Goodway Group's Privacy Policy

GENERAL DISCLOSURES

We serve as a partner to agencies and brand marketers providing managed services for programmatic, social, search and other types of digital media. We work with many demand-side platforms (DSPs) and data partners to create custom media plans and executions for our clients. At the same time, we are committed to protecting the privacy of online consumers. We have worked with our third-party ad-serving technology providers to ensure that we adhere to the privacy guidelines created by the Digital Advertising Alliance (DAA).

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Each of the sites are hosted in the United States and their intended use is Business to Business.

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If you are visiting the sites from outside of the United States, please note that by providing your information, it is being transferred to, stored or processed in the United States and other countries, where our data center and servers are located and operated. This section sets forth the general privacy policy for the United States and other jurisdictions not otherwise specifically covered by the below jurisdiction-specific policies. Depending on your state or country of residence, applicable privacy laws may provide you the ability to request access to, correction of or deletion of your information, as further outlined below. If you are outside the United States, please see the provisions in our INTERNATIONAL PRIVACY POLICY. If you are outside the United States and do not wish to allow the transfer of your personal information to the United States, you should not use these sites and you should opt out of the collection of cookies. View our COOKIES POLICY.

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Business Information

We provide our Services to businesses, and not to individual consumers. Therefore, most of the data that we collect is regarding businesses. However, in the course of providing our Services, we may collect personal information of individuals, as will be described in this Policy. This may include personal information that we collect about you when you visit our sites or your business contact information if we provide our Services to a company that you work with or if you are a sole proprietorship and you engage with our Services.

We take your privacy and the protection of your personal information seriously. We will only store, process and disclose your personal information in accordance with applicable law. We will make it clear when we collect personal information and will explain what we intend to do with it. We do our best to protect your privacy through the appropriate use of information security measures.

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WHAT INFORMATION WE COLLECT

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1. Information You Provide to Us Directly

Goodway Group may collect different information from or about you depending on the manner in which you use our sites or Services. The following examples are provided to help you better understand the information we may collect through your use of the sites or in the course of us providing our Services.

We may collect, use, store and transfer different kinds of personal information about you, which we have grouped together as follows:

• Identity Information includes first name, middle initial, last name, date of birth, gender, username or similar identifier.
• Contact Information includes personal mailing address, email address, telephone number.
• Financial Information includes bank account information and payment card details.
• Transaction Information includes details about the products and services you have purchased from us and the corresponding transactions.
• Technical Information includes, cookie information, location pixel, browsing time, website history, internet protocol (IP) address, your login data, time zone setting and location (geocodes), geolocation data, auth0 logs, pages visited, pages viewed, events and page loads, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Information includes your username and password and your preferences.
• Usage Information includes information about how you use our website, products and services.
• Marketing and Communications Information includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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2. Information Received Through Third-Party Platforms

You may access our sites through third-party platforms, such as Facebook. If you use our sites on or through a third-party platform including via any mobile and/or other Internet connected devices (“Wireless Devices”) or click on third-party links, the collection, use and disclosure of your information and your use of the sites will also be subject to the privacy policies and other terms of such third parties or third-party platforms. You should review such privacy policies, terms and other agreements.

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3. Information We Collect From Third Parties

Goodway Group collects certain information about or relating to you from third parties who directly or indirectly collected the information from you, including identity information such as age, nationality and racial or ethnic origin and social media information such as social media contact, history and account.

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4. Collection of Technical Information and Usage Information

When you access Goodway Group’s sites, we automatically collect certain information. This information may include without limitation: (a) technical information about your computer or Wireless Device such as your IP address, geolocation information, device type, operating system type and version, unique device ID, browser, browser language, domain and other systems information or platform types (collectively “Technical Information”); and (b) usage statistics about your interaction with Goodway Group’s sites, including pages accessed, referring website address(es), time spent on pages, pages visited, search queries, click data, date and time and other information regarding your use of Goodway Group’s sites (collectively “Usage Information”). This Technical Information and Usage Information, which may be linked to your personal information, is collected through the use of server logs and tracking technologies, including: (i) cookies, which are small pieces of code that websites send to your computer or Wireless Device to uniquely identify your browser or mobile device or to store information in your browser setting; and (ii) web beacons, which are small objects that allow us to measure the actions of visitors using the Goodway Group’s sites. For more detailed information regarding how we use cookies and other technology, please review the additional information in our COOKIES POLICY.

