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Cardsona

"Networking Your Many Passions Smartly"

PRIVACY POLICY

Effective Date: April 1, 2020

1. Introduction

The “Cardsona” software application is a mobile and web-based application offered by a collaboration of Tomson Scrap Metal and Smozy, LLC (“we” or “us”).  Among other tools, the Cardsona application provides innovative features for users to create, customize and share personalized digital cards in their accounts, such as business cards, personal interest cards, or other customized cards, which can replace or supplement conventional paper-based cards. In addition, the Cardsona tools create a community environment that facilitates communication and networking among different users (“you”) for a variety of reasons, including for conducting business, professional networking, social or personal networking, and other purposes involving user-to-user interactions.  We are committed to being transparent about the data we collect about you, how it is used and with whom it is shared.This Privacy Policy applies when you use our Services, including the Cardsona application (as described in our Terms of Service). We may offer users choices about the data we collect, use and share in accordance with this Privacy Policy and our Cookie Policy. This Privacy Policy applies to any Member or Visitor to our Services. For California residents, additional disclosures required by California law can be found in the relevant parts of this Privacy Policy.

2. Changes and Updates

Changes to this Privacy Policy apply to your use of our Services after the Effective Date (see below). We can modify this Privacy Policy, and if we make material changes to it we will provide notice to you through our Services, or by other means. This will give you the opportunity to review the changes before they become effective. If you object to this Privacy Policy or any changes to it, you may close your account and stop using the Services. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy, as of its Effective Date.

3. Data We Collect - General

You provide data to create and register an account with us. To create an account, you need to provide personal data including your name, e-mail address, mobile number, and a password. You have choices about the information in your account, such as your education, work experience, skills, photo, city or area, and endorsements. You don’t have to provide additional information in your account; however, more account information helps you to derive more benefits from our Services, including helping to connect you with business contacts and business opportunities. It’s your choice whether to include sensitive information in your account and whether to make that sensitive information public. Please do not post or add personal data to your account that you would not want to be publicly available.We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, respond to a survey, or create a virtual card on our Services. If you opt to import your address book, for example, we will receive data associated with your contacts. If you synchronize your contacts or calendars with our Services, for example, we may collect your address book and calendar meeting information to keep growing your network by suggesting connections for you and others. You don’t have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.

4. Data from Others

You and others may create or post content that includes information about you (as part of articles, posts, comments, videos, etc.) on our Services. We receive personal data (including contact information) about you when others import or synchronize their contacts or calendars with our Services, associate their contacts with Member accounts, upload business cards, or send messages using our Services (including connection requests with other Members). If you or others choose to synchronize e-mail accounts with our Services, we may also collect e-mail header information that can be associated with Member accounts.Customers and partners may provide data to us. We receive personal data (e.g., your job title and work email address) about you when you use the Services of our customers and partners. We receive data about you when you use other devices or services, such as by your use of Apple or Samsung devices and applications. For example, you may choose to send us contact data stored in an Apple-based device.

5. Data Derived from Use of Services

We log your visits and use of our Services, including through mobile applications. We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology, such as when you view or create content (e.g., virtual cards) or advertisements, perform a search, install or update one of our mobile applications, establish connections with other Members, or perform other tasks. We may use log-ins, cookies, device information and internet protocol (“IP”) addresses, among other tools, to identify you and log your access and use of the Services.

6. Cookies and Similar Technologies

As further described in our Cookie Policy, we use cookies and similar technologies (e.g., pixels and ad tags) to collect data (e.g., device IDs) to recognize you and your devices across different services and devices where you have engaged with our Services. We also allow some others to use cookies as described in our Cookie Policy. We also collect (or rely on others who collect) information about your device in areas where you have not engaged with our Services (e.g., ad ID, IP address, operating system and browser information), so we can provide our Members with relevant advertisements and better understand their effectiveness.

7. Your Device and Location

We receive data from your devices and networks, including location data. When you visit or leave our Services (including some plug-ins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

8. Messages and other Communications

We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a connection request from another Member, we track whether you have acted on it and will send you reminders. We also use automatic scanning technology on messages to support and protect our site. For example, we use this technology to suggest possible responses to messages and to manage or block content that violates our Terms of Service.

