TheNumber, LLC – Privacy and Security Policy

TheNumber, LLC ("TheNumber" or "we") is committed to complying with all data protection legislation. Though TheNumber does not typically collect personal information directly from our customers (“you” or “your”), this privacy notice contains information on personal data pertaining to you that we may collect directly from you through this website (“Personal Information”), what we do with that information, and what rights you have.

There are a limited number of circumstances where we may share your information with third parties (for example, pursuant to a court order, if we are part of a merger, or with our business partners and service providers who support our business or collaborate with us). Please read the full Privacy and Security Statement below and contact us if you have questions.

INTRODUCTION

Your privacy is respected and TheNumber is committed to protecting it through our compliance with this Privacy and Security Statement. This Privacy and Security Statement (together with our Terms of Use) describes the types of information we may collect from you or that you may provide. For example, when you visit any of our websites or contact us, and how we use, protect, and disclose that information.

This Privacy and Security Statement does not apply to information collected on or from any third-party site or application (including advertising) that may link to or be accessible from our websites, or information collected from any other source. We are not responsible for the privacy policies or data collection, use and disclosure practices of those sites or other third-party sources.

Please read this Privacy and Security Statement carefully to understand our policies and practices regarding your Personal Information and how we will treat it. By accessing or using any of our websites or services (including email communications), you agree to this Privacy and Security Statement. This Statement may change from time to time, and these changes may affect how we use the information described below, so please check the Privacy and Security Statement periodically for updates.

NOTICE ABOUT HOW WE USE AND PROTECT PERSONAL INFORMATION

Personal Information collected for the purposes of business operations, includes but is not limited to, information you provide to us. Personal Information collected from forms on our website includes information provided at the time of registering to use portions of our websites or our products and services, posting material, or requesting further services and you may be asked for information when you report problems regarding the website or the services provided. When you navigate our website or contact us, we may request or you may choose to provide us with certain information. This may include information by which you may be personally identified, such as name, employer, e-mail address or telephone number, and records and copies of your correspondence with us. Though the request for this information is unlikely, it is possible.

During interaction with our website, information may automatically be collected about your equipment, browsing actions and patterns using common internet technologies, such as cookies and Web beacons. This may include details of your visits to our website, including information about your connectivity, such as your IP address and browser information, location data, logs and other communication data, and the resources that you access and use on the websites.

As a current or previous customer or user of our products or services, you may periodically receive emails from us containing details about features of products currently in use and/or about new products or services that we may offer. Such processing may include the placing of beacons or pixels, alerting us if you have opened our email and how long the email was open. We do this in order to see which emails are effective and which are not so that we can improve our content and services. It helps us make sure that you are getting emails from us that you find useful and relevant. In doing so, we will never track your location or device information.

General business-related information: We use information that you provide to us, including Personal Information:

  • To present our websites, products and services to you and continuously improve upon them.
  • To provide you with information, products or services that you request from us.
  • To notify you about changes to our websites, products or services (including new offerings) and promotions or events.
  • To maintain the integrity and security of our websites, products, and services.
  • For our ordinary business operations, including human resources, recruiting, equity investments, and business research and outreach.

Legal basis for the processing: We are not allowed to process Personal Information if we do not have a valid legal ground. Therefore, we will only process your Personal Information if:

  • The processing is necessary to perform our contractual obligations towards you or to take pre-contractual steps at your request, such as when we authenticate your log-in to our services or ensure that you only have access to the services and data we have agreed to provide you with;
  • The processing is necessary to comply with our legal or regulatory obligations, such as tax reporting or regulatory requirements;
  • The processing is necessary for the legitimate interests of TheNumber, and does not unduly affect your interests or fundamental rights and freedoms;
  • The processing is necessary for the performance of a task carried out in the public interest; or in some cases, and as may be requested from you from time to time, we have obtained prior consent.

To the extent that we process any special categories of data relating to you, we will do so because:

  • The data has been manifestly made public;
  • The processing is necessary for the establishment, exercise or defense of a legal claim;
  • The processing is necessary for reasons of substantial public interest; or
  • You have given your explicit consent to us to process that information (where legally permissible).