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HOW WE USE YOUR INFORMATION

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We may use information about you for a number of purposes including:

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1. Advertising and Marketing

• Creating customized advertisements to display for you on participating websites and to analyze if the advertising resulted in a desired action such as sales; and
• Communicating with you about opportunities, products, services, promotions, discounts, incentives, and/or rewards offered by us and select partners. If we send you marketing emails, each email will contain instructions permitting you to “opt out” of receiving future marketing or other communications.

You can ask us or third parties to stop sending you marketing messages at any time by contacting us. To learn about your choices regarding interest-based advertising and cross-device tracking, please see OPT OUT OF MARKETING AND PROMOTIONAL COMMUNICATIONS AND ADVERTISING.

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2. Providing, Improving and Developing Our Services

• Reviewing and analyzing user browser and wireless device technical information;
• Reviewing user activity across sites (for example, Goodway Group analyzes trends, user traffic and usage information to determine the performance of content, research reports or events);
• Displaying your historical transaction information;
• Providing, maintaining and improving our Services;
• Developing new products and Services;
• Delivering the information and support you request;
• Improving, personalizing and facilitating your use of our Services; and
• Measuring, tracking and analyzing trends and usage in connection with your use or the performance of our Services.

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3. Communicating With You About Our Services

• Responding to questions or concerns; and
• Sending you information we think you may find useful or which you have requested from us about our Services.

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4. Protecting Our Services and Maintaining a Trusted Environment

• Enforcing our Terms of Service or other applicable agreements or policies;
• Verifying your identity;
• Complying with any applicable laws or regulations, or in response to lawful requests for information from the government or through legal process;
• Fulfilling any other purpose disclosed to you in connection with our Services;
• Analyzing trends and user traffic, track purchases and usage information; and
• Contacting you to resolve disputes and provide assistance with our Services.

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5. Other Uses

• For any other purpose disclosed to you in connection with our Services from time to time.

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WHEN AND WITH WHOM DO WE SHARE YOUR INFORMATION

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1. When And How We May Share/Disclose Your Information With Third Parties

‍We will share your information, which may include name, email address, and technical and usage data, with the following third parties and under the circumstances described below or as otherwise described in this Privacy Policy:

• We may share your information with third-party companies that perform services on our behalf including for payment processing, data analysis, data management, file sharing, legal and contract review, recruitment, payroll administration, marketing services, advertising services (including but not limited to retargeted advertising and lead generation), email and hosting services and customer services and support. These service providers may access your personal information and may only use it as directed by us for the purpose of our requested service.

We require all third parties to respect the security of your personal information. We do not allow our third-party service providers to use your personal information for their own purposes, and they are only permitted to process your personal information in accordance with our instructions.

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2. When And How We May Sell Your Information to Third Parties

‍In the past twelve (12) months, Goodway Group has sold personal information to third-parties for commercial purposes. The categories of personal information that were sold for commercial purposes in the last twelve (12) months include: identity, contact, social media, transactional, technical and usage information. Goodway Group does not knowingly sell the personal information of minors under sixteen (16) years of age without affirmative authorization.

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3. Corporate Transactions

‍We may share all or part of your personal information with other business entities in connection with the sale, assignment, merger or other transfer of all or a portion of Goodway Group’s business or assets to such business entity (including due to a sale in connection with a bankruptcy). We will require any such purchaser, assignee or other successor business entity to honor the terms of this Privacy Policy.

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4. Disclosure of Information for Legal Purposes

‍Goodway Group may disclose all or part of your personal information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating any agreement with Goodway Group, or may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of our sites or anyone else that could be harmed by such activities. We may disclose information in response to a subpoena, search warrant, in connection with judicial proceedings, or pursuant to court orders, legal process or other law enforcement measures. Goodway Group may disclose or access personal information when we believe in good faith that the law requires it, to establish our legal rights or to defend against legal claims, and for administrative and other purposes that we deem necessary to maintain, service and improve our Services.

