• Registration or Contact Information such as first and last name and email address, unique identifiers such as your account name and phone number
• Profile Information such as photos, profile description, date you joined Benable
• Payment and Transaction Information processed by our payment processing partner including payment card type, last 4 digits of payment card, transaction history, billing address, phone number, and email
• Information you submit including consumer profiles, your lists and recommendations, your "viewing" activity, comments, photos, videos, audio, any other information you submit on the Services, reviews and feedback you provide about our Services
• Customer service information such as questions and other messages you address to us directly through online forms, by email, over the phone, or by post, and summaries or voice recordings of your interactions with customer care
• Demographic and interest information that you volunteer such as age / date of birth, zip code, gender, race, ethnicity, sexual orientation, political opinions, religious beliefs, union membership*
• Employment or Education Information such as education history, employment experience, business contact information, and union or guild membership
• Social media information (which may include contact information, photos, location, user generated content, demographic information). Information you provide to us directly through our pages on social networking and blogging platforms (e.g., Facebook, Instagram, Snapchat, WordPress, and Twitter). If you link your account or access the Services through a third-party connection or log-in, we may have access to any information you provide to that social network depending on your privacy settings such as your name, email address, friend list, photo, gender, location, and current city
• Other information you choose to provide directly to Benable in connection with your use of the Services

*Submission by you of these categories of Personal Data is optional.

Information We Collect Automatically

• Device information and identifiers such as IP address, time zones, browser type and language, operating system, ISP provider, platform type, device type, software and hardware attributes, and unique device, advertising, and app identifiers
• Internet network and device activity data such as information about files you download, domain names, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, products, goods or services viewed, forms you complete or partially complete, search terms, uploads or downloads, the URL that referred you to our Services, the web sites you visit after this web site, if you share our content to social media platforms, and other web usage activity and data logged by our web servers, whether you open an email and your interaction with email content, access times, error logs, and other similar information. See "Cookies and Other Tracking Technologies" below for more information about how we collect and use this information.
• Geolocation information such as country, city, state and ZIP code associated with your IP address, time zones, and precise geolocation information from GPS-based functionality on your mobile devices, with your permission in accordance with your mobile device settings*
• If you choose to enable the optional Benable Keyboard on your mobile device, this section also applies to you.
  • What the keyboard does. The Benable Keyboard lets you convert links into your shareable Benable links and access your existing Benable links, lists, and recommendations from within other apps, while logged in to your Benable account.
  • Information processed. When you paste or type a link into the Benable Keyboard’s convert feature, that link is sent to our servers to create your shareable Benable link, and is associated with your account like any other link you submit to the Services. We also automatically collect limited usage information about the keyboard itself, such as whether a link conversion succeeded or failed and related timing and error information, which we use to operate, troubleshoot, and improve the keyboard.
  • What we do not collect. The Benable Keyboard does not log, store, or transmit what you type in other apps or with other keyboards. We only process content that you actively type or paste into the Benable Keyboard’s own features (such as its convert field or search bar). The keyboard does not collect your typing history, contacts, or the content of your conversations, and your device automatically prevents third-party keyboards like ours from being used in secure fields such as password fields.
  • “Allow Full Access” permission. Your device requires keyboards to request the “Allow Full Access” permission in order to connect to the internet. The Benable Keyboard uses this permission solely to communicate with Benable’s servers to provide the features described above. You can turn the Benable Keyboard or its Full Access permission off at any time in your device’s keyboard settings.
  • Information collected through the Benable Keyboard is otherwise handled as described in the rest of this Privacy Policy.

Categories of Sources of Personal Data

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

• You, when you provide information to us or when you use the Services and such information is collected automatically
• Public Records
  • From the government or other sources
• Third Parties
  • Analytics vendors and Commercial data sources
    • We may use analytics vendors to analyze how you interact and engage with the Services.
    • We may use vendors or commercial data sources to obtain information to generate leads and create user profiles.
    • Third parties may help us provide you with customer support.
  • Advertising Partners
    • We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements, or communications.
  • Social Networks
    • If you provide your social network account credentials to us or otherwise sign into the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.
  • Other Users
    • Other users of our Services may upload content containing Personal Data or content that allows users to make inferences regarding Personal Data.

*Please note: Certain information such as precise location, union membership, race or ethnicity information is considered "sensitive" under certain laws. If we process information that is deemed sensitive under applicable law, we do so as permitted by and in accordance with applicable legal requirements.

Our Commercial or Business Purposes for Collecting Personal Data

• Providing, Customizing and Improving the Services
  • Creating and managing your account
  • Providing you with the products, services, or information you request
  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Benable or the Services
  • Providing support and assistance for the Services
  • Improving the Services, including testing, research, internal analytics, and product development
  • Personalizing the Services, website content, and communications (and sending them to you) based on your preferences
  • Conducting fraud protection, security, and debugging
  • Carrying out other business purposes stated when collecting your Personal Data
• Marketing the Services
  • Marketing the Services
  • Showing you advertisements, including interest-based or online behavioral advertising
  • Sending marketing 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, Benable, or another party
  • Enforcing any agreements with you
  • Responding to claims that any posting or other content violates third-party rights
  • Resolving disputes

How We Disclose Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section.