DISCLOSURE OF YOUR INFORMATION

Protecting your Personal Information is important to us and we neither rent nor sell your Personal Information to anyone. We may disclose or transfer Personal Information that we collect or you provide as described in this Privacy and Security Statement, including:

  • To a buyer or other successor in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of TheNumber's assets, in which personal information held by TheNumber about our websites' users is among the assets transferred.
  • To our subsidiaries, affiliates, agents, contractors, service providers and other third parties we use to support our business or collaborate with and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes of providing services for or with us.
  • To comply with any court order, law or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms of Use and other agreements that govern the sale or use of our products and services.
  • To protect the rights, property or security of TheNumber, our employees, our users or others.

HOW WE USE AND DISCLOSE YOUR INFORMATION

How to exercise control over your Personal Information:

Tracking and Advertising: You may be able to change settings to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the site may then be inaccessible or not function properly. In relation to email, you can disable most email tracking technology by preventing the loading of embedded pictures in the email. You can do this using your email software settings.

Promotional Offers from the Company: If you do not wish to receive promotional e-mail messages, you can opt-out by emailing privacy@TheNumber.com asking to be removed from future e-mail distributions.

YOUR RIGHTS

If you believe that any Personal Information we hold about you is incorrect or incomplete, you may request the correction of your personal data.

You may also have the right to:

  • Object to the processing of your Personal Information;
  • Request the erasure of your Personal Information;
  • Request restriction on the processing of your Personal Information;
  • Withdraw your consent to process Personal Information (without this withdrawal affecting the lawfulness of any processing that took place prior to the withdrawal).

Such requests will be honored, withdrawal or objection as required under applicable data protection rules but these rights are not absolute. In response to such a request, you may be asked to verify your identity and/or provide information to understand the request.

EXERCISING YOUR RIGHTS

To exercise the above rights, you may send an email to privacy@TheNumber.com.

If you are not satisfied with our response, you have the right to make a complaint in the jurisdiction where you live or work, or jurisdiction where you think an issue in relation to your data has arisen.

LENGTH OF DATA STORAGE

We will only retain Personal Information for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.

CHANGES TO OUR PRIVACY AND SECURITY STATEMENT

We may amend or update this Privacy and Security Statement from time to time. Please revisit this page occasionally to read the current version of this Statement in effect. If you have any concerns or questions about this Statement or if you would like to lodge a complaint, please contact privacy@TheNumber.com.

SECURITY

TheNumber has implemented measures to protect Personal Information against unauthorized, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing.

You are responsible for the safety and security of your information. Should you have been given a password, or you have chosen one yourself, you are responsible for keeping this password confidential. Please do not share your password with anyone.

CHILDREN UNDER THE AGE OF 13

Our website is not intended for children under thirteen (13) years of age. If you become aware that your child has provided us with Personal Information without your consent, please contact us at privacy@TheNumber.com and we will begin the process of deletion. We do not knowingly collect Personal Information from children under thirteen (13.)

CONTACT INFORMATION

Should you have any questions regarding Privacy and Security Statement, please contact us by emailing us at privacy@TheNumber.com or by writing to us at:

TheNumber, LLC Attention: Legal Department 175 Greenwich St., 59 th Floor New York, New York 10007

ADDITIONAL INFORMATION FOR CALIFORNIA

If you are a resident of California, the California Consumer Privacy Act (“CCPA”) provides you with specific rights regarding your Personal Information. These include:

  • You can request information about our collection and use of your Personal Information over the past twelve (12) months concerning: (i) the categories of Personal Information we collected about you, (ii) the business or commercial purpose for collecting your Personal Information, (iii) the categories of sources from which your Personal Information is collected, and (iv) the categories of third parties with whom we share your Personal Information. You can request a list disclosing the categories of your Personal Information we have shared in connection with a business purpose.
  • You can request to receive a copy of your Personal Information in a commonly used and machine-readable format.
  • You can request that we delete your Personal Information, subject to certain exceptions.

To exercise the rights described above, it may be necessary for us to verify your identity or authority to make the request and confirm the Personal Information relates to you. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. We will not discriminate against you for exercising any of your privacy rights under CCPA or applicable law.

During the past twelve (12) months, we collected the categories of Personal Information described above from California residents. We also disclosed such Personal Information to third parties for the purposes specified above during the past twelve (12) months.

Unless expressly stated in a privacy policy or statement applicable to a specific TheNumber affiliate’s website, product or service, TheNumber does not sell your Personal Information.