network Advertising Initiative ("NAI") Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members. [DJ1]  Opting out from one or more ad networks will opt you out from those companies' delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising online. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA's website at www.aboutads.info or the NAI's website at www.networkadvertising.org.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Site.

How We Use Your Information

We may use personal information for the following purposes when we are responsible for how personal information may be used.

• We use your telephone number to verify that you are a real person when you create a report on the Site. We also use your telephone number to follow up with you about your report.
• We use Incident Information, Company Information, and in some cases, Demographic Information to report information about incidents to affected companies.

We also use your information:

• To operate, maintain, enhance and provide features of the Site, to provide services and information that you request, to respond to comments and questions, and otherwise to provide support to users.
• To understand and analyze the usage trends and preferences of our users, to improve the Services, and to develop new products, services, features, and functionality.
• To research and analyze patterns of sexual harassment and discrimination in the workplace, and develop reports and research materials.
• For marketing purposes (in an aggregated or de-identified way), such as for developing and providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest.
• To contact or market to prospective business customers who have requested product demonstrations or information about products and services.
• For our business purposes, such as audits, security, fraud monitoring and prevention.
• To identify potential subject matter and informational resources to you that may pertain to the Company Information or Incident information you have provided.
• To enforce our Terms of Service or other legal rights.

We may use de-identified or aggregate data that does not identify individuals for any purpose and the use and disclosure of such information is not subject to any restrictions contained in this privacy policy.

How We Share Your Information

We may share personal information for the following purposes when we are responsible for how personal information may be disclosed. We may share Company Information and Incident Information with affected companies, including with individual company employees who have been designated as administrators. We also share information that we collect through the Site with third parties in the following circumstances:

• With our affiliates and subsidiaries.
• With our third-party service providers who provide services such as website hosting, data analysis, information technology and related infrastructure provision, auditing, and other services.
• With a potential or actual acquirer, successor, or assignee as part of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in bankruptcy or similar proceedings).
• If required to do so by law or in the good faith belief that such action is appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

We may use and disclose information that does not identify an individual for any purpose, except where we are required to do otherwise under applicable law.

Information We Collect as a Service Provider

As described above, we also provide our Platform and related services to business customers. In these instances, our business customer is responsible for how personal information is collected, used, and disclosed. We use and disclose the personal information that we collect in our capacity as a service provider, including Incident Information, Company Information and Demographic Information, as directed by our business customers to provide our services.  If you have a question about how a business customer may use or disclose personal information or to exercise any privacy rights available under applicable laws, you should refer to your employer’s or the respective company’s respective notices or policies or contact them directly. Where permitted by our customer agreements, we may create de-identified or aggregate information from this business customer information.

Storage and Retention of your Information

The information we collect is processed and stored in the United States by AllVoices for the purposes described herein. As described above, we also may subcontract the processing of your data to, or otherwise share your data with, other members within AllVoices, trusted service providers, and trusted business partners in the United States and other countries. Such third parties may be engaged in, among other things, the provision of Services to you, the processing of transactions and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage or use.

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws. Where we act as a service provider, our retention of information is governed by our customer agreements.

California Privacy Rights

Shine the Light. California law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined by applicable California law) with third parties for their direct marketing purposes. However, AllVoices does not share your personal information with third parties for their own direct marketing purposes.

Notice concerning Do Not Track. AllVoices does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Site links or the privacy or other practices of our business customers. The inclusion of a link on the Site does not imply endorsement of the linked site or service by us or by our affiliates.

Security

We use certain physical, organizational, and technical safeguards that are designed to aid in maintaining the integrity and security of information that we collect. Please be aware that no security measures are perfect or impenetrable and thus we cannot and do not guarantee the security of your data. To report any security concerns, or for any data subject requests, please email privacy@allvoices.co.

Use of Site by Minors

The Services are intended for general audiences and not for anyone under the working age in their jurisdiction and not for children under the age of thirteen (13). We request that children under 13 not provide personal information through the Services. If we become aware that we have collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without legally-valid parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.

Updates to This Privacy Policy

We may make changes to this Privacy Policy. The “Last Updated” date at the top of this page indicates when this Privacy Policy was last revised. If we make material changes to our own use and disclosure of the personal information we previously collected about you, we may notify you in advance of such changes through the Services. We encourage you to read this Privacy Policy periodically to stay up to date about our privacy practices. Your use of the Site following these changes means that you accept the revised Privacy Policy.

Contact Us

Please also feel free to contact AllVoices if you have any questions about this Privacy Policy or AllVoices' practices, or if you are seeking to exercise any of your statutory rights. AllVoices will respond within a reasonable timeframe. You may contact us at privacy@allvoices.co."