• Service Providers. These parties help us provide the Services or perform business functions on our behalf, including hosting, technology and communication providers, support and customer service vendors, product fulfillment and delivery providers, analytics providers, and payment processors
  • Our payment processing partners collect your voluntarily provided payment card information necessary to process your payment. Please see the payment processing partners' terms of service and privacy policy for information on its use and storage of your Personal Data.
• Advertising Partners. These parties, such as ad networks and marketing providers, help us market our services and provide you with other offers that may be of interest to you.
• Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They may include:
  • Companies that track how users found or were referred to the Services
  • Companies that track how users interact with the Services
• Parties You Authorize, Access or Authenticate
  • Social media services
  • Other users of our Services you authorize as followers
• Other Users. Depending on your privacy settings, this could include any other users of our Services.
• The Public
  • Please note that the following information will be viewable publicly (e.g. by Google search) depending on your settings:
    • Full Name you enter into the Services
    • Username you choose to use the Services
    • Date you join the Services
    • Profile photo, if you added one
    • Profile cover photo, if you added one
    • Your profile description & links you add
    • The number of lists you post using our Services and recommendations you added
    • The number of accounts that follow your account and the number of accounts you follow

Legal Obligations

We may share any Personal Data that we collect when required by law or as necessary to protect our users and Services including as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, or property of the Services, our employees or agents or users, or to comply with applicable law or legal process, including responding to requests from public and government authorities.

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), or in contemplation of, or during due diligence related to such a corporate transaction. Should one of these events occur, we will make reasonable efforts to notify you as required by law before your information becomes subject to different privacy policies.

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.

Tracking Tools, Advertising and Opt-Out

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).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services' content for those who engage with our advertising. For example, Google LLC ("Google") uses cookies in connection with its Google Analytics services. Google's ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google's use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
• Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled "Information about Interest-Based Advertisements."

Information about Interest-Based Advertisements

We may serve advertisements and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors, and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors ("Interest-Based Ads"). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users' activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a "web beacon") from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit, or set their own Cookies on your browser, just as if you had requested a web page from their site.

Data Security and Retention

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 process 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 you have an open account with us or as otherwise necessary to provide you with our Services. 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.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16 years of age. If you are a child under the age of 16, 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 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at [email protected].

Your Rights and Choices

Marketing Communications

You can unsubscribe from Benable marketing emails by clicking the unsubscribe link in a marketing email.

Cookies and Other Similar Technologies

Depending on your jurisdiction, you may be provided an option to limit the application of certain Cookies when you first visit our website. You may also be able to choose 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.

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/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union or United Kingdom.

If you replace, change, upgrade, or reset your browser or device, or delete your cookies, or if you use a browser that automatically clears your cookies, you will need to do this again.

We do not respond to browser-based do-not-track signals.

Rights Regarding Your Information

Depending on your jurisdiction (e.g, EU, UK), you may have the right to make certain requests related to your personal information. For example, you may have the right to ask us to:

• Provide you access to or a copy of certain personal information
• Correct or update personal information
• Delete certain personal information
• Restrict or opt you out of certain uses of your information (right to object)
• Withdraw any consent that you previously provided, and
• Provide you with certain details regarding the processing of your information

Please note that certain information may be exempt from such requests under applicable law and certain laws may not apply to us. For example, we need certain information in order to provide the Services to you, so we can't delete it while still providing you with the Services.

To exercise the rights described above, you or your authorized agent (if applicable and as described below) must send us a communication that describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. We will take reasonable steps to verify your identity before responding to certain requests, which may require verifying your name and email address. If we are unable to verify your identity, we may be unable to respond to your requests.

You may also authorize an 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.

You (or where applicable, your authorized agent) may submit a request by emailing us at [email protected] or here.

Depending on applicable law, you may have the right to appeal our decision to deny your request. You may email us such appeal at [email protected]. For residents of the EU and UK, you also have the right to lodge a complaint with a supervisory authority.

Additional Information for Residents Outside of the United States, including the European Union and United Kingdom

In most circumstances, Benable will be the controller of your Personal Data processed in connection with the Services.

Note that we may also process Personal Data of our customers' end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

Legal Basis for Processing Personal Data

Under certain laws, such as those in the UK and EU, we are required to disclose our legal basis for processing your Personal Data. We process your Personal Data as follows.

• Contractual Necessity: We process Personal Data as a matter of "contractual necessity", meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
• Legitimate Interest: We process Personal Data when we believe it furthers our legitimate interests. Examples of these legitimate interests include (as described in more detail above):
  • Customizing and improving the Services
  • Marketing the Services
  • Corresponding with you
  • Enforcing legal terms
  • Completing corporate transactions
• Legal Requirements: We process Personal Data as required to comply with our legal requirements.
• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data.
• Other Processing Grounds: From time to time, we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

EU and UK Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth in the Rights section above. For more information about these rights, or to submit a request, please email us at [email protected]. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

Transfers of Personal Data

The Services are hosted and operated in the United States ("U.S.") through Benable and its service providers. If you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Benable in the U.S. and will be hosted on U.S. servers, and you acknowledge that Benable will transfer, store, and process your information to and in the U.S., and possibly other countries.

Changes to this Privacy Policy

We're constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any material changes either by placing a notice on the Benable website, or by sending you an email, and/or by some other means. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information

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:

• www.benable.com
• [email protected]