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Effective on: October 6, 2023


PRIVACY NOTICE

Introduction and Scope
Contentree (a trading name of Contentgine, Inc), together with its affiliates
and aliases described below, (collectively, “Contentree”, “we”, “us”, “our”)
takes the protection of personally identifiable information (“Personal Data”)
very seriously. Contentree provides business customers (“Customers”) with lead
generation services, including content syndication, data analytics and email
marketing services, as well as our Content Indication Platform (collectively,
the “Lead Generation Services”). This Privacy Notice (the “Notice”) addresses
how we collect, receive, use, store, share, transfer and process your Personal
Data, as well as your rights in determining what we do with the information
collected via our website and in connection with our Lead Generation Services
(collectively, the “Services”). This Notice does not apply to Personal Data we
collect by other means, such as Personal Data of our employees.
Controllership
Within the scope of this Notice, Contentree (a trading name of Contentgine,
Inc), acts as a data controller for the Personal Data we process when you visit
our websites or when you interact with us. Contentree is acting as Data
Processor for the Personal Data we process through our Services. For more
information about this, visit https://www.contentree.com/privacy
Categories of Personal Data
In this privacy policy we refer to “Leads,” “Customer Representatives” and
“Website Visitors”, as follows: (1) if you are a Lead, you are an individual
about whom we process Personal Data in connection with the Lead Generation
Services (for example, individuals who interact with content that we send in
emails on behalf of our Customers or content available on our websites); (2) if
you are a Customer Representative, you are an employee, contractor or other
individual authorized by a Customer to use our Services and we provide you with
Personal Data about the Leads; (3) if you are a Website Visitor, you are an
individual who visits our website and you do not fall under the Lead or Customer
Representative categories. If you are a Lead, we process the following types of
Personal Data about you:
 * biographical information, such as first and last name and date of birth; and
   contact information, such as email address, phone number, postal address, and
   country of residence postal;
 * employment information, such as industry, job title, company name, seniority
   within company, department name, or company size;
 * business contact information, such as company email address and postal
   address; and public LinkedIn profile;
 * analytics information, including the type of content that you engage with
   when using the Services, or after clicking a link in an outreach email;
 * device, internet and mobile information such as the hardware model, operating
   system version, unique device identifiers, browser type, language, IP
   address, wireless network, and mobile network information (including the
   mobile phone number);
 * geo-location information when you use the Services; and/or
 * records and copies of your correspondence (including e-mail addresses), if
   you contact us. This may include call recordings where we monitor and record
   such calls for staff training or quality assurance purposes.

If you are a Customer Representative, we process the following types of Personal
Data about you:
 * business contact information such as first and last name, email address,
   phone number, postal address;
 * billing and payment information, including the address for billing, billing
   contact information and credit card information;
 * device, internet and mobile information such as the hardware model, operating
   system version, unique device identifiers, browser type, language, IP
   address, wireless network, and mobile network information (including the
   mobile phone number);
 * geo-location information when you use the Services; and/or records and copies
   of your correspondence (including e-mail addresses), if you contact us. This
   may include call recordings where we monitor and record such calls for staff
   training or quality assurance purposes.

If you are a Website Visitor, we process the following types of Personal Data
about you:
 * contact information such as first and last name, email address and phone
   number;
 * device, internet and mobile information such as the hardware model, operating
   system version, unique device identifiers, browser type, language, IP
   address, wireless network, and mobile network information (including the
   mobile phone number);
 * geo-location information when you use our website; and/or
 * records and copies of your correspondence (including e-mail addresses), if
   you contact us. This may include call recordings where we monitor and record
   such calls for staff training or quality assurance purposes.

We do not process information that may be considered ‘special category’ or
‘sensitive’ Personal Data, such as health related information or information
relating to racial origin or political affiliations.
How We Receive Personal Data
If you are a Lead, we receive your Personal Data when:
 * you provide it directly to us through our Services, or by clicking a link in
   a Contentree outreach email;
 * our Customers (including Customer Representatives) provide it to us;
 * we receive it from other companies within our corporate group;
 * our service providers provide it to us;
 * we obtain lists from our business partners and data vendors with respect to
   individuals who might be interested in becoming customers of or are otherwise
   interested in our Customers;
 * you provide it on publicly accessible sources, such as on LinkedIn or your
   company website; and/or
 * such information is captured via cookies and similar technologies
   (collectively referred to as “cookies”), as outlined in the “Cookie” section
   below.