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5. Analytics and Data Enrichment Services

‍We use third-party analytics such as Google Analytics to help understand your usage of our sites and to improve our Services.

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6. Aggregated, Anonymized or De-identified Information

‍We may disclose or use aggregated, anonymized or de-identified information for any purpose. Aggregated, anonymized or de-identified information is information that can no longer reasonably identify a specific individual. Although such information may be derived from your personal information, it can no longer directly or indirectly reveal your identity.

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COOKIES POLICY

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Like many online platforms, Goodway Group and its analytics vendors use server logs and automated data collection tools such as browser cookies, pixel tags, scripts and web beacons. These tools are used for analytics purposes to enable Goodway Group to understand how users interact with the sites and Services. Goodway Group and its analytics vendors may tie the information gathered by these means to the identity of users.

Cookies are small text files placed on a computer or device while browsing the Internet. Cookies are used to collect, store and share bits of information about user activities. Goodway Group uses both session cookies and persistent cookies.
Session cookies are used to identify a particular visit to Goodway Group’s sites and collect information about your interaction with the sites. These cookies expire after a short time or when the user closes their web browser after using the sites. Goodway Group uses these cookies to identify a user during a single browsing session such as when you log into the sites. This helps Goodway Group improve the sites and Services as well as improve the users’ browsing experience.

A persistent cookie will remain on a user’s device for a set period of time specified in the cookie. Goodway Group uses these cookies to identify and recognize a specific user over a longer period of time. They allow Goodway Group to:

• analyze the usage of the sites (e.g., what links users click on) in order to improve our offering;
• test different versions of the sites to see which particular features or content users prefer to optimize the sites;
• provide a more personalized experience to users with more relevant content and course recommendations; and
• allow users to more easily log in to use the sites and Services.

Examples of persistent cookies include: (i) preferences cookies to remember information about a user’s browser and settings preferences such as preferred language – preference cookies make a user’s experience more functional and customized, (ii) authentication and security cookies to enable a user to log in or stay logged in to access the sites and Services, to protect user accounts against fraudulent logins by others and to help detect and protect against abuse or unauthorized usage of user accounts and (iii) functional cookies to make the experience of using the sites and Services better, like remembering the sound volume level selected by the user.

To make certain that ads served by us are targeted correctly, partner websites in the network place our pixel tags on their sites. They are used to match a visitor’s browsing behavior to a segment profile designated for targeting ads to visitors and to count users who have visited those sites and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Goodway Group uses tracking technology to: (i) determine if a certain page was visited or whether an email sent by Goodway Group was opened or clicked on by a user; and (ii) to customize the experience of individual users by recommending specific content.

We also use clear gifs in HTML-based emails sent to our users to track which emails are opened and clicked on by recipients. We may use the information we obtain from the cookie in the administration of the sites, to improve the usability of the sites and for marketing purposes. We may also use that information to recognize your computer when you visit our sites and to personalize our sites for you.

Cookies and information captured through our sites are stored for a certain retention period; however, you can eliminate these cookies any time before the expiration date. Our Table of Cookies can be found here.

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HOW TO RESTRICT COOKIES

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You can adjust the settings in your browser in order to restrict or block cookies that are set by the sites (or any other website on the Internet). Your browser may include information on how to adjust your settings. Alternatively, you may visit www.allaboutcookies.org to obtain comprehensive general information about cookies and how to adjust the cookie settings on various browsers. This site also explains how to delete cookies from your computer.

You can control and delete these cookies through your browser settings through the following:

• Google Chrome
• Mozilla Firefox
• Safari
• Opera
• Microsoft Internet Explorer
• Microsoft Edge
• Safari for iOS (iPhone and iPad)
• Chrome for Android

Or you can also use the following cookie management and disposal tool from Google Analytics by downloading and installing the browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout.

Please be aware that restricting cookies may impact the functionality of the Services. Most browsers allow you to refuse to accept cookies. Additional general information about cookies, including how to be notified about the placement of new cookies and how to disable cookies, can be found at www.allaboutcookies.org.

