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3dna Corp. Privacy Policy

Updated: January 1, 2024

 

3dna Corp. dba NationBuilder (“3dna,” “NationBuilder,” “we,” “us” or “our”) respects privacy of our users. This privacy policy (“Privacy Policy”) describes the types of information we may collect from you or that you may provide when you use our nationbuilder.com website or our actionbutton.org website (“Websites”), or when you use our services (collectively, “Services”) and describes our practices for collecting, using, maintaining, protecting and disclosing that information. This Privacy Policy applies to the data collected by us or those acting on our behalf. It does not apply to data collected through other sites, products, or services not approved by us.

By using or accessing our Websites or the Services in any manner, you acknowledge that you accept the practices and policies described in this Privacy Policy, and that we may collect, use, and disclose your information as described herein. If you do not agree with our policies and practices, your choice is not to use our Websites or our Services. We collect your information in order to deliver our Websites and Services to you more efficiently. If you do not provide us with the necessary information, we will not be able to deliver all the features of our Websites and/or Services to you as intended. Remember that your use of our Services is at all times subject to the NationBuilder Master Terms of Service (available at Master Terms of Service) or the ActionButton Terms of Service (available at the ActionButton Terms of Service), both of which incorporate this Privacy Policy (collectively the “Master Terms”). Any capitalized terms we use in this Privacy Policy without defining them have the definitions given to them in the Master Terms.

If you are a resident of or subject to data privacy laws or regulations of a country outside of the United States, please see the additional Privacy Policy terms at the end of this document.

What does this Privacy Policy Cover?

This Privacy Policy applies to information we collect, including:

  • In email, text and other electronic messages between you and us.
  • When and where available, through mobile and desktop applications.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.

This Privacy Policy does not apply to information collected by:

  • Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on our website.

This Privacy Policy also does not apply to information that has been de-identified, anonymized, aggregated and/or otherwise processed so as to be unidentifiable (i) in such a way that the data can no longer be attributed to a specific individual, or (ii) in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (the foregoing is referred to as “De-Identified Information”). We may use and disclose De-Identified Information for any purpose at our discretion.

We gather various types of information from our users, as explained in more detail below, and we use this information in connection with our Services, including to:

  • to personalize and improve our Services;
  • to allow you to set up a user account and profile;
  • to contact you and allow other users to contact you;
  • to fulfill your requests for certain products and services;
  • to provide and improve the Services; and
  • to analyze how you use the Services.

In certain cases, we may also disclose some information to third parties, but only as described below.

Please note that some of our Services may allow you to provide us with iInformation regarding your own users, visitors, supporters or voters (“Third Party Information”). This Privacy Policy deals with our use of your own information, and not Third Party Information that you may provide to us in connection with the Services.

We are not responsible for the practices of sites linked from the Services, or for the privacy practices of nations or actionbuttons that are run by our customers on the Services, and you are advised to review their rules and policies before interacting with any of these sites, nations or actionbuttons before providing them with any private information.

Information We Collect About You and How We Collect It

We may collect the following information from you, including:

  • Your name
  • Your job title
  • Your email address
  • Your phone number
  • Your employer

We collect this information:

  • Directly from you when you provide it to us. When you sign up for the Services, you provide us with information such as your name and email address. In jurisdictions where it is permitted, we may also collect information from your public social media accounts and use it to better provide you with products and services that may be relevant to you.
  • From third parties, for example, our business partners.

Information You Provide to Us. The information we collect on or through our Services may include:

  • Information that you provide by filling in forms. This includes information provided at the time of registering to use our Services, subscribing to or purchasing our services, posting material or requesting further services. We may also ask you for information when you report a problem with our Services.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Services and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Services.
  • Your search queries on the Services.
  • Information of your customers, users, and visitors, and their customers, users, and visitors which they provide or you obtain through the use of our Services, including, but not limited to, contact information, fundraising, and transaction payment data. You are responsible for obtaining any consents and permissions for the collection, storage, processing, disclosure, and transfer of any such information required by applicable law or to allow us to use, process, transfer, etc., such information as set forth in this Privacy Policy (and as revised hereafter).