If you are a Customer Representative, we receive your Personal Data when:
 * you provide it directly to us through our Services;
 * our Customers provide it to us; and/or
 * such information is captured via cookies and similar technologies
   (collectively referred to as “cookies”) as outlined in the “Cookie” section
   below.

If you are a Website Visitor, we receive your Personal Data when:
 * you provide it directly to us through our website; and/or
 * such information is captured via cookies and similar technologies
   (collectively referred to as “cookies”), as outlined in the “Cookie” section
   below.

Purposes of Processing
If you are a Lead, we process your Personal Data to:
 * respond to your requests or questions;
 * provide you with access to the Services and the content therein, including
   content that we send you on behalf of our Customers;
 * create a record for our Customers about your interactions, which we may
   enhance with additional information about you (e.g. your name, job title,
   location and email address); and/or
 * share your Personal Data with our Customers in connection with the Lead
   Generation Services, including to help them improve their business, target
   marketing campaigns and services through different strategies.

If you are a Customer Representative, we process your Personal Data to:
 * respond to your requests or questions;
 * process and complete transactions, including to obtain sales leads, and send
   you related information;
 * provide technical and other support to you;
 * send you promotional communications, such as providing you with information
   about services, features, surveys, newsletters, offers, and events; and
   providing other news or information about us, and the Lead Generation
   Services;
 * enable our service providers to perform certain responsibilities and provide
   certain services in connection with the Lead Generation Services and our
   business and operations
 * provide you with notices about your account;
 * carry out our obligations and enforce our rights arising from any contracts
   entered into between you and us, including for billing and collection; and/or
   verify your identity and prevent fraud or other unauthorized or illegal
   activity.

If you are a Website Visitor, we process your Personal Data to:
 * provide you with access to our website;
 * respond to your requests or questions;
 * provide technical and other support to you; and/or
 * send you promotional communications, such as providing you with information
   about services, features, surveys, newsletters, offers, and events; and
   providing other news or information about us, and the Lead Generation
   Services.

Basis of Processing
We process your Personal Data on the basis of:
 * your consent (you may withdraw your consent at any time by contacting us via
   the information in the “Contact Us” section below. This will not affect the
   lawfulness of our processing before you withdrew your consent. It will also
   not affect processing performed on other lawful grounds);
 * if you are outside Canada, our legitimate interests in providing effective
   Services to our Customers and maintaining our business relationship;
 * the need to comply with the law; or
 * any other ground, as required or permitted by law.

DATA PRIVACY FRAMEWORK
Contentree complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and
the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S.
Department of Commerce.
Contentree has certified to the U.S. Department of Commerce that it adheres to
the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with
regard to the processing of personal data received from the European Union in
reliance on the EU-U.S. DPF. Contentree has certified to the U.S. Department of
Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles
(Swiss-U.S. DPF Principles) with regard to the processing of personal data
received from Switzerland. If there is any conflict between the terms in this
privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF
Principles, the Principles shall govern. To learn more about the Data Privacy
Framework (DPF) program, and to view our certification, please visit
https://www.dataprivacyframework.gov/.
Contentree is responsible for the processing of personal data it receives, under
the DPF, and subsequently transfers to a third party acting as an agent on its
behalf. Contentree complies with the DPF Principles for all onward transfers of
personal data from the EU and Switzerland, including the onward transfer
liability provisions.
The Federal Trade Commission has jurisdiction over Contentree’s compliance with
the EU-U.S. DPF and Swiss-U.S. DPF. In certain situations, Contentree may be
required to disclose personal data in response to lawful requests by public
authorities, including to meet national security or law enforcement
requirements.
In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, Contentree commits to
refer unresolved complaints concerning our handling of personal data received in
reliance on the EU-U.S. DPF and the Swiss-U.S. DPF to TRUSTe, an alternative
dispute resolution provider based in the United States. If you do not receive
timely acknowledgment of your DPF Principles-related complaint from us, or if we
have not addressed your DPF Principles-related complaint to your satisfaction,
please visit https://feedback-form.truste.com/watchdog/request for more
information or to file a complaint. These dispute resolution services are
provided at no cost to you.
For complaints regarding DPF compliance not resolved by any of the other DPF
mechanisms, you have the possibility, under certain conditions, to invoke
binding arbitration. Further information can be found on the official DPF
website.
Data Retention
We will retain your Personal Data for the period necessary for the purposes of
processing listed in this notice unless a longer retention period is required by
law or if it is reasonably necessary for us to comply with our legal
obligations, or to resolve a dispute. If you stop using our Services, we will
store your information in an aggregated and anonymized format; we may use the
anonymized information indefinitely without further notice to you.
Sharing Personal Data with Third Parties
We share Personal Data with our affiliates and Customers, as well as with our
service providers who process Personal Data on our behalf and who agree to use
the Personal Data only to assist us in providing our Services to our Customers,
or as required by law. We share Personal Data of Leads with our Customers as
specified in the “Purposes of Processing” section above. We share Personal Data
with our service providers in relation to the following services they provide to
us:
 * application hosting services;
 * cloud storage services;
 * business productivity services;
 * communication services and software;
 * email verification software;
 * customer relationship management (CRM) software; and
 * contact verification and data enrichment services

