Privacy Policy

Your Privacy Matters to Extropolis

This Privacy Policy governs your relationship with Extropolis Corp. (also “Extropolis,” “we,” “our,” or “us”). Protecting our users and business customers (also “you,” “your,” or “their”) and their privacy is a priority of ours. We have provided this Privacy Policy to help you understand:

  • how we collect your non-public personal information (“Personal Information”), 
  • how we use your Personal Information, and 
  • how we protect your privacy. 

This Privacy Policy governs your access to and use of our website located at www.extropolis.ai and all other apps, websites, newsletters, or digital mediums owned and maintained by Extropolis and also applies to any Personal Information collected, stored, or used by us, such as Information you provide us through the above mediums, by email, mail, or telephonic communications (collectively, the “Website”). In addition, the Privacy Policy describes how we handle Personal Information we collect through the provision of our artificial-intelligence companion services to you, such as by our Website, conversations with the Extropolis artificial-intelligence companion (“AI Companion”), telephone calls, e-mails, and other communications with us, with related professionals, or with other third parties involved in providing services to you (collectively, the “Services”).

By accessing and using the Website and Services, you acknowledge that you have read this Privacy Policy and consent to its terms. 

  1. Privacy

Our Privacy Assurance 

  • We will not share or sell any conversations or conversation history you have with your AI Companion to any other company or service. 
  • We strive to collect only Personal Information necessary or relevant to our business. 
  • We make a reasonable effort to ensure that Personal Information we act upon is accurate, relevant, timely, and complete. 
  • We use only legitimate means to collect Personal Information. 
  • We make Personal Information available externally only to respond to legitimate business needs, to regulatory or other government authorities, or as otherwise permitted by law. 
  • We limit employees’ access to Personal Information to those who need to handle Personal Information and who are trained in the proper handling of such Personal Information. 
  • We take industry standard precautions to protect your Personal Information.
  • We do not sell Personal Information to any person or company. 
  • We do not share Personal Information with non-affiliate companies that would use such Personal Information to market their own products and services, unless permitted pursuant to a joint marketing agreement. 
  • We do not knowingly collect or store medical information or Protected Health Information (PHI), which is defined under US law as any information about health status, provision of health care, or payment for health care that is created or collected by a Covered Entity and can be linked to a specific individual. 

Personal Information We Collect from You 

We get most of our Personal Information directly from you through the Website or via any application you complete, email, mail, mobile apps, or telephonic communications, and various transactions with us. Sometimes our agents may contact you by phone or mail to obtain additional Personal Information. Depending on the nature of your transaction, we may need additional Personal Information. We also might obtain Personal Information about you from transactions with us or third-party service providers.

Some examples of the Personal Information we may collect from you include, among other types of Personal Information: 

  • Name 
  • Phone number 
  • Email address 
  • Home address and other information related to your geographic location
  • Birth date
  • Gender
  • Work status 
  • Credit card and related validation information
  • Other biographical information such as your hobbies & interests and other facts about you and your life that may be pertinent to your conversation with your AI Companion 

You can choose not to provide certain information, but it may delay or prevent us from providing products and/or our Services to you.

Personal Information from Internet Use 

We may also automatically receive and store certain types of Personal Information whenever you visit the Website, such as the name of the domain and host from which you access the Internet, the IP address of the computer you are using, the web browser and operating system you are using, the date and time you access the Website, and the Internet address of the website from which you linked to the Website. We may log and use your IP address to administer the Website, to help diagnose problems with our server, to analyze trends, to track users’ webpage movements, to help identify you and your geographic region, and to gather broad demographic information for aggregate use. 

We may use standard tools, such as “cookies” (which may be html files, flash files, or other technology), web beacons, or similar technologies (collectively, “Tracking Tools”). Cookies are small text files stored locally on your computer that help store user preferences. “Web beacons” or “clear gifs” are small pieces of code placed on websites used to collect advertising metrics, such as counting page views, promotion views, or advertising responses. We may use Tracking Tools to monitor the Website and Internet usage and to improve or customize the content on the Website. 

