Privacy

Ocurate Privacy Notice

Last Updated: April 7, 2022

This Privacy Notice explains how Ocurate, Inc. (“Ocurate”, “we”, “us”, “our”) collects, uses, discloses, and otherwise processes personal information in connection with the services we provide (the “Services”),including through any websites and mobile applications that link to this Privacy Notice. This Privacy Notice is not a contract and does not create any legal rights or obligations.

About Us: Ocurate uses artificial intelligence to help leaders understand the value and affinity of their consumers and constituents by fostering strong connections with a product or platform. For example, using our own proprietary database and information provided by our clients, we help clients to predict customer lifetime value for e-commerce businesses.

‍What is Personal Information?

When we use the term“ personal information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to you.

Sources of Personal Information

Ocurate collects personal information from sources including:

Public Records and Publicly Available Information, such as voter registration information and identifying information from credit files, where permitted bylaw. This information may include your name, age, political party affiliation, marital status, address, and aggregated data such as income data, online identifiers ,and employment-related information.

Survey Information, including information from individuals who have permitted us to monitor their media consumption and online behaviors. This information may include demographic information you choose to provide about your race, ethnicity, gender or political affiliation and responses to questions about your foundational attitudes about the world.

Inference Information, including inferences we derive from other personal information we process in connection with the Services, such as information relating to consumer preferences and personality traits.

Information You Provide, such as contact information or other information that you share when communicating with us.

Information Our Clients Provide, such as customer IDs, transaction history, production data, product usage and purchase data. (Please note that we only use this information to provide our Services to specific clients. For more information about our client’s privacy practices, we encourage you to contact our clients directly.)

Personal Information Automatically Collected

As is true of many digital platforms, we and our third-party partners may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies, and logging technologies (collectively, “cookies”) to automatically collect this personal information. The personal information that may be automatically collected includes:

Log File Data, including your internet protocol (IP)address, operating system, browser type, browser id, date/time of visit, and pages visited.

Analytics Data, including the electronic path you take to our Services, through our Services and when exiting our Services, as well as your usage and activity on our Services, such as the links and object you view, click, or otherwise interact with (also known as “Clickstream Data”.

Location Data, including your general geographic location based on your IP address or more precise location when accessing our Services through a mobile device.

To manage cookies, you may change your browser settings to: (i) notify you when you receive a cookie, so you can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies. Please note that doing so may negatively impact your experience using our Services, as some features and offerings may not work properly or at all. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all browsers and devices, you will need to do so on each browser on each device that you use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our emails or performed certain functions with them.

Our Use of Personal Information

We use personal information we collect to:

Provide our Services: We use your personal information to provide our clients with our Services, including by using artificial intelligence to predict customer lifetime value for our clients. For example, Ocurate has leveraged its deep learning framework and unique data to create a profile of clients’ highest value customers. The profiles include insights tied to foundational personality traits (such as neurotic or compassionate), behaviors (such as geographic distribution), and attitudes(such as political preferences).

Monitor the performance of and improve our Services: We use your personal information to measure the performance of our services, fix issues, conduct analytics and research, and improve and otherwise develop the features and functionalities of our Services, including by means of machine learning and anonymized analysis.

Communicate with you, market to you and deal with complaints: We use your personal information to send you communications relating to our Services and for marketing purposes. We also may use your personal information to address any comments or complaints you submit to us.

Maintain the safety and security of our services: We use your personal information to detect and prevent fraud, abuse, or other harmful activities, diagnose and fix technology problems, conduct security investigations and risk assessments, and improve and enforce our security measures.

Legal and regulatory requirements and proceedings: We use your personal information in connection with legal and regulatory proceedings and requirements, including the defense of legal claims, responding to law enforcement requests, and for compliance with corporate reporting obligations, and compliance with applicable laws.

If you choose to contact us, we may need additional information to fulfill your request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.

Our Disclosure of Personal Information

We disclose personal information in the following ways:

With Our Affiliates: We may share personal information with other companies owned or controlled by Ocurate, Inc. and other companies under common ownership with Ocurate, Inc. which include subsidiaries (any organization we own or control) or parent companies (any organization that owns or controls us) and any subsidiaries they own, particularly when we collaborate in providing Services.

With Service Providers: We may share personal information with service providers to help us deliver our Services, develop suggestions, fulfill requests on our sites, and improve our Services.

With Other Businesses as Needed to Provide Services: We may share personal information with third parties that you engage with through our Services or as needed to fulfill a request or transaction including, for example, payment processing services, financing providers.

Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.

Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:

  • In connection with the establishment, exercise, or defense of legal claims;
  • To comply with laws or to respond to lawful requests and legal process;
  • To protect the rights and property of us, our agents, clients, and others, including to enforce our agreements, policies, and terms of use;
  • To detect, suppress, or prevent fraud;
  • To reduce credit risk and collect debts owed to us;
  • To protect the health and safety of us, our clients, or any person; or
  • As otherwise required by applicable law.

Consent: We will not disclose personal information about you to certain other third parties without your consent.

Children’s Personal Information

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you are under the age of 13, please do not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information, we collect has been provided by a child under the age of 13, we will promptly delete that personal information.