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Content”). Your User Content is posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to disclose your User Content. Therefore, we cannot and do not guarantee that your User Content will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

  • Device and usage information, which may include the type of device you are using, your operating system, your browser type, your browser language, your internet service provider, your domain name, your internet protocol (IP) address, your device and mobile ad identifiers, the website that referred you to our website, the web pages you view (including the date and time you viewed them), the services or functionality you access or use (including the date and time of your access or use), and the subject of the ads you click or scroll over.
  • Location information (which may include general information about the location of your device based on your IP address).
  • In some cases click or touch stream data, movement, scroll, and third-party sites or services you were using before and after interacting with our Services.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). For more information on how to opt-out of advertiser tracking mechanisms, please visit www.networkadvertising.org/managing/opt_out.asp.

We use automatically-collected information to improve our Services and to deliver a better and more personalized service, including, but not limited to, by enabling us to:

  • Estimate our audience size and usage patterns
  • Store information about your preferences, allowing us to customize and improve our Website
  • Recognize you when you return to our Website

The technologies we use for this automatic data collection may include cookies, web beacons, pixel tracking, and GIF. Each of these is discussed below. For details on the specific cookies we are currently using, please review our Cookie Declaration.

  • Cookies (or browser cookies)
    • A cookie is a small file placed on the hard drive of your computer or mobile device. It may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Cookies are managed by the web browser on your computer (Internet Explorer, Firefox, Safari or Google Chrome).
    • Different types of cookies which have different purposes are used on our Website.

      Essential Cookies

      • These cookies are essential to allow you to browse our Website and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.

      Performance Cookies

      • These cookies collect information on the use of our Website, such as which pages are consulted most often. This information enables us to optimize our Website and simplify browsing. Performance cookies also enable our affiliates and partners to find out whether you have accessed one of our Websites from their site and whether your visit has led to the use or purchase of a product or service from our Website, including the references for the product or service purchased. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.

      Functionality Cookies

      • These cookies enable our Website to remember the choices you have made when browsing. For example, we can store your geographical location in a cookie so that the Website corresponding to your area is shown. We can also remember your preferences, such as the text size, font and other customizable aspects of the Website. Functionality cookies may also be able to keep track of the products or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on sites which do not belong to us.

    • You may refuse to accept browser cookies by activating the appropriate setting in your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue necessary cookies when you direct your browser to our Website.

      We also use cookies to implement tracking technology on our Website. This allows us to display content that is tailored to you on our Website and which service categories you request. This tracking uses De-Identified Personal Information data (i.e., data that cannot be identified as being specifically associated with you) and does not use your Personal Information. We will not combine this data with your other Personal Information without your express permission.You may withdraw or change your cookie settings at any time by visiting https://nationbuilder.com/cookie_declaration.

  • Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity)
  • Pixel Tracking. In addition to using Cookies, the Website may employ “pixel tracking,” a common process which may be used in connection with advertisements on other sites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user's activity. We may access these pixel tags to identify activity and interests that may allow us to better match our services, and other offers with your interests and needs. For example, if you visit our Website from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Website. If you visit our Website, and we link you to another website, we may also be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing and research.
  • GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.

Third-party Use of Cookies and Other Tracking Technologies

We use third parties to assist us in serving advertisements on other websites, tracking site usage statistics, and providing certain content. These third parties may use cookies alone or other tracking technologies to collect information about your use of the Website and the Services.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how to opt out of these third parties' use of your information, please see “Personalized Content, Advertising, and Your Choices” below.

How To Turn Off Cookies

Most browsers give you the option to stop accepting cookies in the browser settings, or to turn them off for a particular website. However, we use cookies for some basic functionality, like collecting your email for RSVPs on event pages. If you choose to update your settings in that way, some of the ways that our Website functions will be prevented from working as intended.