In addition, on occasion we may also set a “session cookie” on the Website to help us administer the Website. The session cookie expires when you close your web browser and does not retain any Information about you after it expires. If you do not want the benefits of these cookies, you may opt-out by visiting http://www.networkadvertising.org/optout_nonppii.asp. However, if you do so, you may not receive the full benefit from the use of the Website. 

We may use Tracking Tools only to gather information as indicated in this Privacy Policy. In many web browsers, you can choose to delete, disable, turn off, or reject most Tracking Tools through the “Internet Options” sub-option of the “Tools” menu of your web browser or otherwise as directed by your web browser’s support feature. Please consult the “Help” section of your web browser for more information. By agreeing to this Privacy Policy, you are consenting to the use of Tracking Tools as set forth in this Privacy Policy. 

Finally, our web servers may collect “log data.” Log data provides aggregate information about the number of visits to different pages on the Website. This Privacy Policy does not apply to other types of information you may disclose or that we may collect, including aggregate user statistics, demographic information, and other data that does not include Personal Information or from which you cannot be identified.

We use such aggregate log data to improve access to the Website based on visitors’ web browsers and operating system types to make the Website available to as many relevant users as possible. We do not link the “log data” collected to Personal Information. Third party providers may also collect aggregate log data independently from us. 

How We Use Your Personal Information 

Under data protection law, we can only use your Personal Information if we have a proper reason for doing so, e.g.:

  • To comply with our legal and regulatory obligations;
  • For the performance of Services or to take steps at your request before engaging in Services with you;
  • For our legitimate interests or those of a third party; or
  • Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your Personal Information for and our reasons for doing so:

Uses of Your Personal Information

Our Reasons for Such Use

To provide products and/or Services to you

For the performance of our contract with you or to take steps at your request before entering into a contract

To make decisions about the types of products and prices we can offer to you

For our legitimate interests or those of a third party, i.e. to factor various risks into the products and prices we offer

To assess your eligibility for payment plans and to process your payments

For our legitimate interests or those of a third party, i.e. to factor various risks into payment plans we offer

To communicate with you and others as part of our business and to respond to your requests

For our legitimate interests or those of a third party, i.e. to send updates to you regarding our products and Services

For the performance of our contract with you or to take steps at your request before entering into a contract

To prevent and detect fraud or abuse

For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us, a third party or for you

Conducting checks to identify our customers and verify their identity

Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business

To comply with our legal and regulatory obligations

Gathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodies

To comply with our legal and regulatory obligations

Ensuring business policies are adhered to, e.g. policies covering security and internet use

For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can improve our products and Services

Operational reasons, such as improving efficiency, training, and quality control

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can improve our products and Services

Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information

To comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can improve our products and Services

Preventing unauthorized access and modifications to systems

For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you

To comply with our legal and regulatory obligations

Generally establish and defend legal rights and protect our operations or those of any of our group companies or business partners

For our legitimate interests or those of a third party; i.e. to pursue available remedies to limit our damages.

Updating and enhancing customer records

For the performance of our contract with you or to take steps at your request before entering into a contract

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products

Statutory returns or responses

To comply with our legal and regulatory obligations

Ensuring safe working practices, staff administration, and assessments

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our Services and those of selected third parties to:

  • existing and former customers;
  • third parties who have previously expressed an interest in our Services;
  • third parties with whom we have had no previous dealings.

For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers

External audits and quality checks, e.g. security accreditation and the audit of our accounts

For our legitimate interests or those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards

To comply with our legal and regulatory obligations

Facilitate social sharing functionality

For our legitimate interests or those of a third party, i.e. to enable efficient functionality between our Services and digital mediums

Send you important information regarding changes to our policies, other terms and conditions, our Services and other administrative information

For our legitimate interests or a those of a third party, i.e. to obtain your consent to updated policies

To comply with our legal and regulatory obligations

 

The following table provides additional detail on the types of Personal Information we collect and how we use that information, particularly in the context of your conversations with your AI Companion:

Personal information

Why we need the data

When it is collected

Is it ever shared?