However, before transferring your Personal Data to these third parties, we will
either ask for your explicit consent or require the third party to maintain at
least the same level of privacy and security for your Personal Data that we do.
We remain liable for the protection of your Personal Data that we transfer or
have transferred to third parties through our designated data transfer
mechanism, except to the extent that we are not responsible for the event that
leads to any unauthorized or improper processing.
Personal Data may be stored or processed by us and/or our third party service
providers outside of your jurisdiction, including to the United States. When
this occurs, your information may be accessible without notice to you by the
courts, law enforcement and national security authorities of that jurisdiction.
We may also transfer Personal Data to third countries outside of the European
Union, the EEA, the UK or Canada. The European Commission and/or the UK
government may have determined that some of these third countries do not provide
an adequate level of protection with respect to Personal Data. We will only
transfer your Personal Data to third parties in these countries when there are
appropriate safeguards in place. These include the Standard Contractual Clauses
(“SCCs”) as approved by the European Commission or the equivalent mechanism
approved by the UK government. Such mechanisms are formally integrated into our
agreements with third parties when the processing is subject to EEA and/or UK
data protection laws.
Other Disclosure of Your Personal Data
We disclose your Personal Data to the extent required by law, or if we have a
good-faith belief that we need to disclose it in order to comply with official
investigations or legal proceedings (whether initiated by governmental/law
enforcement officials, or private parties). We may also disclose your Personal
Data if we sell or transfer all or some of our company’s business interests,
assets, or both, or in connection with a corporate restructuring. Finally, we
may disclose your Personal Data to our subsidiaries or affiliates, but only if
necessary for business purposes, as described in the section above. We reserve
the right to use, transfer, sell, and share aggregated, anonymous data for any
legal business purpose. Such data does not include any Personal Data. The
purposes may include analyzing usage trends or seeking compatible advertisers,
sponsors, and customers.
Direct Marketing
Where required by applicable law, we will only send you direct marketing
communications, such as through email, including offers any news and exclusive
offers, promotions, or events, where you have consented to do so. You may
opt-out of receiving direct marketing communications at any time by contacting
us or by using opt-out facilities provided in the direct marketing
communications.
Cookies
A “cookie” is a small file stored on your device that contains information about
your device. We may use cookies to provide basic relevant ads, website
functionality, authentication (session management), usage analytics (web
analytics), and to remember your settings, and generally improve our websites
and services.
We use session and persistent cookies. Session cookies are deleted when you
close your browser. Persistent cookies may remain even after you close your
browser, but always have an expiration date. Please refer to the policies of
these third parties to learn more about the way in which they collect and
process information about you.
If you would prefer not to accept cookies, you can change the setup of your
browser to reject all or some cookies. For more information, please visit
https://www.aboutcookies.org/.
Currently, various browsers offer a “do not track” or “DNT” option which sends a
signal to websites visited by the user about the user’s browser DNT preference
setting. We do not currently commit to responding to browsers’ DNT signals with
respect to our website, in part, because no common industry standard for DNT has
been adopted, including no consistent standard of interpreting user intent.
We and third parties on our digital properties may use cookies and similar
tracking technologies to collect information and infer your interests for
interest-based advertising purposes. If you would prefer to not receive
personalized ads based on your browser or device usage, you may generally
express your opt-out preference to no longer receive tailored advertisements.
Please note that you will continue to see advertisements, but they will no
longer be tailored to your interests.
To opt-out of interest-based advertising by participating companies in the
following consumer choice mechanisms, please visit:
- Digital Advertising Alliance (DAA)’s self-regulatory opt-out page
(http://optout.aboutads.info/) and mobile application-based "AppChoices"
download page (https://youradchoices.com/appchoices)
- European Interactive Digital Advertising Alliiance (EDAA)'s consumer opt-out
page (http://youronlinechoices.eu)
- Network Advertising Initiative (NAI)’s self-regulatory opt-out page
(http://optout.networkadvertising.org/).
Data Integrity & Security
We have implemented and will maintain technical, administrative, and physical
measures that are reasonably designed to help protect Personal Data from
unauthorized processing. This includes unauthorized access, disclosure,
alteration, or destruction. Such measures, which may necessarily evolve over
time as the availability and effectiveness of methods vary, include physical,
organizational and technological safeguards.
Still, no system can be guaranteed to be 100% secure. If you have questions
about the security of your Personal Data, or if you have reason to believe that
the Personal Data that we hold about you is no longer secure, please contact us
immediately as described in this Privacy Notice.
Your California Privacy Rights
California Civil Code Section §1798.83 permits users of the Site that are
California residents to request certain information regarding our disclosure of
Personal Data to third parties for their direct marketing purposes. To make such
a request, please send an e-mail to us at: privacy@contentree.com or write to us
at: Contentree, 316 California Ave. #47, Reno, NV, 89509.
If you are a California resident, you may have rights under the Consumer Privacy
Act of 2018 and the related regulations (the “CCPA”) regarding your “Personal
Information” (as defined in the CCPA.) This section does not apply to
information exempted from the scope of the CCPA.
The below table explains our practices in the preceding 12 months related to the
categories and types of Personal Information that we collect about you and the
categories of third parties that we disclosed and/or sold this information to.
We do not have actual knowledge that we sell Personal Information of individuals
under 16 years of age.

