Privacy Policy

Last Updated: October 11, 2024

Sellona, Incorporated (collectively, “ Sellona,” “ we,” “ our,” or “ us”) is committed to maintaining your confidence and trust in the privacy and security of your personal information. This Privacy Policy describes how we use, disclose,ƒ√ƒ and protect the personal information collected:

• through our website, www.Sellona.com, and any other websites or mobile apps where this Privacy Policy is posted or linked (collectively, the “Digital Properties”) and any services available through the Digital Properties;
• in connection with the delivery of our products and services to our customers;
• in connection with our business development and marketing activities, and
• through our other offline and business interactions.

Collectively, we refer to our online and offline interactions with you as the “ Services.”

Please carefully review this Privacy Policy to learn more about how we handle information and our privacy practices.

1. WHAT IS PERSONAL INFORMATION

Personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual or household. It does not include aggregated or de-identified information that is maintained in a form that is not capable of being associated with or reasonably linked to an individual.

1. PERSONAL INFORMATION WE COLLECT

Depending on your use of the Services and how you otherwise interact with us, we may collect or obtain information from and about you in several ways, including (A) directly from you, (B) automatically when you visit and interact with the Digital Properties; or (C) from third parties. Additional details regarding our collection of your personal information are included below.

1. Information provided by you

When you visit and interact with the Digital Properties or otherwise engage with us, we collect personal information that you share with us. For example, we may collect personal information when you contact us (via phone, web, email, etc.), request that we send you promotional communications or other materials, or otherwise communicate with us.

Depending on the context of your interactions with us and the Services, the categories of personal information that we may collect directly from you include:

• Contact information, including your name, street address, telephone number, and email address.
• Identifying information, including your Sellona account name and other similar identifiers.
• Correspondence and communications, including any correspondence related to the Services we provide you.
• Preferences, including how frequently you wish to receive marketing and promotional communications from us.
• Other information you choose to provide, including information you post on message boards or other user communications you submit to the Digital Properties and other information that you provide during your interactions with us.

• Information about other individuals. Some personal information that we receive from you may relate to other individuals. You are responsible for obtaining all necessary permissions to provide us with personal information relating to other individuals.

• Information collected through automated means

When you visit and interact with the Digital Properties, we (and our service providers, advertisers, and partners) may use cookies, pixels, web beacons, and other similar tracking technologies to collect certain information automatically. The specific types of information we (and our service providers and partners) may collect include:

• Device information includes the Internet Protocol (IP) address or other unique identifier(s) assigned to your device, the location of your device, and other information about your browser, device, and operating system.
• Usage information, which includes information about your interaction(s) with the Digital Properties (e.g., the date and time of your visit(s); the area(s) or page(s) that you visit; the amount of time you spend on a page or use the Digital Properties; the domain name from which you accessed the Digital Properties; and other click-stream or usage information).

• Behavioral information includes information about your behavior on the Digital Properties (e.g., how you move and scroll through the Digital Properties, your keystrokes, how you interact with webforms, etc.) and the actions you take upon receiving an email from us.

• Information we collect through third parties

• Analytics. We use third-party analytics and tracking tools to better understand who is using the Digital Properties, how they are used, and how to improve their effectiveness and related content. We may also use the information collected to draw inferences.

• Google Analytics. We use Google Analytics (or similar) to better understand how users interact with the Digital Properties. For information on Google Analytics’ information-handling practices and how you can control the use of information sent to Google, visit https://policies.google.com/technologies/partner-sites. If you wish to prevent your information from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout.
• Targeted advertising. We use third-party tools and services to serve targeted advertisements to you across the internet. These tools may include cookies, pixels, web beacons, or similar tracking technologies that automatically collect, store, or transmit certain information about your interaction(s) with the Digital Properties and other websites and mobile apps you interact with and use across your devices. Our third-party service providers and partners use the collected information to serve advertisements to you and measure the performance of our advertising campaigns. To learn more about your targeted advertising choices, see the “Your Choices” section below. You may be able to adjust your device or browser settings to limit certain tracking or to decline cookies.
• ChatBot Technology. We may use chatbots on certain Digital Properties to help provide customer service and support, including through a virtual assistant. A chatbot is a software application that mimics human conversations in text or voice interactions on our website. It enables communication between a human and a machine, which can take the form of messages or voice commands. The chatbot is designed to work without the assistance of a human operator. It responds to questions posed to it in natural language as if it were a real person using a combination of pre-programmed scripts, machine learning, and generative artificial intelligence (“AI”). When asked a question, the chatbot will answer using the knowledge database that is currently available to it. If the conversation introduces a concept the chatbot is not programmed to understand, it will advise of its limitations. The chatbot functionality is limited to Sellona customer service and support inquiries and may not be monitored in real-time. If you use our chatbot service, we will collect and maintain any information you provide to us when using the chatbot. You are responsible for the information you share with the chatbot, and we strongly advise you not to input sensitive or personal information, such as financial or account details or other confidential information. We will also create and store a transcript of your chat interaction with us, which our third-party service provider will store. We may use these transcripts and the information you provide for quality control, customer service, fraud prevention, and security.