Name*

To enable your AI Companion to address you by name.

In text chats with your AI Companion, when you create an account, or when you edit your profile.

Yes, we use an external service to deliver service-related personalized emails to you that address you by name.

Other profile information

To customize conversations with your AI Companion. This may include your birthday, gender, work status, etc. For example, Extropolis will enable or disable conversations about school or work, depending on which one is relevant. We do not collect any of this information if you choose not to provide it.

When you edit your profile

No

Email*

To enable you to log in using your email and restore password in case you forget it.

When you create an account

Yes, we use an external service to deliver automated emails to you (for example, in case you forgot your password). This service provider gets access only to the first name and email.

Your hobbies & interests

To include more conversation about relevant subjects, for example about video games or specific books.

In text or voice chats with your AI Companion

No

Facts about you and your life

To enable personalized conversation based on facts that your AI Companion recognizes in your messages.

In text or voice chat with your AI Companion

No

Mood history

To display your mood history and help you recognize what triggers certain moods.

In text chat with your AI Companion

No

People mentioned in the chat

To enable conversations about important people in your life and recognize them on pictures that you send to your AI Companion. The information you provide may include the name, the relation to you, a face recognition fingerprint.

In text or voice chat with your AI Companion

No

Integration with your social media account

To enable conversations about your recent posts on social media. This information also includes photos that you post on social media. The level of access to your social media does not allow us to post on your behalf.

When you choose to connect social media in text chat with your AI Companion

No

Voice messages sent to Extropolis during a voice call

To provide the voice call experience and to improve the quality of it.

In voice calls with your AI Companion

Yes, we use an external service for voice-to-text recognition. Only the voice messages can be sent to this service without any other personal information.

Images you send to Extropolis

To enable object and face recognition and appropriate reaction to images that you share with your AI Companion in chat.

When you send an image to your AI Companion in a text chat

Yes, we use an external service for object recognition in photos. Only the photo may be sent to this service without any other personal information.

Text messages you send to Extropolis

To display your chat history in the app or in your web browser and sync the history across all your devices and to train Extropolis machine learning models and improve the quality of your text chat experience.

In text chat with your AI Companion

No

Usage data

We collect and store your usage data, such as button clicks or search queries, to track and analyze product metrics and to better understand and serve the users of the Services.

When you interact with the Apps or the Website

Yes, we use an external service to track and visualize de-identified usage data.

 

  • Items marked with an “asterisk” (*) are mandatory, whereas all the other items are optional and you may choose not to provide this information.

As described below, we also may collect certain information from and about the computers, phones, and other web-connected devices that you access the Website from. We combine this information across different devices you use. For example, we use the information collected about your use of the Website on your phone to better personalize the content you receive from Extropolis or features you have access to when you use it on another device, such as your laptop or tablet.

The device information also helps us conduct user research across our customer demographics, interests and behavior. None of this information may identify you personally. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Device information

Description

Device attributes

Information such as the operating system, hardware, and software versions, browser type.

Identifiers

Unique identifiers, such as your device ID.

Data from device settings

Information you allow us to receive through device settings you turn on, such as access to your camera or photos.

Network and connections

Information such as the name of your mobile operator or ISP, language, time zone.

Cookie data

Data from cookies stored on your device, including cookie IDs and settings (only for the Website). Learn more about how we use cookies in the “Cookies” section.

