Privacy Policy

This Privacy Policy explains how Profile Technologies Inc. and its core product, Human Intelligence, (together "Human Intelligence", "we", "our", and "us") collects, uses, discloses and otherwise processes your personal information (also known as personal data) in connection with the use of Human Intelligence websites and applications, including software, that link to this Privacy Policy (collectively, the "Sites" and individually, "Websites" or "Applications"), our people data governance platform products and services (the "Platform Services") and in the usual course of business, such as in connection with our events, sales, and marketing activities (collectively, with Sites and Platform Services, "Services"). It also contains information about your choices and privacy rights.

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If you are a California resident, the California Consumer Privacy Act ("CCPA") requires us to provide you with additional information regarding your rights with respect to your "personal information." This information is described in our Supplemental Privacy Notice to California Residents below.

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Our Services

We provide the Platform Services to our customers (collectively, "Customers") under an agreement with them and solely for their benefit and the benefit of their personnel authorized to access and use the Platform Services ("Authorized Users"). Our Platform Services unify people and HR data from our Customers' connected source systems (such as Workday, Lattice, Greenhouse, Culture Amp, and similar systems) and provide governed access, policy enforcement, row-level security, and audit logging to enable analysis and AI-assisted workflows on behalf of our Customers.

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Our processing of Customer employee, candidate, and other workforce data on behalf of our Customers (which may include performance, compensation, demographic, and protected characteristic information) is governed by our agreement with the relevant Customer, including our Data Processing Agreement. In that context, our Customer is the controller of such data and we act as a processor.

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This Privacy Notice does not apply to: (i) the data that our Customers and their Authorized Users upload, submit, or otherwise make available to the Platform Services and other data that we process on their behalf, as defined in our agreement with the Customer — for those data subjects, please refer to the privacy notice of the Customer (typically your employer); (ii) any products, services, websites, or content that are offered by third parties or that have their own privacy notice; or (iii) personal information that we collect and process in connection with our recruitment activities, which is covered under our Applicant Privacy Notice if and when published.

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We recommend that you read this Privacy Notice in full to ensure that you are informed. The sections below describe:

• • Information We Collect About You
  • How We Use Your Information
  • How We Disclose Your Information
  • International Users and Transfers
  • Your Choices and Rights
  • Other Important Information
  • Changes to this Notice
  • How to Contact Us

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Information We Collect About You

Information that we collect from or about you includes information you provide, information we collect automatically (e.g., as you use the Services), and information we receive from other sources.

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Information you provide

When using our Services, we may collect certain information, such as:

• Identifiers: We collect your name, email address, phone number, postal address and country to administer your account and provide our Services to you.
• Professional / employment-related information: We also collect information about your job title, role, function, and company name.
• Account information: If you create an account on the Services, we will collect your authentication information used to access the Services.
• Customer service and other interaction information: We will collect information when you interact and communicate with us, for example, when you request information about our Platform Services through our website forms (including our "Talk to Us" and white paper request forms), interact with our sales team or contact customer support, complete a survey, provide feedback, register for an event, or take part in marketing activities. We may keep a record of your communications with us and other information you disclose during the course of such communications (which may be stored as an audio file or transcript).
• Commercial information: We keep records of your history of past purchases and transactions with us.
• Financial information: We collect information about your designated payment method(s), which may be collected by our third-party payment and billing service providers.

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Information we collect automatically

We use standard automated data collection tools, such as cookies, web beacons, tracking pixels, tags, and similar tools, to collect Internet and device activity information about how people use our Sites and interact with our emails.

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For example, when you visit our Sites we (or an authorized third party) may collect certain information from you or your device. This may include information about your computer or device (such as operating system, device identifier, browser language, and Internet Protocol (IP) address), and information about your activities on our Sites (such as how you came to our Sites, access times, the links you click on, browsing behavior, clicks and cursor movements, and other statistical information). We use this information to help us understand how you are using our Sites and how to better provide the Sites to you. We may also use web beacons and pixels in our emails — for example, to notify us when you click on a link in the email. We may also use your IP address to derive your general location information.