9. Sites and Services of Others

We receive information about your visits and interaction with services provided by others when you log-in with us or visit others’ services that include some of our plugins or our ads, cookies or similar technologies.

10. Other Data CollectionWe are constantly trying to improve our Services, which means we get new data and create new ways to use data. Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we collect, use or share your data, we will notify you and may also modify this Privacy Policy accordingly.

11. How We Use Your Data

We use your data to provide, support, personalize and develop our Services. How we use your personal data will depend on which Services you use, how you use those Services, and the choices you make in your settings. We use the data that we have about you to provide and personalize our Services, including with the help of automated systems and inferences we make, so that our Services (including advertisements) can be more relevant and useful to you and others. Our Services help you connect with others, find and be found for work and business opportunities, stay informed, and be more productive. We use your data to authorize access to our Services and honor your settings.Our Services allow you to stay in touch and up to date with colleagues, partners, clients, and other professional contacts. To do so, you can connect with the professionals whom you choose, and who also wish to connect with you. Subject to your and their settings, when you connect with other Members, you will be able to search Member connections in order to exchange professional and personal opportunities.We use data about you (such as your account data) to help others find you, suggest connections for you and others (e.g., Members who share your contacts or job experiences), exchange virtual cards, and enable you to invite others to become a Member and connect with you. You can also opt-in to allow us to use your precise location or proximity to others for certain tasks (e.g., to suggest other nearby Members for you to connect with, calculate the commute to a new job, or notify your connections that you are at a professional event).It is your choice whether to exchange a virtual card, send a connection request, or allow another Member to become your connection, or receive a virtual card from you. When you invite someone to connect with you, your invitation will include your network and basic account information (e.g., name, profile photo, job title, region). You can choose whether or not to share your own list of connections with your connections.Our Services allow you to collaborate with colleagues, search for potential clients, customers, partners and others to do business with. Our Services allow you to communicate with other Members, exchange virtual business cards with them, and schedule and prepare meetings with them. If your settings allow, we scan messages to provide “bots” or similar tools that facilitate tasks such as scheduling meetings, drafting responses, summarizing messages, or recommending next steps.

12. Communications

We offer settings to control what messages you receive and how often you receive some types of messages. We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use our Services, network updates, reminders, job suggestions and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices. We also enable communications between you and others through our Services, including transmitting messages between connected Members, for example.

13. Advertising

We may serve you customized advertising both internally and externally from our Services. We offer you choices regarding personalized advertisements, but you cannot opt-out of seeing other kinds of advertisements. We target (and measure the performance of) advertisements to Members, Visitors, and others directly or through a variety of partners, using the following data, whether separately or in combination:- Data from advertising technologies internal or external to our Services, pixels, ad tags, cookies, and device identifiers.- Member-provided information (e.g., name, contact information, title and industry).- Data from your use of our Services (e.g., search history, feed, content you read, connections, group participation, page visits, videos you watch, clicking on an ad, etc.).- Information from advertising partners, vendors and publishers.- Information inferred from data described above (e.g., using job titles from a profile to infer industry).We will show you advertisements called sponsored content which look similar to non-sponsored content, except that they are labeled as advertising (e.g., as “ad” or “sponsored”). If you take action (such as to like, comment or share) on these advertisements, your action is associated with your name and viewable by others, including the advertiser. Subject to your settings, if you take action through the Services, that action may be mentioned with related advertisements.We adhere to self-regulatory principles for interest-based advertising and participate in industry opt-outs from such ads. This does not opt you out of receiving advertising; you will continue to get other advertisements by advertisers not listed with these self-regulatory tools. We do not share your personal data with any third-party advertisers or ad networks except for: (i) hashed IDs or device identifiers (to the extent they are personal data in some countries); (ii) with your separate permission (e.g., in a lead generation form) or (iii) data already visible to any users of the Services (e.g., profile). However, if you view or click on an advertisement internal or external to our Services, the advertisement provider will get a signal that someone visited the page that displayed the advertisement, and they may be able to determine it is you. Advertising partners can associate personal data collected by the advertiser directly from you with hashed IDs or device identifiers received from us. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.

14. Marketing

We promote our Services to you and others. In addition to advertising our Services, we use Members’ data and content for invitations and communications promoting membership and network growth, engagement, and our Services, such as by showing your connections that you have used a feature on our Services.