 

With whom do we share your Personal Information 

We may disclose the Personal Information we collect to companies or individuals that perform Services on our behalf with whom we have joint marketing agreements. In order to conduct our business and to better serve you, we may disclose all of the Personal Information we collect, as described above, to:

    • Our service providers. We may also share your Personal Information with external third-party service providers, such as accountants, actuaries, auditors, experts, lawyers and other outside professional advisors; call center service providers; IT systems, support and hosting service providers; printing, advertising, marketing and market research and analysis service providers; banks and financial institutions that service our accounts; document and records management providers; translators; and similar third-party vendors and outsourced service providers that assist us in carrying out business activities. We may share your Personal Information with OpenAI, one of our service providers, and you are required to agree to their Privacy Policy and Terms of Use as a condition of using OpenAI’s services.
  • Providers of Internet-connected devices and associated software. Extropolis may make the Personal Information you provide to us via our apps available to providers of Internet-connected devices and/or associated operating systems and/or software as set forth in the terms of use and/or privacy policies you agree to with those providers.
  • Governmental authorities and third parties involved in court action. Extropolis may also share Personal Information with governmental or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement, tax authorities and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our group companies; (f) to protect our rights, privacy, safety or property, and/or that of our group companies, you or others; and (g) to allow us to pursue available remedies or limit our damages.
  • Other Third Parties. We may share Personal Information with purchasers and prospective purchasers or other parties in any actual or proposed reorganization, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business, assets or stock.  

These companies and individuals may only use the Personal information for the transactions we request. We may disclose your Personal Information to third parties for the following reasons: 

  • Providing you the Services 
  • Payment processing 
  • Tracking how visitors use the Website 
  • Fulfilling a transaction you requested 
  • Preventing fraud 
  • Marketing our products 
  • Complying with requests from law enforcement 
  • With your consent (e.g., if you authorize us to share your Personal Information)
  • Protecting our rights, property, or safety, or that of users of Extropolis or the general public

 

We may de-identify or anonymize your information so that you are not individually identified, and provide that information to our partners. We also may combine your de-identified information with that of other users to create aggregate de-identified data that may be disclosed to third parties who may use such information to understand how often and in what ways people use our services, so that they, too, can provide you with an optimal experience. For example, we may use information gathered to create a composite profile of all the users of the Services to understand community needs, to design appropriate features and activities. However, we never disclose aggregate information to a partner in a manner that would identify you personally, as an individual.

In the event of a bankruptcy or a sale, merger, or acquisition, we may also transfer your Personal Information to a separate entity. That entity will be responsible for ensuring that your Personal Information is used only for authorized purposes and persons in a manner consistent with this Privacy Policy and applicable law.

Additionally, we may share Personal Information when it is required by a court or government agency or to respond to a Claim by you or a third party. In doing so, we may respond to any subpoena received from a court or government agency without prior notice to you. Unless prohibited by law or by a court order, we will use reasonable efforts to notify you of any subpoena received from any other party that requires us to disclose your identity and will wait ten (10) days thereafter, or a lesser amount of time as required by the deadline in the subpoena, before providing the requested Personal Information. 

Personal Information may also be shared by you, on message boards, chat, profile pages, and blogs, and other Services to which you are able to post information and materials (including, without limitation, our social media pages and apps). Please note that any information you post or disclose through these Services will become public information, and may be available to third parties who access the Extropolis Services and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Services.

We do not sell any of your Personal Information to any third parties. 

 

Retention, Confidentiality, and Security of Personal Information

We store Personal Information for as long as reasonably necessary to fulfill the purposes described above, as we determine is necessary for business records, and as required under applicable law.

We restrict access to Personal Information about you to those who need to know in order to provide products or Services to you and to conduct our internal operations. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your Information. 

Additionally, the Website is a certificate trusted website and uses security software to encrypt information before and during transmission to the internet. If we become aware of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice through the Website if a security breach occurs. We may also send an email to you at the email address you have provided to use in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

However, some of our security measures depend on the compatibility of your web browser. While we strive to protect your Information, the internet is not absolutely secure and, thus, we cannot promise guaranteed security. In the unlikely event that we believe that the security of your Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate and to the extent we have your email address, we may notify you by email. 

