PRIVACY NOTICE

Last updated August 26, 2026

We review and update this Privacy Notice at least once every twelve (12) months, and more frequently as needed to reflect changes in our practices or applicable law.

This Privacy Notice for The ASCII Group (“we,” “us,” or “our”), describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

• Visit our website at https://www.ascii.com or any website of ours that links to this Privacy Notice
• Download and use our mobile application, or any other application of ours that links to this Privacy Notice
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@ascii.com.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not intentionally collect or process sensitive personal information. Learn more in the section “WHAT INFORMATION DO WE COLLECT?”

Do we collect any information from third parties? We may collect information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
4. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
10. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
13. DO WE COLLECT INFORMATION FROM MINORS?
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
16. CONTROLS FOR DO-NOT-TRACK FEATURES

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• mailing addresses
• job titles
• usernames
• passwords
• contact preferences
• contact or authentication data
• billing addresses
• debit/credit card numbers
• account information

Payment Information. When you make a payment, your payment card details are collected and processed by our third-party payment processor, Stripe, LLC. We receive and retain your billing address and transaction records, but we do not store your full payment card number.

Sensitive Information. We do not intentionally collect or process sensitive personal information (such as government identifiers, racial or ethnic origin, health data, precise geolocation, or biometric data). If you voluntarily provide sensitive information to us (for example, through free-text fields or customer-support communications), we process it only as needed to respond to your request and delete it when no longer needed.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. The location information we collect automatically is approximate only (for example, derived from your IP address at the city or country level); we do not collect precise geolocation (such as GPS coordinates) from your device. We use approximate location information for security, fraud prevention, content localization, and analytics.

Like many businesses, we also collect information through cookies and similar technologies.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We will not use your personal information for materially incompatible purposes without providing any notice required by law and obtaining your consent where required.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To create and manage your account and authenticate users. We process your information to register you, maintain your account, and verify your identity when you log in.
• To provide and deliver our Services. We process your information to make our Services available, fulfill your requests, and provide the products and features you use.
• To administer billing and process payments. We process your information to invoice you, process payments through our payment processor(s), and maintain payment and tax records.
• To communicate with you. We process your information to respond to your inquiries, provide customer support, and send administrative and service-related messages.
• For analytics and to improve our Services. We process your information to understand how our Services are used and to maintain, improve, and develop our Services.
• For marketing and promotional communications. Where permitted by law and, where required, with your consent, we process your information to send you marketing communications. You can opt out at any time.
• For security and fraud prevention. We process your information to keep our Services secure, prevent and detect fraud and abuse, and protect our rights and the rights of others.
• To comply with legal obligations. We process your information where necessary to comply with applicable law, respond to lawful requests, and establish, exercise, or defend legal claims.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a Contract. We may process your personal information when necessary to perform our contract with you or to take steps at your request before entering into a contract, such as to create and manage your account, provide and deliver our Services, and administer billing and payments.
• Legitimate Interests. We may process your personal information where necessary for our legitimate interests (or those of a third party), provided those interests are not overridden by your interests or fundamental rights. Our legitimate interests include operating, securing, and improving our Services, preventing fraud and abuse, conducting internal analytics, and (where consent is not required) marketing to existing customers.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

The table below shows how our main processing purposes map to these legal bases under the GDPR and UK GDPR:

If you are located in Canada, this section applies to you.

We process your personal information in accordance with the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and substantially similar provincial privacy laws, including Alberta's Personal Information Protection Act, British Columbia's Personal Information Protection Act, and Quebec's Act respecting the protection of personal information in the private sector (as amended by Law 25).

We may process your information where you have given us express consent (which we generally obtain for sensitive information or for purposes that would not be obvious to you) or where your consent can reasonably be implied (for example, for processing necessary to provide a Service you have requested). You can withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. To withdraw consent or opt out of marketing, contact us using the details in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” or use the unsubscribe link in our marketing emails.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations

Survey Data. We conduct surveys and may use the results for research, reporting, and statistical purposes. We publish and share survey results only in aggregate form. Before publication or external sharing, we remove individual identifiers and review the results internally to help ensure that they cannot reasonably be traced back to an individual respondent. Any aggregate survey data shared externally is provided only in summarized form and does not include individual-level data or information intended to enable re-identification.