If you choose to turn cookies off, all modern browsers allow you to do so, usually in their settings page.

Cookie settings in Internet Explorer

Cookie settings in Firefox

Cookie settings in Chrome

Cookie settings in Safari web and iOS

How We Use Your Information

We may use information that we collect about you or that you provide to us, including:

  • To present our Services and their contents to you.
  • To provide you with information, products or services that you request from us.
  • For analyzing how the Services are used, diagnosing service or technical problems, and maintaining security.
  • To personalize advertising and content.
  • To enable third parties or agents to help us maintain the Services, analyze how users use the Services, or provide other administrative services to us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account, including expiration and renewal notices.
  • To market our products and services to you, as well as those of our partners, including, but not limited to, contacting you about new product lines, product updates, details of current and future projects, and quality and technical issues.
  • To operate, maintain, and provide to you the features and functionality of the Services.
  • To process a payment for a product or service that you purchased.
  • To administer surveys, contests, special promotions, and our newsletter.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Services, our policies, terms or any products or services we offer or provide though it. To allow you to participate in interactive features on our Services.
  • In any other way we may describe when you provide the information at the point of collection.
  • To protect or defend our legal rights and property.

To comply with applicable laws and regulations. We may also combine information that we collect from you with information we obtain about you from third parties.

Social Media

In order to register as a user with us, you may have the option to sign in using your Facebook or other social media site ("SMS") login. If you do so, you authorize us to access certain SMS account information, such as your public SMS profile (consistent with your privacy settings in SMS), your email address. The SMS may transfer information about you to their platform without action by you. This information may include your platform user identification number, which website you are on, and more. SMS are controlled by the respective platform's privacy policy, and not by our Privacy Policy. You can find the privacy policy for a platform on their website.

How We Disclose Your Information

We may disclose your information for the purposes discussed in this section.

Service Providers. We may disclose your information to our service providers (e.g., providers of cloud storage, marketing, analytics, etc.) for the purpose of improving the Service or providing the Service to you. If we do this, our service providers' use of your information will be bound by obligations of confidentiality. We may store information in locations outside our direct control (for instance, on servers or databases located or co-located with hosting providers).

Information you post publicly. Any information or content that you voluntarily disclose for posting to the Services becomes available to the public, as controlled by any applicable privacy or website customization settings. To change your privacy settings on the Services, you may visit your NationBuilder account settings page. If you remove information that you posted to the Services, copies may remain viewable in cached and archived pages of the Services, or if other users have copied or saved that information.

Legal purposes. We may also disclose your information when required to do so by law, court order, legal process, or subpoena, including to respond to any government or regulatory request, or if we believe in good faith that such action is necessary to (a) conform to the law, comply with legal process served on us or our affiliates or partners, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Master Terms (including for billing and collection purposes), take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, or to protect the security or integrity of our site; and (c) to exercise or protect the rights, property, or personal safety of NationBuilder, our users or others.

Affiliates. We may disclose your information to our affiliates and subsidiaries (if any) under common ownership and/or control.

Advertising Partners. Except as provided herein, we may disclose your information to third parties that assist in tailoring and serving advertisements that are relevant to you. We may also allow third-party advertising technologies (e.g., ad networks and ad servers) to use cookies and similar technologies on the Services to deliver relevant and targeted content and advertising to you on the Services and other websites you visit and applications you use, as explained further in “Personalized Content, Advertising, and Your Choices” below.

Consent. If you consent, we may disclose your information publicly or to third parties, such as if you agree to provide a product or service review and have that content attributed to you.

Business Transfers. We may disclose or transfer your information to a potential buyer or other successor for the purpose of considering a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which information held by us about our users is among the assets transferred.