You should also take steps on your own to protect your Personal Information. There are steps you can take to help maintain the security of your Personal Information, such as: 

  • Using the latest version of your web browser. 
  • Keeping your username and password confidential. 
  • Accessing the Website only on personal or trusted computers. 

Please refer to the Federal Trade Commission’s website at http://www.business.ftc.gov/privacy-and-security/consumer-privacy for information about how to protect yourself against identity theft.

 

  1. Personal Information and Third Parties

Links 

The Website may include links to other websites. This Privacy Policy only applies to our Website and Services. We do not make any representations about any websites other than our own. Any Personal Information you provide to any linked websites will be subject to the privacy policies of that website. If provided, you should review the privacy policies of any linked websites carefully. 

Social Media 

The Website may include social media features, such as YouTube, Facebook, Twitter, and LinkedIn pages or widgets. These features may collect your IP address, which page you are visiting on the Website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Website. Your interactions with these features are governed by the privacy policy of the company providing it. 

Commercial Electronic Messages

By providing your email address to us, you affirmatively and expressly consent to receiving commercial emails from us and from our third-party service providers. These parties may send you commercial emails in order to deliver information about the Website, information about developments relating to products, special offers, and other information, including but not limited to updates to the Website. 

Children 

We do not knowingly collect Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through the Website. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Information on the Website without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through the Website, please contact us, and we will work to promptly delete that information from our databases.

III. Additional Relevant Provisions and Laws

We comply with the privacy laws of the U.S. and make no representation that this Privacy Policy or the Terms of Use comply with the laws of any other jurisdiction. If you choose to visit the Website, you do so at your own initiative and at your own risk and you are responsible for complying with all applicable local laws and you waive any causes of action, suits, penalties, fines, losses, damages, costs, or expenses, including attorneys’ fees (“Claims”) that may arise under such local laws. 

Enforcement and Disputes

We are committed to resolve complaints about your privacy and our collection or use of your Personal Information. If you do not receive timely acknowledgement of your request or have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. 

California Residents 

The following provisions apply only to residents of the state of California:

  1. Do Not Track. Section 22575 of the California Business & Professions Code requires website and online service operators to disclose whether they honor web browser “Do Not Track” settings. At this time, as no standard has been adopted by the World Wide Web Consortium (W3C) regarding such practices, and given current industry considerations, we generally do not respond to “do not track” signals, which you may initiate through your personal browser or device. We will update our practices and Policy as these standards evolve. For more information about Do Not Track, please visit www.allaboutdnt.org.
  2. CCPA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), to the extent it applies to Extropolis, and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You

You have the right to know:

  • The categories of Personal Information we have collected about you;
  • The categories of sources from which the Personal Information is collected;
  • Our business or commercial purpose for collecting or selling Personal Information;
  • The categories of third parties with whom we share Personal Information, if any; and
  • The specific pieces of Personal Information we have collected about you.

Please note that we are not required to:

  • Retain any Personal Information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
  • Re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Information; or
  • Provide the Personal Information to you more than twice in a 12-month period.

Personal Information Shared or Disclosed for a Business Purpose

In connection with any Personal Information we may share or disclose to a third party for a business purpose, you have the right to know:

The categories of Personal Information about you that we share or disclose and the categories of third parties to whom the Personal Information was shared or disclosed; and

The categories of Personal Information that we shared or disclosed about you for a business purpose.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sharing or disclosing of your Personal Information. 

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

  • Delete your Personal Information from our records; and
  • Direct any service providers to delete your Personal Information from their records.

Please note that we may not delete your Personal Information if it is necessary to:

  • Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with an existing legal obligation; or
  • Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

  • Deny goods or services to you;
  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Provide a different level or quality of goods or services to you; or
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your Personal Information.