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When you use our Platform Services or other Applications, we automatically collect certain information about how you are using those services ("Usage Data"). While most Usage Data is not personal information, it may include information about your account (such as user ID, email address, or IP address) and information about your computer or device (such as browser type and operating system). It may also include information about your activities in connection with the Platform Services, such as the pages or features you access or use, queries executed, time spent on pages or features, and other statistical information. We collect Usage Data to provide, support, and operate the Services, for network and information security, to better understand how our Platform Services are used, and to improve our products and services more generally.

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We may also use the information we collect automatically (for example, IP address and unique device identifiers) to identify the same unique person across Services to provide a more seamless and personalized experience to you.

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The types of data collection tools we use may change over time as technology evolves. You can learn more about our use of cookies and similar tools, as well as how to opt out of certain data collection, by visiting our Cookie Notice (if and when published).

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Information we receive from other sources

We may obtain information about you from third-party sources, including resellers, distributors, business partners, event sponsors, security and fraud detection services, social media platforms, and publicly available sources. Examples of information we receive from third parties include marketing and sales information (such as name, email address, phone number, and similar contact information) and information about your interactions with our Sites and Platform Services. We may combine such information with the information we receive and collect from and about you in ways consistent with this Privacy Notice.

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How We Use Your Information

We use your personal information to provide, maintain, improve, and update our Services. Our purposes for collecting your personal information include:

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To Provide the Services

• to provide, maintain, deliver, and update the Services;
• to create and maintain your Human Intelligence account;
• for billing, payment, or account management — for example, to identify your account and correctly identify your usage of our products and services;
• to provide you with customer service and support.
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Sales and Marketing

• for sales phone calls for training and coaching purposes, quality assurance, and administration (in accordance with applicable laws), including to analyze sales calls using analytics tools to gain better insights into our interactions with customers;
• to tailor and send you newsletters, emails, and other content to promote our products and services (you can always unsubscribe from our marketing emails by clicking the unsubscribe link in those communications) and to allow third-party partners (such as event sponsors) to send you marketing communications about their services, in accordance with your preferences and applicable law.
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To Communicate with You

• to send you notifications about the Services, including technical notices, updates, security alerts, administrative messages, and invoices;
• to respond to your questions, comments, and requests, including to keep in contact with you regarding the products and services you use;
• to contact you to conduct surveys, receive your feedback, conduct audits, and for market research purposes.
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Online Advertising

• for online advertising purposes — for example, to display and measure advertising on third-party websites.
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Personalization and Service Improvement

• to personalize your experience when using our Services;
• to measure your use of and improve Services, and to develop new products and services;
• to generate and analyze statistical information about how our Sites and Platform Services are used in the aggregate.
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Legal and Security Purposes

• to investigate security issues, prevent fraud, or combat the illegal or unauthorized use of our products and services;
• to comply with our obligations under applicable law, legal process, or government regulation.
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With Your Consent

• We will also use your information for other purposes where you have given consent for such uses.

To engage in these uses of your information, we may use tools such as large language models and other forms of artificial intelligence in accordance with applicable law. We do not use our Customers' employee, candidate, or workforce data submitted to the Platform Services to train our underlying AI models, except where expressly permitted by the agreement with the relevant Customer.

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De-Identified / Anonymized Information. We may de-identify or anonymize information we collect so the information cannot reasonably identify you or your device, or we may collect information that is already in de-identified or anonymized form. Except as otherwise prohibited by applicable law, our use and disclosure of de-identified and anonymized information is not subject to any restrictions under this Privacy Notice, and we may use and disclose it to others for any purpose, without limitation.

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How We Disclose Your Information

We may disclose your personal information to third parties as follows:

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• Affiliates: to our affiliates and subsidiaries for the purposes described in this Privacy Notice.
• Service Providers and Sub-Processors: to our service providers and sub-processors who assist us in providing the Services, such as cloud infrastructure and hosting, database services, authentication, AI/ML processing, billing and payment processing, customer support, sales and marketing, and data analysis. These providers are subject to appropriate contractual restrictions on their use of your information. A current list of our material sub-processors is available on request and is described in our Data Processing Agreement with Customers.
• Third-Party Partners and Sponsors: to third-party business partners, such as resellers, distributors, and/or referral partners, who are involved in providing content, products, or services to our prospects or Customers. We may also engage with third-party partners who are working with us to organize or sponsor an event you have registered for, to enable them to contact you about the event or their services (but only where we have a lawful basis to do so, such as your consent where required by applicable law).
• Online Advertising Partners: to online advertising providers that tailor online ads to your interests based on information they collect about your online activity over time and across different services.
• For Legal Purposes: when authorized by law or where we deem necessary in good faith to comply with legal process; when required to protect and defend the rights or property of Human Intelligence or our Customers, including the security of our Sites, products, and services; or when necessary to protect the personal safety, property, or other rights of the public, Human Intelligence, or our Customers.
• With Your Consent: when you instruct us to do so or where you have consented to the disclosure of your information with third parties.
• Business Transactions: we may engage in transactions with other companies involving the sale of assets or parts of our business. We may disclose your information as part of, or in contemplation of, such transactions. If a portion or all of our assets are transferred to a third party in connection with such transactions, your information may be among the transferred assets, including in the course of activities leading up to such transactions (e.g., transaction diligence).

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International Users and Transfers

Human Intelligence may transfer your personal information to countries other than your country of residence. In particular, we may transfer your personal information to the United States and other countries where our affiliates, business partners, and service providers are located. These countries may have different data protection laws to the country where you reside.

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Wherever we process your personal information, we take appropriate steps to ensure it is protected in accordance with this Privacy Notice and applicable data protection laws. The safeguards we use include implementing the European Commission's Standard Contractual Clauses for transfers of personal information from the EEA or Switzerland between us and our business partners and service providers, and equivalent measures for transfers of personal information from the United Kingdom and other global jurisdictions with similar transfer requirements. Human Intelligence also offers our Customers the ability to enter into a Data Processing Agreement (DPA) that contains standard contractual clauses for transfers between us and our Customers. We also make use of supplementary measures to ensure your information is adequately protected.

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Information for EU, UK, and Swiss Users

If you are located in the European Economic Area, United Kingdom, or Switzerland, the controller of your personal information is Profile Technologies Inc., 1401 Pennsylvania Avenue, Suite 105, Wilmington, DE 19806, United States.

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We only collect your personal information if we have a legal basis for doing so. The legal basis that we rely on depends on the personal information concerned and the specific context in which we collect it. Generally, we collect and process your personal information where:

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• We need it to enter into or perform a contract with you, such as to provide you with the Services, respond to your request, or provide you with customer support;
• We need to process your personal information to comply with a legal obligation (such as to comply with applicable legal, tax, and accounting requirements) or to protect the vital interests of you or other individuals;
• You give us your consent, such as to receive certain marketing communications; or
• Where we have a legitimate interest, such as to respond to your requests and inquiries, to ensure the security of the Services, to detect and prevent fraud, to maintain, customize, and improve the Services, to promote Human Intelligence and our Services, and to defend our interests and rights.

You have a right to lodge a complaint with your local data protection authority regarding our data processing activities.

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Your Choices and Rights

We offer you choices regarding the collection, use, and disclosure of your personal information and we will respect the choices you make in accordance with applicable law. Please note that if you decide not to provide us with certain personal information, you may not be able to access certain features of the Sites or use the Platform Services.

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Account information

If you want to correct, update, or delete your account information, please contact us at privacy@humanintelligence.com.

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Opt out of marketing

We may periodically send you marketing communications that promote our products and Services consistent with your choices. You may opt out from receiving such communications either by following the unsubscribe instructions in the communication you receive or by emailing us at privacy@humanintelligence.com. Please note that it may take us some time to process your request in accordance with applicable law, and we may still send you important service-related communications regarding our products or services, such as communications about your subscription or account, service announcements, or security information.

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Your privacy rights

Depending upon your place of residence, you may have rights in relation to your personal information. For example, residents of certain U.S. states and residents of the EU, UK, and Switzerland can exercise the following rights, depending on the laws of your jurisdiction:

• Access to, or a copy of, your information (where feasible, in a portable, machine-readable form);
• Confirmation that we are processing your information;
• Correction or amendment of your information;
• Deletion of your information;
• Transfer of your information to a third party, where technically feasible;
• Restriction or objection to certain uses of your information (e.g., opt out of marketing communications);
• The withdrawal of consent to processing your information for certain purposes that were originally based on your consent;
• Opt out of the processing of your personal information for profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.