Category Types of Information Categories of recipients for a business purpose
Categories of recipients for selling Identifiers Name, title, business email
address, business address, business phone number Our affiliates, cloud storage
providers, payment processors, security vendors, website hosting vendors
Customers (to provide the Lead Generation Services) Personal information listed
in the California Customer Records statute (which may overlap with other
categories) Name, address, phone number Our affiliates, cloud storage providers,
payment processors, security vendors, website hosting vendors Customers (to
provide the Lead Generation Services) Characteristics of protected
classifications None Our affiliates, cloud storage providers None Geolocation
data Business address Our affiliates, cloud storage providers, payment
processors, security vendors, website hosting vendors Customers (to provide the
Lead Generation Services) Commercial information None Our affiliates, cloud
storage providers, payment processors, security vendors, website hosting vendors
None

As a California resident, you may have the rights listed below in relation to
Personal Information that we have collected about you. However, these rights are
not absolute, and in certain cases, we may decline your request as permitted by
law.
 * Right to Know. You have a right to request the following information about
   our collection, use and disclosure of your personal information over the
   prior 12 months, and ask that we provide you with a copy of the following:
   * categories of and specific pieces of personal information we have collected
     about you;
   * categories of sources from which we collect personal information;
   * the business of commercial purposes for collecting personal information;
   * categories of third parties to whom the personal information was disclosed
     for a business purpose; and
   * categories of personal information disclosed about you for a business
     purpose.
 * Right to Delete. You have a right to request that we delete personal
   information, subject to certain exceptions.
 * Right to Opt Out. You have a right to opt out of the sale of your personal
   information to third parties. To opt out of the sale of your personal
   information, please click the “Do Not Sell My Info” link or reach out using
   one of the methods outlined below.

To submit a request to exercise any of your California privacy rights, please
contact us by emailing privacy@contentree.com.
We may need to verify your identity before processing your request, and may ask
you for limited information, such as your email address, government issued ID
before providing a substantive response to the request. You may designate, in
writing or through a power of attorney document, an authorized agent to make
requests on your behalf to exercise your rights. Before accepting such a request
from an agent, we will require that the agent provide proof you have authorized
them to act on your behalf, and we may need you to verify your identity directly
with us.
We will not discriminate against you for exercising any of your rights under the
CCPA.
Other Privacy Rights
Depending on where you live, you may have some or all of the rights listed below
in relation to information that we have collected about you. However, these
rights are not absolute, and in certain cases, we may decline your request as
permitted by law. :
 * Confirmation of existence of processing: you may have the right to confirm
   that we process Personal Data about you;
 * Access: you may have the right to access Personal Data we hold about you, how
   we use it, and who we share it with;
 * Portability: you may have the right to receive a copy of the Personal Data we
   hold about you and to request that we transfer it to a third party, in
   certain circumstances and with certain exceptions;
 * Correction: you may have the right to correct any of your Personal Data we
   hold that is inaccurate;
 * Anonymization: you may have the right to anonymization, blocking or
   elimination of Personal Data that is unnecessary, excessive or processed in a
   way that is noncompliant with the provisions of laws of certain
   jurisdictions;
 * Erasure: you may have the right to delete the Personal Data we hold about
   you;
 * Restriction of processing to storage only: you may have the right to require
   us to stop processing the Personal Data we hold about you, other than for
   storage purposes, in certain circumstances;
 * Objection: you may have the right to object to our processing of your
   Personal Data. We will stop the relevant processing unless: (i) we have
   compelling legitimate grounds for the processing that override your
   interests, rights, or freedoms, or (ii) we need to continue processing your
   Personal Data to establish, exercise, or defend a legal claim;
 * Information regarding entities with whom data shared: you may have the right
   to information regarding the public and private entities with whom we have
   shared use of your Personal Data;
 * Information on consent: you may have the right to information on the
   possibility of not providing consent, and on the effects of consent denial;
 * Objection to marketing: you can object to marketing at any time by opting-out
   using the unsubscribe/ opt-out function displayed in our communications to
   you; and
 * Withdrawal of consent: where we rely on consent to process your Personal
   Data, you may have the right to withdraw this consent at any time by
   contacting us via the information in the “Contact Us” section below.