 

  1. Shine the Light. We need to disclose to you that we do not share information for third party direct marketing purposes. Effective January 1, 2005, under California Civil Code Section 1798.83, if an individual who is a California resident has provided Personal Information to a business in connection with a business relationship that is primarily for personal, family, or household purposes, and if that business has within the immediately preceding calendar year disclosed such an individual’s Personal Information to a third-party and knows or should have known that such third-party used the information for its own direct marketing purposes, then that business is obligated to disclose in writing to such individual upon request, what Personal Information was shared and with whom it was shared. Any request for a disclosure required under this California law should be sent to us by regular mail as indicated by the contact section below.

Please note that under this law, we are not required to respond to a customer’s request more than once in a calendar year, nor are we required to respond to any request that is not sent to the email or mailing address designated above. 

  1. International Visitors. The Website is hosted in and provided from the United States and is mainly intended for visitors located within the United States. If you use the Website from the European Economic Area (“EEA”), the United Kingdom, Switzerland, Canada, or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your Personal Information to the United States. The United States does not have the same data protection laws as the EEA, UK, Switzerland, Canada, and some other regions. If you reside in the EEA, UK, or Switzerland, you have the right to access Personal Information we hold about you and to ask that your Personal Information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through our contact information herein. Also, we may transfer your data from the United States to other countries or regions in connection with storage and processing of data, fulfilling your requests, marketing efforts, and operating our business. By providing your Personal Information to us or our authorized vendors or partners or via the Site, you consent to the transfer of your Personal Information to the United States and the use of your Personal Information, in accordance with this Policy.

If you are a resident of the EEA, the United Kingdom, or Switzerland, you may have certain additional rights with respect to your Personal Information under the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), including, without limitation, the following:

  • the right of access to your Personal Information.
  • the right to rectify your Personal Information if it is incorrect or incomplete.
  • the right to have your Personal Information erased (“right to be forgotten”) if certain grounds are met.
  • the right to withdraw your consent to our processing of your Personal Information at any time (if our processing is based on consent).
  • the right to object to our processing of your Personal Information (if processing is based on our legitimate interests) provided that we may retain your Personal Information for certain compelling purposes such as legal, auditing, accounting, and billing purposes.
  • the right to object at any time to our processing of your Personal Information for direct marketing purposes, including, without limitation, for profiling purposes to the extent that it is related to direct marketing. If you object to processing for direct marketing purposes, we will no longer process your Personal Information for such purposes.
  • the right to receive your Personal Information from us in a structured, commonly used and machine-readable format, and the right to transmit your Personal Information to another controller without hindrance from us (data portability).

The following terms shall also apply to our collection, use, and retention of the Personal Information of applicable EEA, UK, and Switzerland residents:

Basis for collection. As set out above, we collect and process Personal Information for which you have given your express consent at the time of collection. We also collect and process Personal Information in order to improve our services, to deliver services and perform obligations under contracts we have with you, and to comply with our own legal obligations.

Sensitive data. We do not intentionally collect sensitive data, for example, biometric data, health data, or data revealing racial or ethnic origin, from visitors to our site.

Onward transfer. Except as otherwise provided in this privacy policy, we only disclose Personal Information to third parties who reasonably need to have access to it for the purpose of the transaction or activity for which it was originally collected or to provide services to or perform tasks or our behalf or under our instruction. All such third parties must agree to use such the Personal Information we provide to them only the purposes for which we have engaged them and they must either: (a) comply with a mechanism permitted by the applicable EEA, UK, & Swiss data protection law(s) for transfers and processing of Personal Information; and (b) agree to provide adequate protections for the Personal Information that are no less protective than those set out in this privacy policy. Where we have knowledge that an entity to whom we have provided Personal Information is using or disclosing Personal Information in a manner contrary to this privacy policy, we will take reasonable and appropriate steps to prevent, remediate or stop the use or disclosure.

Authorized transfer. We also may disclose Personal Information for other purposes or to other third parties when you have consented to or requested such disclosure. Please be aware that we will disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We are not liable for appropriate onward transfers of Personal Information to third parties.

