This Privacy Policy describes how FruitionData, Inc. (DBA WiseLayer) ("WiseLayer", "we", “us” or "our") handle personal information that we collect through our digital properties that link to this Privacy Policy, including our website (collectively, the “Service”), as well as through social media, our marketing activities, and other activities described in this Privacy Policy.

Please note that if you subscribe to and integrate with a third-party app or analytical model available through the Service, any personal information exchanged with or through such third-party app or analytical model is subject to the third party’s own privacy policies and practices, not this policy, and we are not responsible for the third party’s actions, including the third party’s processing of your data.

PERSONAL INFORMATION WE COLLECT
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Information you provide to us.  Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, salutation, email address, mailing address, professional title and company name, and phone number.
• Demographic Information, such as your city, state, country of residence, and postal code.
• Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Transactional data, such as information relating to or needed to complete your subscription orders on or through the Service, including order numbers and transaction history.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
• Marketing partners, such as joint marketing partners and event co-sponsors.

Automatic data collection.  We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or general geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

HOW WE USE YOUR PERSONAL INFORMATION
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We may use your personal information for the following purposes or as otherwise described at the time of collection:

‍Service delivery.  We may use your personal information to:

• provide, operate and improve the Service and our business;
• communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
• communicate with you about events in which you participate;
• understand your needs and interests, and personalize your experience with the Service and our communications; and
• provide support for the Service, and respond to your requests, questions and feedback.

Research and development.  We may use your personal information for research and development purposes, including to analyze and improve the Service and our business.  As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect.  We make personal information into anonymous data by removing information that makes the data personally identifiable to you.  We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

‍Marketing.  We, our service providers and our third-party partners may collect and use your personal information for marketing purposes:

• Direct marketing. We may send you direct marketing communications.  You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Compliance and protection.  We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent.  In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.  
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Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

• Technical operation. To allow the technical operation of the Service.
• Functionality. To enhance the performance and functionality of our services.
• Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. 

HOW WE SHARE YOUR PERSONAL INFORMATION
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We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.  

‍Affiliates.  Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

‍Service providers.  Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, consumer research, marketing, and website analytics). 

‍Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. You can read Stripe’s privacy policy here: https://stripe.com/privacy. 

‍Third parties designated by you. We may share your personal data with third parties where you have instructed us or provided your consent to do so. We will share personal information that is needed for these other companies to provide the services that you have requested. 

Business and marketing partners. Third parties with whom we co-sponsor events, with whom we jointly offer products or services, or whose products or services may be of interest to you.

‍Professional advisors.  Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

‍Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

‍Business transferees.  Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, WiseLayer, our parent, our affiliates, or our subsidiaries (including, in connection with a bankruptcy or similar proceedings).

YOUR CHOICES
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In this section, we describe the choices available to you.

‍Opt-out of marketing communications.  You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at contact@wiselayer.com.  Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

‍Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

‍Declining to provide information. We need to collect personal information to provide certain services.  If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

‍Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:

• Browser settings.  Changing your internet web browser settings to block third-party cookies.
• Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
• Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option at the following websites:
  Google: https://adsettings.google.com/
  Facebook: https://www.facebook.com/about/ads
  
• Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
  Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
  Digital Advertising Alliance: optout.aboutads.info

You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.  We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above. 

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

OTHER SITES AND SERVICES
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The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

SECURITY
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We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

INTERNATIONAL DATA TRANSFER
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We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

CHILDREN
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The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

CHANGES TO THIS PRIVACY POLICY
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We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

HOW TO CONTACT US

• Email:  privacy@wiselayer.com
• Mail: FruitionData Inc. (DBA WiseLayer), 360 W 31ST ST 6TH FLOOR, NEW YORK, NY 10001