Some of the above rights only apply in certain circumstances, and all of these
rights may be limited by law. For example, where fulfilling your request would
adversely affect other individuals or our trade secrets or intellectual
property, where there are overriding public interests or where we are required
by law to retain your Personal Data.
We sometimes use computers to study your Personal Data. We might use this
Personal Data so we can attempt to predict your buying behavior and interests.
Depending on where you live, for decisions that may seriously impact you, you
may have the right not to be subject to automatic decision-making or the right
to request the revision of the decisions made solely on the basis of automatic
processing of your Personal Data, including profiling. But in those cases, we
will always explain to you when we might do this, why it is happening and the
effect.
Contentree has limited rights to access Personal Data our service providers
submit to us. Therefore, if you contact us with such a request, we will forward
your request to that service provider and provide any needed assistance as they
respond to your request. To exercise any of these rights or raise any other
questions, please contact us by using the information in the “Contact Us”
section below.
Privacy of Children
The Services are not directed at, or intended for use by, children under the age
of 13. If you believe we have inadvertently collected information about your
child, please contact us and we will attempt to delete the information.
U.S. Regulatory Oversight
Contentree is subject to the investigatory and enforcement powers of the United
States Federal Trade Commission.
EEA and UK Supervisory Authority Oversight
If you are located in the EEA and/or the UK and we process your Personal Data
subject to the data protection laws of these jurisdictions you have the right to
lodge a complaint with a data protection regulator in the EEA country in which
you live or work or where you think we have infringed data protection laws, or
with the UK Information Commissioner’s Office, as applicable to you.
Affiliates and Newsletter Domains
Contentree is affiliated with Intentgine, Inc.
Contentree also operates under several aliases, which it refers to as its
“Newsletter Domains”. The following Newsletter Domains are owned and operated by
the companies in our corporate group:
 * Analytics Platform Solutions <analyticsplatformsolutions.com>;
 * B2B Demand Gen Solutions <b2bdemandgensolutions.com>;
 * Blockchain Software Solutions <Blockchainsoftwaresolutions.com>;
 * Cloud Info Hub <cloudinfohub.com>;
 * Contentreads <contentreads.com>;
 * Human Resources Briefings <humanresourcesbriefings.com>;
 * Info Business Tech <infobusinesstech.com>;
 * IT Local Gov <itlocalgov.com>;
 * IT Security World <it-securityworld.com>;
 * IT Solutions Report <itsolutionsreport.com>;
 * Sales CRM Solutions <salescrmsolutions.com>;
 * Tech Marketing Web <techmarketingweb.com>; and
 * Video Conference Solutions <vidconferencesolutions.com>.

Additional Newsletter Domains may be adopted from time-to-time, without notice
to you.
Changes to this Notice
We may update this Privacy Notice and its effective date to reflect changes to
our data governance practices. If we propose to make any material changes, we
will notify you by means of a notice on this page. We encourage you to
periodically review this page for the latest information on our privacy
practices.
Contact Us
If you have any questions about this Notice or our processing of your Personal
Data, please write to us by email at privacy@contentree.com or by postal mail
at:
Contentree, Inc. DBA Contentgine
Attn: Paul Hong, COO
316 California Ave #47
Reno NV 89509
United States

Please allow up to four weeks for us to reply.
If you 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.

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