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This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Platform. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

Category of Personal Data

Examples of Personal Data We Collect

Categories of Third Parties With Whom We Share this Personal Data

Profile or Contact Data

  • First and last name

  • Email

  • Phone number

  • Unique identifiers such as passwords

  • Service Providers

Payment Data

  • Financial account information

  • Payment card type

  • Credit or debit card number, as processed by Bill.com and SVB Financial Group, Inc.

  • Billing address, phone number, and email

  • Service Providers

Device/IP Data

  • IP address

  • Domain Server

  • Type of device/operating system/browser used to access the Services

  • Service Providers

  • Advertising Partners

  • Analytics Partners

Web Analytics

  • Web page interactions

  • Referring webpage/source through which you accessed the Services

  • Non-identifiable request IDs

  • Statistics associated with the interaction between device or browser and the Services

  • Service Providers

  • Advertising Partners

  • Analytics Partners

  • Business Partners

  • Parties You Authorize,Access or Authenticate

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You

When you provide such information directly to us.

  • When you create an account or use our interactive tools and services.

  • When you send us an email or otherwise contact us.

When you use the Services and such information is collected automatically.

  • If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant services, such as information regarding when you are logged on and available to receive updates or alert notices.

Our Commercial or Business Purposes for Collecting or Disclosing Personal Data

Providing, Customizing and Improving the Services

  • Improving the Services, including testing, research, internal analytics and product development.

  • Personalizing the Services, website content and communications based on your preferences.

  • Doing fraud protection, security and debugging.

  • Processing orders or other transactions; billing.

  • Providing you with the products, services or information you request.

  • Meeting or fulfilling the reason you provided the information to us.

  • Providing support and assistance for the Services.

  • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (the “CPRA”).

Marketing the Services

  • Marketing and selling the Services.

Corresponding with You

  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Samooha or the Services.

  • Sending emails and other communications according to your preferences or that display content that we think will interest you

Meeting Legal Requirements and Enforcing Legal Terms

  • Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.

  • Protecting the rights, property or safety of you, Samooha or another party.

  • Enforcing any agreements with you.

  • Responding to claims that any posting or other content violates third-party rights.

  • Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice. If you are a California resident, please note that we only use or disclose your sensitive personal information for the purposes set forth in section 7027(m) of the CPRA regulations and we do not collect or process sensitive personal information with the purpose of inferring any characteristics about California residents.

We disclose your Personal Data only to service providers or other parties under particular circumstances as described in this Section. Our service providers may include, for example, hosting, technology and communication providers or payment processors (Bill.com LLC and SVB Financial Group, Inc.).

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In addition, disclosures of your Personal Data may occur in the circumstances described below. 

Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above. 

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

  • Essential Cookies. Essential Cookies are required for providing you with features or Services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and Services unavailable.

  • Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

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You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work. 

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To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

 

For example:

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  • We retain your profile information and credentials for as long as you have an account with us.

  • We retain your payment data for as long as we need to process your purchase or subscription.

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 18  years of age; if you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided Personal Data to us, please contact us at support@samooha.tech.

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain Services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@samooha.tech.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

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  • The categories of Personal Data that we have collected about you.

  • The categories of sources from which that Personal Data was collected.

  • The business or commercial purpose for collecting or selling your Personal Data.

  • The categories of third parties with whom we have shared your Personal Data.

  • The specific pieces of Personal Data that we have collected about you

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If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient. However, we do not currently sell your Personal Data.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CPRA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested, or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Correction

You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CPRA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request. 

Personal Data Sales Opt-Out and Opt-In

We will not sell your Personal Data, and have not done so over the last 12 months. To our knowledge, we do not sell the Personal Data of minors under 18 years of age.

Personal Data Sharing Opt-Out and Opt-In 

Under the CPRA, California residents have certain rights when a business “shares” Personal Data with third parties for purposes of cross-contextual behavioral advertising. We will not share your Personal Data for cross-contextual behavioral advertising, and have not done so over the last 12 months. To our knowledge, we do not share the Personal Data of minors under 16 years of age for purposes of cross-contextual behavioral advertising.

We Will Not Discriminate Against You for Exercising Your Rights Under the CPRA

We will not discriminate against you for exercising your rights under the CPRA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CPRA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CPRA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Exercising Your Rights under CPRA

To exercise the rights described in this Privacy Policy, you or, if you are a California resident, your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

 

We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

 

You may submit a Valid Request using the following methods:

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If you are a California resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at support@samooha.tech. However, we do not currently disclose or sell your Personal Data. 
 

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at support@samooha.tech with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. However, we do not currently disclose or sell your Personal Data. 

Other Country Privacy Rights

European Union Resident Rights

The Services are not currently available to Customers in the European Union. If you are a European Union resident, please don't attempt to place an Order or otherwise sign up for the Services

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

What this Privacy Policy Covers
Personal Data
Categories of Personal Data We Collect
Categories of Sources of Personal Data
Our Commercial or Business Purposes for Collecting
How We Share Your Personal Data

Privacy Policy

Effective Date: Feb 1, 2023

At Samooha, we take your privacy seriously. By using or accessing our website and other products and services (the “Services”) in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy. This Privacy Policy describes our collection and processing practices of Personal Data (defined below) that you provide directly to us or that we collect directly from you or a third party other than any enterprise customer. This Privacy Policy does not cover the processing of Personal Data provided to us by our enterprise customers, which is governed by our agreement with each such enterprise customer. We only process such Personal Data at the direction of enterprise customers. Accordingly, if we process your Personal Data on behalf of one of our enterprise customers and you wish to discontinue such processing, or if you seek to exercise your rights with respect to such Personal Data, please reach out to the enterprise customer on behalf of which we are processing your Personal Data. We will follow such enterprise customer’s instructions regarding your request.

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Remember that your use of Samooha's Platform is at all times subject to our Terms of Service, which incorporates this Privacy Policy. Any capitalized terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.

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You may print a copy of this Privacy Policy by clicking here

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As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. Upon such changes, we will alert you to any such changes by placing a notice on the Samooha website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes

Tracking Tools and Opt-Out
Data Security
Personal Data of Children
Data Retention
California Resident Rights
Exercising Your Rights under CPRA
Other State Law Privacy Rights
Other Country Privacy Rights
Contact Information
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