15. Developing Services and Research

We use data, including public feedback, to conduct research and development for our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect professionals to each other and to economic opportunity. Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations.

16. Customer Support

We use data (which can include your communications) to investigate, respond to, and resolve complaints and for performance issues (e.g., bugs) associated with the Services.

17. Insights

We use your data to produce and share insights that do not personally identify you. For example, we may use your data to generate statistics about our Members, their profession or industry, to calculate advertisement impressions served or clicked on, or to publish visitor demographics for a Service or create demographic workforce insights.

18. Security and Investigations

We may need to use your data (including your communications) for security purposes or to prevent or investigate possible fraud or other violations of our Terms of Service and/or attempts to harm our Members, Visitors, or others.

19. How We Share Information - General

Any data that you include on your account, any content you create or post publicly, or any action (e.g., likes, follows, comments, shares) you take through our Services will be seen by others, consistent with your settings.Subject to your settings, your account data may be visible internally or externally to the Services (e.g., Visitors to our Services or users of third-party search engines). Your settings, degree of connection with the viewing Member, the subscriptions they may have, their usage of our Services, access channels, and search types (e.g., by name or by keyword) impact the availability of your account information and whether certain data can be seen.

20. Shared Content, Posts, and Messages

When you share content or a post publicly (e.g., a virtual card, image, video or article), it can be viewed by everyone and re-shared anywhere (subject to your settings). Members, Visitors, and others will be able to find and see your publicly shared content, including your name (and photo if you have provided one).

21. Other Service Providers

We may use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

22. Legal Disclosures

We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others. It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Tomson Scrap Metal, our Members, personnel or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

23. Change in Control or SaleWe can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys our company or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

24. Your Choices and Obligations – General

We generally retain your personal data as long as you keep your account open or as needed to provide you with the Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services occasionally or infrequently, we will retain your information and keep your profile open, unless you close your account. In some cases, we choose to retain certain information (e.g., insights about Services use) in a depersonalized or aggregated form.We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your content and controlling the visibility of your posts to advertising opt-outs and communication controls. We may offer you settings to control and manage the personal data we have about you.For personal data that we have about you, you can request that we:- Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).- Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.- Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).- Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

25. Account Closure

If you choose to close your account with us, your personal data will generally stop being visible to others on our Services within three (3) business days. We generally delete closed account information within 30 days of account closure, except as noted below.We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse (e.g., if we have restricted your account for breach of our Terms of Service), enforce our Terms of Service, or fulfill your request to "unsubscribe" from further messages from us. We will retain de-personalized information after your account has been closed.Information you have shared with others (e.g., through messages to other Members) will remain visible after you close your account or delete the information from your own profile or mailbox, and we do not control data that other Members have copied out of our Services. Groups content and ratings or review content associated with closed accounts will show an unknown user as the source. Your account data may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

26. Security

We implement reasonably security safeguards in accordance with industry standards and designed to protect your data. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.27. Lawful Basis for Processing DataWe will only collect and process personal data about you where we have a lawful basis to do so. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to deliver the Services you have requested), and “legitimate interests.” Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.

28. Direct Marketing and Do Not Track Signals

We currently do not share personal data with third parties for their direct marketing purposes without your permission.

29. California Privacy Disclosure

This notice describes the rights of Californians under the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA requires businesses that receive information from more than fifty thousand California consumers to provide certain information to them. We fully describe our practices to all our members and visitors in our Privacy Policy, but use this separate notice to ensure that we meet the CCPA’s requirements.

29.1 We Do Not Sell Your Personal Information

The CCPA requires us to disclose whether we sell your personal information. We do not sell your personal information.