If you (or an authorized agent acting on your behalf) wish to exercise any of your rights under applicable data protection laws, please submit a request to privacy@humanintelligence.com. We will respond to requests we receive in accordance with applicable laws. Human Intelligence may take certain steps to verify your request using information available to us, such as your email address or other information associated with your Human Intelligence account, and if needed we may ask you to provide additional information for verifying your request. Any information you provide to us for verification purposes will only be used to process and maintain a record of your request.

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If you have made a request to access, delete, or correct your personal information and we deny your request, depending on your place of residence you may have the ability to appeal our denial. You can exercise this right by contacting us at privacy@humanintelligence.com. If an appeal right is applicable to you, we will let you know in our response.

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As described above, we may also process personal information that has been submitted by a Customer to our Platform Services. If your personal information has been submitted to the Platform Services by or on behalf of a Human Intelligence Customer (typically your employer) and you wish to exercise your privacy rights, please direct your request to the relevant Customer. We will assist Customers in responding to such requests as set out in our Data Processing Agreement with them.

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Notice of Right to Opt Out of Data "Sales" and "Targeted Advertising"

If you are a U.S. resident and depending on the state in which you live, you may have the right to opt out of the "sale" of your personal information or the disclosure of your personal information for purposes of online targeted advertising. We do not "sell" personal information in the traditional sense of exchanging information for monetary payment. However, because the definitions of "sale" and "targeted advertising" under applicable law may include the disclosure of your information (which includes your identifiers and Internet and device activity) to certain types of advertising and marketing partners, we provide the right to opt out of these activities. You may opt out of these activities based on cookies and similar online identifiers by visiting our "Your Privacy Choices" link on our website footer (when available) or by enabling a browser-based opt-out signal, which we will also comply with where legally required. You may opt out of these activities based on other identifiers (such as your email address) by emailing privacy@humanintelligence.com.

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Other Important Information

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Notice to California Residents

If you are a California resident, you have additional rights under the CCPA. For detailed information about our practices under California law, see the Supplemental Privacy Notice to California Residents below.

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Notice to Authorized Users

Our Platform Services are intended to be used by organizations. Where the Platform Services are made available to you through an organization (such as your employer), that organization is the administrator of the Platform Services and is responsible for the accounts and/or services over which it has control. For example, administrators can access and change information in your account or restrict and terminate your access to the Platform Services. We are not responsible for the privacy or security practices of an administrator's organization, which may differ from the practices reflected in this Privacy Notice. Please contact your organization or refer to its policies for more information.

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Data Retention

Human Intelligence retains the personal information described in this Privacy Notice for as long as you use our Services, as may be required by law (for example, to comply with applicable legal, tax, or accounting requirements), as necessary for other legitimate business or commercial purposes described in this Privacy Notice (for example, to resolve disputes or enforce our agreements), or as otherwise communicated to you. Personal information we process on behalf of a Customer is retained in accordance with our agreement with that Customer.

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Security

We are committed to protecting your information. We use a variety of technical, physical, and organizational security measures designed to protect against unauthorized access, alteration, disclosure, or destruction of information. These measures include encryption at rest and in transit, multi-factor authentication, role-based access controls, network segmentation, intrusion detection, security monitoring and logging, regular security assessments and penetration testing, employee security training, and incident response procedures. However, no security measures are perfect or impenetrable. As such, we cannot guarantee the security of your information.

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Third-Party Services

Our Services may contain links to third-party websites, applications, services, or social networks. We may also make available certain features that allow you to sign in to our Sites using third-party login credentials or access third-party services from our Platform Services. Any information that you choose to submit to third-party services is not covered by this Privacy Notice. We encourage you to read the terms of use and privacy notices of such third-party services before disclosing your information to them to understand how your information may be collected and used.

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Children's Data

The Sites and Platform Services are not directed to children under 18 years of age, and Human Intelligence does not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under an age for which consent or other legal obligations are required, we will take steps to delete such information. If you are aware that a child has submitted such information to us, please contact us using the details provided below.