Third-Party Websites

Our Services may include links to third-party websites, plug-ins, and applications. Except where we post, link to, or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

Region-Specific Disclosures

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions, or states. Please refer below for disclosures that may be applicable to you:

  • If you are a resident of the State of California in the United States, please click here[CD1] for additional California-specific privacy disclosures.
  • If you are a resident of the State of Nevada in the United States, Chapter 603A of the Nevada Revised Statutes permits you to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us as set forth below.

Updates to This Privacy Notice

We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the "Last Updated" date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify you by email to your registered email address, by prominent posting on this website or through our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to admin@ocurate.com

Alternatively, inquiries may be addressed to:

Ocurate, Inc, 2443 Fillmore St #3801812, San Francisco, CA 94115

Additional California Privacy Disclosures

Last Updated: April 7, 2022

Scope of Disclosures

These Additional California Privacy Disclosures (the "CA Disclosures")supplement the information contained in our Privacy Notice and apply solely to individual residents of the State of California ("consumers" or "you").

These CA Disclosures provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).

Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Notice[A4]  or as otherwise defined in the CCPA.

Personal Information Disclosures

When we use the term “personal information” in these CA Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

For the purposes of these Disclosures, personal information does not include:

  • Information provided to us by our clients solely for the purpose of providing Services to them. (For more information about our clients’ privacy practices, please contact them directly.)
  • Deidentified, aggregated or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you.
  • Information relating to our job applicants, employees, contractors, and other personnel.
  • Information about employees and other representatives of third-party clients or entities we may interact with.

Other information excluded from the CCPA's scope, such as:

  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Collection and Use of Personal Information

In the last 12 months, we have collected the following categories of personal information from the categories of sources and for the purposes set forth below, which reference the personal information, sources and purposes described in the Sources of Personal Information and Our Use of Personal Information sections of our Privacy Notice:

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We use the categories of personal information listed above for the purposes set out in the “Our Use of Personal Information” section of our Privacy Notice:

Disclosure and Sale of Personal Information

In the last 12 months, we have disclosed for a business purpose and sold the following categories of personal information, which reference the categories of personal information described above:

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Recipients of Personal Information

As described in the Our Disclosure of Personal Information [A1] section of the Privacy Notice, we share personal information with various of third parties for business purposes, or we may sell your personal information to third parties, subject to your right to opt out of those sales.

Your California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):

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How to Exercise Your California Privacy Rights

To exercise your right to know and/or right to deletion, please submit a request by:

·        Emailing [admin@ocurate.com] with the subject line “California Rights Request,”

We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems.  Although we try to limit the personal information collected in connection with a request to exercise the right to know and/or the right to deletion to that personal information, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity.

To Exercise Your Right to Opt Out of Personal Information Sales

Unless you have exercised your Right to Opt Out of Personal Information Sales, we may sell personal information (including the inferences we derive from other personal information) to third parties for monetary or other valuable consideration. The third parties to whom we sell personal information may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties.

To exercise your Right to Opt Out of Personal Information Sales, please submit a request by clicking the following link:

Do Not Sell My Personal Information

You do not need to create an account with us to exercise your Right to Opt Out of Personal Information Sales. However, we may ask you to provide additional personal information so that we can properly identify you in our dataset and to track compliance with your opt out request. We will only use personal information provided in an opt out request to review and comply with the request. If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.

Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by contacting us at admin@ocurate.com.

Cookies, Analytics and Personalized Advertising

As is true of many digital platforms, we allow certain third-party partners and providers to collect information about consumers directly through our Services for purposes of analyzing and optimizing our Services and ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. We may also use third-party partners to collect certain personal information directly from your browser or device when you visit or interact with our Services for the purpose of serving relevant advertisements on our site, as well as on other websites or mobile applications, or personalize content or perform other advertising-related services such as reporting, attribution, analytics, and market research. These third-party businesses will use personal information for their own purposes in accordance with their own privacy notice or privacy policy, which may include reselling this information to additional third parties. To the extent the practices described in this paragraph are interpreted to constitute a “sale” under the CCPA, please see the “Personal Information Automatically Collected” section of our Privacy Notice for more information including how to exercise your rights to opt-out of cookies, analytics, and personalized advertising.

Minors Under Age 16

We do not and will not “sell” the personal information of consumers we know to be less than 16years of age, unless we receive affirmative authorization (the “Right to OptIn”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.

"Shine the Light"

California's" Shine the Light" law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please click the link below.

Do Not Sell My Personal Information

PLEASE NOTE: to opt-out of all disclosures to third parties for direct marketing purposes, you must provide your personal information to be added to our suppression list.

Authorized Agent

You may designate an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.

Request Statistics

Click here for annual statistics about the requests to exercise California privacy rights we receive, fulfill and deny.

‍Updates to These CA Disclosures

We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the "Last Updated" date at the beginning of these CA Disclosures. If we make material changes to these CA Disclosures, we will notify you by email to your registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

‍Contact Us

If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to admin@ocurate.com

Alternatively, inquiries may be addressed to:

Ocurate, Inc, 2443 Fillmore St #3801812, San Francisco, CA 94115

Additional California Privacy Disclosures

Last Updated: April 7, 2022

The following chart displays the annual statistics for our consumer request processes, which is designed to provide you with greater transparency into our privacy practices.

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