Personalized Content, Advertising, and Your Choices

Online Analytics

We may use third-party web analytics tools on our Services, such as Google Analytics, Segment, and others. These service providers use the sort of technology previously described in the “Information We Collect About You and How We Collect It” section to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

Tailored Online Advertising

We may personalize the content and advertising that you see when using the Services through the use of third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as other websites you visit and other applications you use. These third-party advertising technologies may include Google, Twitter/X, LinkedIn, Facebook and others. The ads may be based on various factors such as the content of the page you are visiting, your searches, demographic data, and other information we collect from you. These ads may be based on your current activity or your activity over time and may be tailored to your interests.

Also, third parties whose products or services are accessible or advertised via the Services may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (i) inform, optimize, and serve ads based on past visits to our websites and other sites and (ii) report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our websites and use of our Services. We also may disclose a hashed version of your email address with third-party advertising partners for purposes of delivering tailored advertising. We neither have access to, nor does this Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt-out of ad targeting as described below. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Advertising Initiative's Consumer Opt-Out link or the Digital Advertising Alliance's Consumer Opt-Out link to opt out of receiving tailored advertising from companies that participate in those programs. You may also withdraw or change your cookie settings at any time by visiting https://nationbuilder.com/cookie_declaration.

Please note that you may still receive advertisements even if you opt out of tailored advertising. In that case, the ads will just not be tailored. Also, we do not control the two opt-out links listed above and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Your Data Rights and Choices

Communications

In accordance with applicable law, we may send you marketing and promotional emails. If you would like to opt out of email marketing, notify us at [email protected] or follow the unsubscribe instructions in the email. Please note that even though you may opt out of receiving marketing-related communications from us, we may still send you important administrative and transactional messages (e.g., notifications regarding updates to our legal terms).

Rights Regarding Your Information

Depending on your jurisdiction, you may have the right, in accordance with applicable data protection laws, to make requests related to your “personal information” or “personal data” (as such terms are defined under applicable law, and collectively referred to herein as “personal information”). Specifically, you may have the right to ask us to:

  • Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information.
  • Provide you access to and/or a copy of certain personal information we hold about you. Note that you may be able to access certain of this information by logging into your account.
  • Correct or update personal information we hold about you.
  • Delete certain personal information we have about you.
  • Provide you with information about the financial incentives that we offer to you, if any.
  • Restrict or object to certain uses of your information.
  • Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.

Please note that certain information may be exempt from such requests under applicable law. For example, we need certain information in order to provide the Services and our services to you.

You may also have the right to opt out of “sales” of your information and “sharing/processing of your information for targeted advertising” as described below. If you are a California resident, please see the “Notice to California Residents” section below for more information about our privacy practices and your rights.

As provided in applicable law, you also have the right to not be discriminated against for exercising your rights. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify your identity, we may be unable to respond to your requests.

To exercise any of these rights, you can email us at [email protected] with your name and type of request you are making.

You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent's request as permitted by applicable law.

Depending on applicable law, you may have the right to appeal our decision to deny your request. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority.

Notice of Right to Opt Out of Sales of Personal Information and Processing/Sharing of Personal Information for Targeted Advertising Purposes

Depending on your jurisdiction, you may also have the right to opt out of “sales” of your information and “sharing/processing of your information for targeted advertising.”

As explained in the “How We Disclose Your Information” section above, we sometimes disclose information to unaffiliated third parties we collaborate with or that provide offers that we think may be of value to you. We also provide information to third-party advertising providers for targeted advertising purposes or use advertising analytics partners to assist us in analyzing use of our services and our user/customer base. Under applicable law, the disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information or the processing/sharing of personal information for targeted advertising purposes.

If you would like to opt out of the disclosure of your personal information for purposes that could be considered “sales” for those third parties' own commercial purposes, or “sharing” or processing for purposes of targeted advertising, please visit https://nationbuilder.com/cookie_declaration. Note that you will need to opt out on each device you have used to access the Services.

Please note that we do not knowingly sell the personal information of minors under 16 years of age.

Notice to California Residents

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and disclose your “personal information” as defined in the California Consumer Privacy Act (“CCPA”).