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Changes to this Notice

Human Intelligence may change this Privacy Notice from time to time. We will post any changes on this page and, if we make material changes, provide a more prominent notice (for example, by adding a statement to the website landing page, providing notice through the Platform Services login screen, or by emailing you). You can see the date on which the latest version of this Privacy Notice was posted at the top of this page. If you disagree with any changes to this Privacy Notice, you should stop using the Services and deactivate your Human Intelligence account.

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How to Contact Us

Please contact us at privacy@humanintelligence.com if you have any questions about our privacy practices or this Privacy Notice. You can also write to us at:

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Profile Technologies Inc. 

1401 Pennsylvania Avenue, Suite 105

Wilmington, DE 19806

United States

Attn: Privacy

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If you interact with Human Intelligence through or on behalf of your organization, your personal information may also be subject to your organization's privacy practices, and you should direct any questions to that organization.

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Supplemental Privacy Notice to California Residents

This Supplemental Privacy Notice to California Residents ("Supplemental Notice") supplements the Privacy Notice above and applies solely to California residents. It is provided to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 ("CCPA"). Capitalized terms used but not defined in this Supplemental Notice have the meanings given to them in the CCPA.

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Categories of Personal Information Collected

In the past 12 months, we have collected the following categories of personal information about California residents in the contexts described in our Privacy Notice above:

• Identifiers (such as name, email address, phone number, postal address, IP address);
• Personal information categories listed in the California Customer Records statute (such as name, contact information, payment information);
• Commercial information (such as transaction and purchase history);
• Internet or other electronic network activity (such as browsing and usage data, interaction with our Sites and Services);
• Geolocation data (approximate location derived from IP address);
• Professional or employment-related information (such as job title, employer, role);
• Inferences drawn from the above to create a profile about preferences and characteristics.

Information processed on behalf of our Customers (typically including employee, workforce, performance, compensation, and similar data) is governed by our agreement with the relevant Customer. In that context, our Customer is the business and we are a service provider for purposes of the CCPA.

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Sources of Personal Information

• Directly from you (such as when you fill out a form on our Sites or contact us);
• Automatically from your device (such as through cookies and similar technologies);
• From our Customers (such as when your employer authorizes you as an Authorized User of the Platform Services);
• From third-party sources (such as business partners, event sponsors, and publicly available sources).
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Purposes of Collection and Use

We collect and use personal information for the business and commercial purposes described in the "How We Use Your Information" section of our Privacy Notice above.

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Disclosure of Personal Information

We may disclose the categories of personal information listed above to the categories of recipients described in the "How We Disclose Your Information" section of our Privacy Notice above, including affiliates, service providers and sub-processors, third-party partners, online advertising partners, legal and regulatory authorities, and parties involved in business transactions.

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Sale and Sharing of Personal Information

We do not "sell" personal information in the traditional sense of exchanging information for monetary payment. However, as described in our Privacy Notice above, certain disclosures of identifiers and Internet activity to advertising and marketing partners may constitute a "sale" or "share" under the CCPA. You may opt out of these activities by visiting the "Your Privacy Choices" link on our website footer (when available), by enabling a browser-based opt-out signal, or by emailing privacy@humanintelligence.com. We do not knowingly sell or share the personal information of California residents under 16 years of age.

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Your California Rights

California residents have the following rights:

• Right to know what personal information we collect, use, disclose, and "sell" or "share";
• Right to access and obtain a portable copy of your personal information;
• Right to correct inaccurate personal information;
• Right to delete personal information (subject to legal exceptions);
• Right to opt out of "sale" and "sharing" for cross-context behavioral advertising;
• Right to limit use and disclosure of sensitive personal information;
• Right to non-discrimination for exercising your CCPA rights.

To exercise these rights, please email privacy@humanintelligence.com. We will verify your request using reasonable methods consistent with applicable law. You may also designate an authorized agent to make a request on your behalf, subject to verification.

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Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. The specific retention periods depend on the category of information and the context of processing.

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Contact for California Privacy Requests

California residents may submit privacy requests by emailing privacy@humanintelligence.com or by writing to the postal address listed in "How to Contact Us" above.

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