Live Chat Room Polls. We may conduct short surveys and polls through our chat room platform. If you participate, your name, company affiliation, and individual response may be visible to other members in real time. We will provide a clear and prominent notice at the point of participation explaining this visibility and that participation constitutes your consent to it.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work.

The categories of third parties with whom we may share personal information are:

• Cloud hosting and infrastructure providers (to host and operate our Services)
• Payment processors (to process payments and prevent payment fraud)
• Email and communications providers (to deliver service and marketing communications)
• Analytics providers (to understand and improve how our Services are used)
• Advertising and marketing partners (only as described in the cookies and tracking-technologies section below)
• Security, fraud-prevention, and IT service providers
• Customer support and professional services providers (including consultants, auditors, and legal advisors)

Examples of our third-party vendors include Stripe, LLC, Google, and Microsoft. You may request a current list of our third-party vendors by emailing privacy@ascii.com.

We require these third parties to protect your personal information and to use it only for the purposes for which we engaged them, pursuant to a written contract.

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. Any such disclosure will be subject to appropriate confidentiality, security, and legal safeguards, and the recipient will be required to honor this Privacy Notice or provide equivalent protection.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Business Partners. Where we share your information with business partners to offer you products, services, or promotions, we do so only as permitted by law and, where required, with your consent. If this sharing constitutes “targeted advertising” or a “sale”/“share” under applicable US state law, you may opt out as described in the cookies and tracking-technologies section and the US state privacy-rights section below. Examples of our business partners include Stripe, LLC, Google, and Microsoft. You may request a current list of our business partners by emailing privacy@ascii.com.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a “sale”/”sharing” (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section “DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?”

The cookies and similar technologies we use fall into the following categories:

• Strictly necessary cookies (first-party): required to operate the Services, maintain security, and remember your preferences. These cannot be switched off in our systems.
• Analytics/performance cookies (first- and third-party): help us understand how the Services are used so we can improve them. We use Microsoft Clarity and Google Analytics for these purposes.

Google Analytics and Microsoft Clarity use cookies to help us understand how visitors use our Services. These cookies include:

• Persistent identifiers that recognize returning visitors: Google Analytics’ _ga cookie, a first-party cookie with a rolling duration of up to two (2) years; and Microsoft Clarity’s _clck first-party cookie and CLID and MUID third-party cookies, each with a duration of up to one (1) year.
• Session cookies that help connect activity during a visit: Google Analytics’ _gid first-party cookie and Microsoft Clarity’s _clsk first-party cookie, each with a duration of up to twenty-four (24) hours; and Microsoft Clarity’s ANONCHK third-party cookie, with a duration of up to ten (10) minutes.
• Operational cookies that manage data traffic and synchronization: Google Analytics’ _gat first-party cookie, with a duration of up to one (1) minute; and Microsoft Clarity’s MR cookie, with a duration of up to seven (7) days.

For more information, email privacy@ascii.com.

We display a cookie banner by default to all visitors, regardless of location, and we do not use geolocation-based suppression that would prevent the banner from appearing for visitors in jurisdictions that require an affirmative choice. For visitors in California and Florida (and other states that require it), we do not set or activate non-essential cookies — including analytics cookies such as Google Analytics — unless and until you give affirmative opt-in consent. For visitors in other states with comprehensive consumer privacy laws, non-essential cookies may be set subject to your right to opt out, which you can exercise at any time. You can manage your choices at any time through the cookie preference tool available on our website and through your browser settings, and, where required by law (including in the EU and UK), we obtain your consent before setting non-essential cookies.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: ASCII does not offer registration or login to our Services using social media accounts.

Our Services do not offer the ability to register or log in using third-party social media account details, such as Facebook, Google, or X logins. If you are asked to provide social media login credentials in connection with our Services, do not provide them and contact us at privacy@ascii.com.