• Information collected from other third-party sources. We may obtain your personal information from other sources, including, for example, our service providers, advertisers, lead generators, Network Partners (as defined below), and other partners.

• Combined Information

We may combine personal information that we receive from and about you, including information you provide to us, information we automatically collect through the Digital Properties, and information we receive from third-party sources. Where applicable, we will use, disclose, and protect the combined information for the purposes described in this Privacy Policy.

1. HOW WE USE PERSONAL INFORMATION

We may use personal information we collect for the following business purposes:

• Providing the Services, including entering into or performing our contract with you, operating, maintaining, supporting, and providing the Services, auditing or monitoring your transactions, and undertaking activities to verify or maintain the quality or safety of our Services or to improve, upgrade, or enhance them.

Maintaining or servicing accounts, including providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytic services, providing storage, or providing similar services.

• Communicating with you, including to contact you for administrative purposes (e.g., to provide the Services and information that you request or to respond to your comments and questions) or to send you important updates and communications about this Privacy Policy or other applicable terms and conditions.
• Sending you marketing and promotional communications, including emails about products or services that may interest you. Details on how to exercise your choices with respect to marketing and promotional communications from us can be found in the "Your Choices" section below.
• Personalizing the Services, including tailoring the content we may send or display to you and otherwise personalize your experience with us.
• Advertising and marketing, including to provide you with targeted advertising on the Digital Properties or on other online services across the devices you may use. Details on how to exercise your choices with respect to targeted advertising can be found in the “Your Choices” section below.
• Conducting research and analytics to develop and improve the Services, including analyzing usage trends and preferences to improve the Services and to develop new products, services, and features.
• Maintaining security and preventing fraud, including monitoring and maintaining the security of our systems and networks, and detecting, preventing, investigating, and protecting you, our business, and others from fraud, unauthorized transactions, and other unlawful or unsafe activity.
• Satisfying our legal and regulatory obligations, including complying with applicable law and responding to lawful requests and communications from law enforcement authorities and other government officials.
• Conduct other activities for legitimate business purposes, including supporting our business operations and transactions, administering our general business and other related functions, and carrying out sales or other business transactions.
• With your consent. We may also use your personal information as described to you at the point of information collection or with your consent.

• To protect our rights and the rights of others. We may use your personal information as we believe necessary or appropriate to protect our rights, privacy, safety, property, or those of others.

• HOW WE DISCLOSE PERSONAL INFORMATION

We may disclose each category of personal information we collect from and about you with the following categories of recipients:

• Network Partners. We may disclose your personal information to certain service providers who offer services to our customers through the Digital Properties (“ Network Partners”) to provide you with information about financial products and services that may interest you. Network Partners that interact with you may use or retain your personal information whether or not you use their services. Their handling of your personal information is subject to their privacy policies.
• Our Business Partners. We disclose your personal information to other companies with whom we partner to provide the Services and carry out other activities described in this Privacy Policy.
• Our Service Providers. We disclose your personal information to third parties that provide us with business, professional, or technical support services or administer activities on our behalf. We only allow our service providers to handle your personal information if we are satisfied that they take appropriate measures to protect it. We also impose contractual obligations on service providers, contractors, and third parties to ensure they can only use your personal information to provide services to us and to you.
• Our Analytics Providers. We disclose your personal information to parties that help us perform analytics and measure the effectiveness of the Services and our marketing and advertising efforts.
• Our Marketing and Advertising Partners. We disclose your personal information to our marketing and advertising partners, including social media networks, third-party advertising networks, and other parties that assist us in serving, measuring the performance of, and optimizing our advertisements.
• Governmental and Public Authorities. We disclose your personal information to government and public authorities as necessary or permitted by the laws of any jurisdiction in which we operate, including in response to a subpoena, court order, investigative demand, request for cooperation from a law enforcement agency, or similar request from a self-regulatory body or government agency.
• Relevant Third Parties in Connection with a Business Transaction. We may disclose or otherwise transfer your personal information to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of any insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
• Other Third Parties. We may disclose your personal information to other third parties as we believe necessary or appropriate either to (1) comply with applicable law; (2) protect our operations and those of our affiliates and subsidiaries; (3) investigate and prevent fraud and other illegal activity; (4) protect our rights, privacy, safety, property, or those of others; or (5) allow us to pursue available remedies or limit damages that we may sustain.
• As Disclosed to You. We may disclose your personal information for other reasons described at the time of information collection or prior to disclosing your information.
• With your Consent. We may disclose your personal information with your consent or when you direct us to do so.