We describe the categories of information we collect, our business purposes for collecting such information, the sources and uses of such information and the entities to which we disclose such information in the “Information We Collect About You and How We Collect It,” “How We Use Your Information,” and “How We Disclose Your Information” sections of this Privacy Policy. We provide additional information required by the CCPA below.

Categories of Personal Information We Collect, Use, and Disclose

Throughout this Policy, we discuss in detail the types of Information we collect from and about users and discuss how we use and disclose such information. The following are the “categories” of personal information under the CCPA that we collect from California consumers and that we may, as discussed throughout this Policy, use and disclose for our business purposes:

Identifiers (such as name, address, email address); commercial information (such as transaction data); financial data (such as credit card information processed by our payment processor); device identifiers (such as IP address and unique device identifiers); internet or other network or device activity (such as browsing history); general geolocation data derived from IP addresses; any user-generated content or feedback that you provide; and registration information (e.g., username and password) (which is considered “sensitive” personal information under California law).

How We Use These Categories of Personal Information

We and our service providers may use the categories of personal information we collect from and about you for the following business and commercial purposes (as those terms are defined in applicable law):

  • Our or our service providers' operational purposes;
  • Auditing consumer interactions on our site (e.g., measuring ad impressions) and with other third parties, which may include data compilers, business partners and promoters of our products (e.g., retailers, distributors, contractors, representatives or online marketplaces);
  • Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
  • Bug detection and error reporting;
  • Customizing content that we or our service providers display on the Services (e.g., contextual ads);
  • Providing the Services and our services (e.g., account servicing and maintenance, customer service, advertising and marketing, analytics, and communication about the Services and our services);
  • Improving our existing services and developing new services (e.g., by conducting research to develop new products or features);
  • Other uses that advance our commercial or economic interests, such as third-party advertising and communicating with you about relevant offers from third party partners;
  • Other uses about which we notify you.

Examples of these types of uses are discussed in our main privacy policy in the “How We Use Your Information” section. We may also disclose this information to third parties for legal, compliance or security purposes, or in connection with a business transfer, as described further in “How We Disclose Your Information” above.

Sale/Sharing of Personal Information

The CCPA sets forth certain obligations for businesses that “sell” personal information or “share” personal information for cross-context behavioral advertising purposes. Under the CCPA, “sale” and “sharing” are defined such that they may include allowing third parties to receive certain information for advertising purposes. We “sell” or “share” the following categories of information to third-party advertising partners and vendors that support our advertising efforts (such as advertising analytics services):

Identifiers (such as name and email address); commercial information (such as customer status); general geolocation data.

If you would like to opt out of our use of your information for such purposes that are considered a “sale” or “sharing” for cross-context behavioral advertising purposes under California law, please visit https://nationbuilder.com/cookie_declaration. If you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law. Please note that we do not knowingly sell the personal information of minors under 16 years of age.

Additional Privacy Rights

In addition to the rights set forth in the section above on “Sale/Sharing of Personal Information,” California residents may make certain requests about their personal information under the CCPA as set forth in the section above on “Rights Regarding Your Information.”

The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note, in the limited circumstances that we process sensitive personal information (such as usernames in combination with passwords) as defined in the CCPA, we do not use or disclose it other than for disclosed and permitted business purposes for which there is not a right to limit under the CCPA. We ask that users not include sensitive information in correspondence with or any submissions to us.

If you are a California resident and would like to exercise any of your legal rights under the CCPA, you can email us at [email protected] with your name and type of request you are making.

Shine the Light

California Law permits customers who are California residents to request certain information once per year regarding our disclosure of “personal information” (as that term is defined under applicable California law) to third parties for such third parties' direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Except as otherwise described herein with respect to legally required browser based opt outs, we do not recognize or respond to browser-initiated DNT signals, as there is no industry-wide framework for DNT signals. To learn more about Do Not Track, click here. Please note that Do Not Track is a different mechanism than the legally-recognized browser-based opt out preference signal mentioned above.