Data processors. We may retain third parties to process or analyze Personal Information we collect from our site. For example, a site may be maintained or hosted by a third party service provider or a promotion may be administered by a sales promotion agency. These suppliers and other third parties who provide services for us are contractually obligated not to use Personal Information about you except as we authorize. 

Profiling. We may analyze Personal Information we have collected about you to create a profile of your interests and preferences so that we can contact you with information that is relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use Personal Information about you to detect and reduce fraud and credit risk. 

Your rights. Your rights include: (a) a right to withdraw your consent to the processing of Personal Information about you to which you have previously given consent; (b) a right to object to processing of Personal Information about you for the purpose of direct marketing; and (c) a right to have incorrect Personal Information about you corrected or removed. 

If you request to have incorrect Personal Information removed, we may retain some of your Personal Information as necessary for the purposes of our legitimate business interests or in furtherance of public interests in accordance with applicable laws. Any Personal Information you have shared publicly with others may continue to be publicly visible on the site.

You also have the right to obtain a copy of the Personal Information we have about you, although we reserve the right to charge a fee for this depending on the nature and frequency of your request(s) and our cost to provide the information. 

If you are located in the EEA, the UK, or Switzerland and the GDPR applies to you, and you are or have been our customer, we may send you marketing communications based on our legitimate interests, subject always to your right to opt out of such communications. Further, if you are located in the EEA, the UK, or Switzerland and the GDPR applies to you, we will not share your Personal Information with a third party for such third party’s marketing purposes, unless you have specifically consented to us doing so.

You may contact us as indicated below to exercise any of the above rights. We may request specific information from you to confirm your identity, and in some circumstances we may charge a reasonable fee for access to your Personal Information. We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf. Any Personal Information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

If you believe that our processing of your Personal Information is inconsistent with your data protection rights under the GDPR and we have not adequately addressed your concerns, you may have the right to lodge a complaint with the Data Protection Supervisory Authority of your country.

For purposes of the GDPR, we are a “controller” and you are a “data subject.”

 

  1. Updates, Access, Correction

Updates to this Privacy Policy; Incorporation; Scope

We may, from time to time, unilaterally modify the Privacy Policy without notice to you, so it is important that you review this Privacy Policy every time you use or access the Website. Such modifications by us are effective upon posting to the Website and your access to or use of the Website at any time constitutes acceptance of the Privacy Policy in effect at that time. Our use of Personal Information collected or obtained at any time is subject to the Privacy Policy in effect at the time of such use. 

This Privacy Policy supplements, but does not replace other applicable policies, practices, and privacy notices that may relate to specific business relationships you have with us or to certain products or Services, as described in the applicable privacy notice. At the start of our business relationship with you as a client, we will give you a copy of our privacy notice that applies to that relationship, if applicable. In the event of a conflict between this Privacy Policy and a privacy notice for a specific product or service, the specific product or service privacy notice shall govern.

Whether you use the Website or not, the provisions of the Terms of Use apply to this Privacy Policy, including without limitation, the following: Disclaimer of Warranties, Limitation of Liability, Indemnification, Choice of Law, and Dispute Resolution. We encourage you to review the Terms of Use before using the Website. 

Access and Correction of Personal Information

Certain US states give you the right to access and correct the Personal Information that we have collected from or about you. 

If you would like to exercise any of your rights as described in this Privacy Policy, please contact us as indicated below in the contact section.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period and Extropolis will be required to comply only to the extent CCPA applies to Extropolis.

If you choose to contact us directly, you will need to provide us with at least the following details:

  • Enough information to identify you (e.g., your full name, address, and any customer or matter reference number);
  • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
  • A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf. Any Personal Information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

Please be aware that there are also some types of Personal Information to which we are not required to give you access. 

  1. Contact

Contacting Extropolis 

For clarification or if you have any concerns about the Privacy Policy or Terms of Use, please write to us at: 

We will promptly investigate and attempt to respond in a manner that complies with the principles described in this Privacy Policy. 

Last Updated: March 2022