• De-identified, Anonymized or Aggregated Information. We may de-identify, anonymize, or aggregate personal information and disclose such information to third parties for various purposes as permitted by applicable law.

• Sale of Personal Information

We do not sell your personal information and will not do so in the future without giving you notice and an opportunity to exercise your rights. No mobile opt-in data will be shared with third parties.

• We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.
• All of the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

1. YOUR CHOICES

We respect your privacy and allow you to make certain choices about how we use your personal information, as described below.

• Marketing and Promotional Communications. You can opt-out of receiving marketing and promotional communications by emailing us at support@sellona.com. You can opt-out of receiving marketing and promotional communications from us by following the instructions included in any such communication that you receive from us. Note that even if you opt-out of receiving marketing and promotional communications from us, you will still receive non-marketing or transactional messages from us, including messages about your account and responses to your inquiries/requests.
• Cookies. As noted above, we (and our third-party providers and partners) use cookies for various purposes, including analytics and targeted advertising. You may be able to adjust your device or browser settings to limit certain tracking or to decline cookies. Refer to your device's settings or your browser's "Help" section for more information on how to delete cookies or disable your device or browser from receiving cookies or adjust your tracking preferences. Additional information about cookies, including how to manage and delete them, can be found here: https://allaboutcookies.org/.
• Targeted Advertising. We use services provided by Google, Meta, and similar companies that use tracking technologies to collect information about your online activities, preferences, and interactions with websites from you and across your devices. These services are used to serve targeted advertising to you and measure the performance of our advertising campaigns. For example, these services enable us to retarget you with advertisements based on what you have viewed or engaged with on our Digital Properties while you are using platforms provided by Google or Meta to measure when you have clicked through to our Digital Properties after seeing an advertisement on those or other platforms. Some websites/platforms and mobile devices allow you to exercise certain choices concerning targeted advertising, as described below.
  • Web browsers. You may be able to opt-out of receiving targeted advertising using the browser opt-out tools and consumer choice mechanisms provided by targeted advertising self-regulatory groups by following the links below:
    • Digital Advertising Alliance (DAA): https://optout.aboutads.info/?c=2&lang=EN
    • Network Advertising Alliance (NAI): https://optout.networkadvertising.org/?c=1

Note that you will need to opt-out separately on all of your browsers and devices, as each opt-out will apply only to the specific browser or device from which you opt-out. If you delete or reset your cookies, change browsers, or use a different device, any opt-out cookie may no longer work, and you will have to opt-out again.

• • Mobile devices. You can control whether you see targeted advertisements on your mobile device in the following ways:
    • Device Settings. Your device operating system may provide mechanisms that allow you to opt-in or opt-out of the use of information about your usage of mobile apps to deliver targeted advertising to your mobile device. For more information, consult your device settings.
    • AppChoices Tool. The DAA offers a tool for opting out of the collection of cross-app information on a mobile device for targeted advertising. To exercise your choices concerning participating companies, you may download the AppChoices tool, available here: https://youradchoices.com/appchoices.
    • Other choices. The advertising partners that we have listed below may provide you with additional choices with respect to targeted advertising, including the ability to control your advertising preferences directly through their services. We encourage you to review the privacy policies of the third-party services you use for more information regarding your choices.
      • Google: https://adssettings.google.com
      • Meta/Facebook: https://www.facebook.com/about/ads

• Access and Correct Personal Information. You may also be able to access and correct certain personal information. See Your Privacy Rights and How to Exercise Them, for more information.