7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers and primary service providers are located in the United States and the European Union. If you are accessing our Services from outside those countries, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we share your personal information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above), which may be located in the United States, Ireland, and other countries. These countries may have data protection laws that differ from those of your country, and your information may be accessible to courts, law enforcement, and other authorities there.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, and we transfer your personal information to a country that has not received an adequacy decision from the European Commission, the UK government, or the Swiss authorities, we will use a valid transfer mechanism recognized under applicable law, including the General Data Protection Regulation (EU) 2016/679, to protect your information. These safeguards include the European Commission's Standard Contractual Clauses (and, for UK transfers, the UK International Data Transfer Agreement or UK Addendum), or another lawful transfer mechanism such as binding corporate rules. You may request a copy of the relevant safeguards by contacting us using the details in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”

If you are located in Canada, your personal information may be transferred to, stored, and processed by service providers located outside Canada, including in the United States and Ireland, where it may be accessible to government, law enforcement, and other authorities under the laws of those jurisdictions. We use contractual and other measures to require comparable protection for your personal information. For questions about our use of service providers outside Canada, contact our privacy officer using the details in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). Our general retention periods are set out below:

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at privacy@ascii.com.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

We will consider and act upon any request in accordance with applicable data protection laws. We will respond within the timeframe required by the law that applies to you (for example, within one (1) month under the EU/UK GDPR, subject to extension, and within 45 days under most US state laws, subject to extension). We may verify your identity before acting on your request, using measures proportionate to the sensitivity of the request. If we decline your request, we will explain why and, where applicable law provides an appeal or complaint mechanism, tell you how to use it.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update or delete your account information; or
• Contact us using the contact details in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”
• Reach out to your account manager.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at privacy@ascii.com.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California and certain other US state laws require us to let you know how we respond to web browser DNT signals. Because there is not yet a uniform standard for conventional DNT signals, we do not respond to them at this time. However, where required by applicable US state law, we honor recognized universal opt-out mechanisms — such as the Global Privacy Control (GPC) — as a valid request to opt out of the sale/sharing of personal information and targeted advertising for the browser or device from which the signal is sent.

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The “Examples” column provides illustrative examples of each category; the “Collected” column indicates whether we actually collect that category. For a comprehensive inventory of the personal information we process, please refer to the section “WHAT INFORMATION DO WE COLLECT?”

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

Sources of Personal Information

Learn more about the sources of personal information we collect in “WHAT INFORMATION DO WE COLLECT?”

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, “HOW DO WE PROCESS YOUR INFORMATION?”

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

We do not sell your personal information for money. To the extent our use of third-party advertising technologies constitutes “sharing” or “targeted advertising” under applicable US state law, you may opt out as described in the cookies and tracking-technologies section above.

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Minnesota)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at privacy@ascii.com, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@ascii.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine The Light” Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”

13. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

• offer you the products or services that you want
• respond to or help with your requests

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?”

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner. We aim to acknowledge complaints within seven (7) business days and to respond substantively within thirty (30) days. Your personal information may be disclosed to overseas recipients, including service providers located in the United States.

European Economic Area (EEA), United Kingdom, and Switzerland

If you are located in the EEA, UK, or Switzerland, you have the rights described in the section “WHAT ARE YOUR PRIVACY RIGHTS?” above, including the rights of access, rectification, erasure, restriction, portability, and objection, and the right not to be subject to solely automated decision-making that produces legal or similarly significant effects. Our legal bases for processing are described in the section “WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?” You may lodge a complaint with your local supervisory authority, the UK Information Commissioner's Office, the Swiss Federal Data Protection and Information Commissioner, or by emailing us at privacy@ascii.com.

Canada

If you are located in Canada, you have the right to access and correct your personal information and to withdraw consent, subject to legal and contractual restrictions. You may direct questions or complaints to our privacy officer using the details in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”, and you may also complain to the Office of the Privacy Commissioner of Canada or the applicable provincial commissioner (in Alberta, British Columbia, or Quebec). Your personal information may be processed by service providers outside Canada as described in the section “IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?”

14. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time, and we review it at least once every twelve (12) months. The updated version will be indicated by an updated “Last updated” date at the top of this Privacy Notice. If we make material changes, we will notify you only by prominently posting a notice of the changes on our website; we will not provide direct notice by email, in-app messaging, or other direct notification methods. We encourage you to review this Privacy Notice frequently to stay informed of how we protect your information.

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, or to exercise your privacy rights, you may email our privacy team at privacy@ascii.com or submit a data subject access request. You may also contact us by post at:

The ASCII Group
4445 Willard Ave
Suite 200
Chevy Chase, MD 20815
United States

Individuals outside of the United States should also email our privacy team at privacy@ascii.com for any questions, comments, or concerns.

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.

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