29.2 Your Rights Under the CCPA - The CCPA provides Californians with the following rights:

- Requests for Information - Like all of our Members or Visitors, you (or your authorized agent) can request a copy of your personal information. Under the CCPA, you can also request that we disclose how we have collected, used, and shared your personal information over the past 12 months, including the categories of personal information we collected and our purposes for doing so; the categories of sources for that information; the categories of third parties with whom we shared it for a business purpose and our purposes for doing so. Companies that sell personal information must make additional disclosures.- Your Right to Opt Out of Sales - We do not sell personal information, so we don’t have an option for you to opt out.- Your Right to Notification – We won’t collect new categories of personal information or use them for materially different purposes without first notifying you.- Nondiscrimination for exercising your CCPA Rights - The CCPA prohibits businesses from discriminating against you for exercising your rights under the law. Such discrimination may include denying services, charging different prices or rates for services, providing a different level or quality of services, or suggesting that you will receive a different level or quality of goods or services as a result of exercising your rights.- Your Right to Delete Personal Information - Like all of our Members, you can request that we delete your personal information by closing your account. You also can request that we delete specific information. We honor such requests, unless an exception applies, such as when the information is necessary to complete the transaction or contract for which it was collected or when it is being used to detect, prevent, or investigate security incidents, comply with laws, identify and repair bugs or ensure another consumer’s ability to exercise their free speech rights or other rights provided by law.

29.3 The CCPA Categories of Personal Information We Collect and the Sources

Our Privacy Policy describes the information we collect and its sources. This notice organizes that information around the personal information categories set forth in the CCPA:- CCPA Personal Information Category: identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers).  Sources of this information: information you provide directly or through your interactions with our Services or partners (as defined in our Privacy Policy); vendors that provide information to help us serve Members relevant advertisements and understand advertising effectiveness; and, information from other Members.- CCPA Personal Information Category: characteristics of protected classifications under California or Federal law (e.g., your gender or age) (“Characteristics of Protected Classifications”). Sources of this information: information you provide to us directly and inferences we make based on that information and information from our Members.- CCPA Personal Information Category: commercial information (e.g., information regarding products or services purchased, obtained, or considered).  Sources of this information: information you provide to us directly, such as account data, your interactions with our Services, and information from our partners and Members.- CCPA Personal Information Category: internet or other electronic network activity information (e.g., browsing history, search history, and information regarding your interactions with our Services). Sources of this information: your interactions with our Services; your visits to third party sites that offer autofill functionality, as needed for fraud prevention and security purposes; if you are a Member, your interactions with the services of partners and other Members- CCPA Personal Information Category: geolocation data.  Sources of this information: information you provide to us directly or through your interactions with our Services.- CCPA Personal Information Category: professional or employment-related information. Sources of this information: information you provide to us directly, and information from our customers, partners, or from other Members.- CCPA Personal Information Category: inferences.  Sources of this information: information you provide to us directly or through your interactions with our Services, and information from our Members and partners.- CCPA Personal Information Category: personal information described in Cal. Civ. Code §1798.80(e) (such as name, address, telephone number, education, employment history, credit card or debit card number). Sources of this Information: information you provide directly or through your interactions with our Services, and information from our Members or partners.- CCPA Personal Information Category: audio, electronic, visual or similar information. Sources of this Information: information you provide directly or through your interactions with our Services, Members, or partners.

29.4 The CCPA Categories of Personal Information We Share for a “Business Purpose”

While we do not sell your personal information, we may share it to support our own operational purposes in providing Services to you, as described in our Privacy Policy. These operational purposes, known as “business purposes” under the CCPA, are described below. In addition, we may share personal information at your direction, such as when you choose to communicate with other members through our Services.- Auditing Interactions - We may share the types of personal information listed herein with partners, service providers and related companies, in order to audit interactions and transactions, such as to count or verify the positioning and quality of advertisement impressions.- Security Purposes - In order to secure our Services, including to detect, prevent and investigate security incidents or violations of our Terms of Service, we may share the types of personal information listed herein with our partners, service providers, law enforcement and related companies.- Service Improvements - In order to improve our Services (such as to identify bugs, repair errors or ensure that services function as intended) or conduct internal research and analysis to improve our technology, we may share the types of personal information listed herein with our partners, service providers and related companies.- Service Providers and Other Notified Purposes - We may share the types of personal information listed herein with Service Providers, as defined by the CCPA, in order to have them perform services specified by a written contract or with others for a notified purpose permitted by the CCPA (e.g., to respond to law enforcement requests).

30. Contact Information

If you have any questions, comments, or complaints regarding this Privacy Policy, please contact us via the e-mail address and/or physical address listed in our mobile application and our website.

Effective Date: April 1, 2020