• INFORMATION SECURITY

We maintain physical, electronic, and procedural measures designed to safeguard your personal information from unauthorized access and disclosure. However, no system can be completely secure. Therefore, although we take steps to secure your information, we cannot guarantee your information, searches, or other communications will always remain secure.

1. INFORMATION RETENTION

We will retain your personal information for at least as long as necessary to fulfill the purposes outlined in this Privacy Policy, including to satisfy our legal or reporting requirements, unless a longer retention period is required or allowed under law. We reserve the right to retain your personal information to the extent allowed by applicable law. We also reserve the right to provide access to or delete personal information only to the extent required by applicable law.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of personal information; the potential risk from deletion, unauthorized use, or disclosure of the personal information; the purpose(s) for which we use or may use the personal information; whether we can achieve the purpose(s) through other means; and the applicable legal requirements.

If we de-identify information, we will maintain and use the information in de-identified form and not attempt to re-identify the information except as required or permitted by law.

1. THIRD-PARTY WEBSITES

The Digital Properties may include links to or redirect you to third-party websites, plug-ins and applications, and social media services where you can connect with us. Third-party websites may also reference or link to our websites and online services. Except where we post, link to, or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any data privacy practices of third-party websites and online services or the practices of other third parties. To learn about the data privacy practices of these third parties, please visit their respective privacy policies.

1. CHILDREN’S PRIVACY

The Services are not intended for or directed to individuals under 18, and we do not knowingly collect personal information from individuals under 18.

1. SERVICES LIMITED TO THE UNITED STATES

Our Digital Properties are designed to provide services in the United States and are governed by the laws of the United States. All Services may not be available in all U.S. states or territories. We make no representation that our Digital Properties are governed by or operated in accordance with the laws of any other nation or foreign jurisdiction.

If you are a resident of California, Colorado, Connecticut, Utah, or Virginia in the United States, please see Your Privacy Rights and How to Exercise Them for more information about state-specific privacy rights.

California residents who have an established business relationship with us have rights to know how their personal information is disclosed to third parties for direct marketing purposes under California's "Shine the Light" law or to opt-out of such practices (Civ. Code §1798.83). To opt-out of this type of sharing, please see Your Choices for more information or contact us at support@sellona.com.

1. Your Privacy Rights and How to Exercise Them

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

• Your Privacy Rights:
• Confirm whether or not we are processing and accessing your personal information.
• Correct inaccuracies in your personal information.
• Delete personal information provided by or obtained about you.
• Opt-out of the processing of your personal information for targeted advertising.
• Opt-out of the sale of your personal information.
• Opt-out of profiling performed in furtherance of decisions that produce legal or similarly significant effects.
• Nondiscrimination. Depending on your state of residence, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate, or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.
• To Submit a Request. To submit a request to exercise one of the privacy rights identified above, please email us at support@sellona.com. We may need to verify your identity before processing your request. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. We will use personal information provided by you in connection with a rights request only to review and comply with the request.
• To Exercise Your Right to Opt-Out of Sharing for Targeted Advertising. Please see the Your Choices section of this Privacy Policy for more information about how to opt-out of sharing for targeted advertising.
• Submitting Authorized Agent Requests. In certain circumstances, you are permitted by law to use an authorized agent to submit requests on your behalf through the designated methods set forth above, where we can verify the authorized agent's authority to act on your behalf. To verify the authorized agent's authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residence, we may need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and verify your identity in connection with the request.

• Appealing Privacy Rights Decisions. Depending on your state of residence, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted via email to support@sellona.com.

• CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our information handling and privacy practices or changes in applicable law. The "Last Updated" date at the top of this page indicates when this Privacy Policy was last revised. If we make changes, we will revise the date at the top of this page, and in the case of material changes, we will provide you with additional notice if required by applicable law. Unless otherwise stated, the current version of this Privacy Policy applies to all Digital Properties and all personal information under our control. We encourage you to review this Privacy Policy periodically to remain informed about our information handling and privacy practices. By visiting or using our Digital Properties, you agree that any changes to this Privacy Policy shall apply to any personal information we may maintain about you, whether collected before or after such changes.

1. HOW TO CONTACT US

If you have any questions or comments about this Privacy Policy or our information handling and privacy practices, contact us using the following contact details:

Email: support@sellona.com

By mail: Sellona Incorporated, 6255 Old Dominion Dr. Suite 120 Mclean Va. 22101