Additional Information for International Users

IMPORTANT NOTICE: This Privacy Policy originates and is hosted on a Website located in the United States, which has different data protection laws from those of other nations. Due to differing laws and legal practice, be aware that law enforcement agencies in the United States may have access to your information.

If you are a resident of a country other than the United States, we take appropriate steps to protect, process, and transfer your information only in accordance with this Privacy Policy and applicable law, which may include using standard contractual clauses or other transfer mechanisms.

EU-US Data Privacy Framework

3dna Corp. complies with the EU-U.S. Data Privacy Framework ("DPF") as developed by the U.S. Department of Commerce and the European Commission to govern the collection, use, and retention of personal information transferred from the European Union to the United States. 3dna Corp. has certified to the U.S. Department of Commerce that it adheres to the DPF. If there is any conflict between the terms in this Privacy Policy and the DPF, the DPF shall govern. To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov/s/

In compliance with the DPF, 3dna Corp. commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our DPF policy should first contact [email protected].

3dna Corp. has further committed to refer unresolved DPF complaints to the JAMS DPF Dispute Resolution Program, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. The services of the JAMS Program are provided at no cost to you.

As part of the DPF, 3dna Corp. is subject to the investigatory and regulatory enforcement powers of the U.S. Federal Trade Commission. Under certain conditions described at: https://www.dataprivacyframework.gov/s/article/My-Rights-under-the-Data-Privacy-Framework-DPF-Program-dpf you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

3dna Corp. sometimes transfers personal data to a third party for the purposes of subprocessing. When we do make such transfers, we limit them as follows: (i) we transfer data only for limited and specified purposes, consistent with the consent you have provided; (ii) we ensure that the subprocessor is obligated to provide at least the same level of privacy protection required by the DPF; (iii) we take reasonable and appropriate steps to ensure that the subprocessor effectively processes the personal information transferred in a manner consistent with our obligations under the DPF; (iv) we require the subprocessor to notify us if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the DPF; (v) if we receive such notice, we take reasonable and appropriate steps to stop and remediate any unauthorized processing; and (vi) we agree to provide a summary or a representative copy of the relevant privacy provisions of our contracts with subprocessors to the Department of Commerce upon its request.

In the context of an onward transfer to a third party subprocessor, 3dna Corp. remains responsible for the processing of personal information it receives under the DPF if the subprocessor processes such personal information in a manner inconsistent with the Principles, unless we can prove that we are not responsible for the event giving rise to the damage.

How Long Do We Keep Your Information?

We will keep your information as long as it is necessary for the purpose for which we obtained it, unless you ask us to delete it at an earlier time. Our retention periods are based on business needs and legal requirements, and your information that is no longer needed is either irreversibly anonymized or destroyed securely.

Security

We have implemented measures designed to secure your information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers (or those of our service providers) behind firewalls. We may store, retrieve, access, and transmit your information in the U.S. or in other countries. Any payment transactions will be performed using our third party payment processors, who will use appropriate security procedures.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Websites or Services, you are responsible for keeping the password confidential. You should not share your password with anyone. You must prevent unauthorized access to your account and information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. The information you share in public areas may be viewed by other users.

Unfortunately, the transmission of information via the internet is not completely secure. Although we try to protect your information as discussed in this section, we cannot guarantee the security of your information transmitted to us or which we obtain. Any transmission of information is at your own risk. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or used with our Services.

Changes to Our Privacy Policy

We're constantly working to improve our Services, and the laws of various jurisdictions are continually changing, so we may need to change this Privacy Policy to reflect changes in how we operate or to comply with law. We will alert you to changes by changing the posting date of the Privacy Policy; by placing a notice on our Websites; or as part of the Services, by sending you an email, or using some other means, including those required by applicable law. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

Data Protection Officer, [email protected]

PO Box 811428
Los Angeles, CA 90081