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THIRD-PARTY ADVERTISING AND ANALYTICS

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We use third-party service providers to provide site metrics and other analytics services. These third parties may use cookies, web beacons and other technologies to collect information such as your IP address, identifiers associated with your device, other applications on your device, the browsers you use to access our sites and Services, webpages viewed, time spent on webpages, links clicked and conversion information (e.g., transactions entered into). This information may be used by Goodway Group and third-party service providers on behalf of Goodway Group to analyze and track usage of our sites and Services, to determine the popularity of certain content and to better understand how you use our sites and Services. The service providers that we engage are bound by confidentiality obligations and other restrictions with respect to their use and collection of your information.

This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons or other tracking technologies, which are covered by such third-parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third-parties to learn about their privacy practices. For more information about targeted advertising specifically, please visit http://www.aboutads.info/choices.

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LINKING SITES

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The sites contain links to other websites. Goodway Group is not responsible for the privacy practices or the content of such websites including any websites that may indicate a special relationship or partnership with us (such as co-branded pages or “powered by” or “in cooperation with” relationships). We do not share information we gather with other websites or any other entities or individuals unless such sharing is disclosed to you in advance through this Privacy Policy. Other linked websites, however, may collect personal information from you that is not subject to our control. To ensure protection of your privacy, always review the privacy policy of the websites you may visit by linking from the sites. Please note that this Privacy Policy applies only to our sites, and not to other companies’ or organizations’ websites to which we link.

For instance, information collected through Google Analytics is shared with Google and its partners who may combine it with other information you provided to them or they collected from your use of their services. This information is stored in Google’s servers according to their privacy practices.

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SOCIAL MEDIA

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We may collect information from other sources such as social media platforms that may share information about how you interact with our social media content. We do not control how your personal information is collected, stored or used by such third-party websites or to whom it is disclosed. You should review the privacy policies and settings on any social media website that you subscribe to so that you understand the information they collect and may be sharing. If you do not want your social media websites to share information about you, you must contact that website and determine whether it gives you the opportunity to opt out of sharing such information. Goodway Group is not responsible for how these third-party websites may use information collected from or about you.

Further, our sites may include social media features such as share buttons. Our integration of these features may allow third-party social media to collect certain information such as your IP address and which page(s) you are visiting when using our sites and Services and to set a cookie to enable that feature to function properly. Your interactions with these features are governed by the privacy policy of the Goodway Group providing it.

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HOW LONG WE RETAIN YOUR INFORMATION

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We generally retain your information as long as reasonably necessary to provide you the Services or to comply with applicable laws, and we will establish a document/information retention policy to govern our retention of such information. We may retain copies of information about you and any transactions or Services you have used for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce other applicable agreements or policies or to take any other actions consistent with applicable law.

In some circumstances we may anonymize or de-identify your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. This allows the specific information collected (name, email, address, phone number, etc.) to become anonymous but allows Goodway Group to keep the non-personal information. For example, Goodway Group will not be able to tell if John Smith registered for an event, but we will be able to tell that a person registered for an event and maintain headcount and transactional history. This will allow Goodway Group to maintain a level of information that helps us develop and improve our sites and Services.

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OPT OUT OF MARKETING AND PROMOTIONAL COMMUNICATIONS AND ADVERTISING

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If you no longer wish to receive advertising based on your interests or other web-browsing behavior, the online advertising industry provides websites from which you may opt out of interest-based advertising from Goodway Group and other companies that participate in industry self-regulatory programs. The U.S.-based opt-out pages are www.aboutads.info/choices and www.networkadvertising.org/choices. The European based page is www.youronlinechoices.com. In Canada, use www.youradchoices.ca/choices.

For mobile apps, you can opt out of Goodway Group using information about your usage of mobile apps that are targeted to your interests by using your device settings, for most devices. We are not able to directly access the Mobile App Opt-Out on devices that offer it. To learn how to use the mobile app opt-out, consult your device instructions. To find information on opting out on mobile devices, please visit http://www.networkadvertising.org/mobile-choice.

You may also opt out of receiving marketing and promotional messages from Goodway Group if those messages are powered by Goodway Group by following the instructions in those messages. If you decide to opt out, you will still receive non-promotional communications relevant to your use of our Services.

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DIGITAL ADVERTISING ALLIANCE COMPLIANCE DISCLOSURE

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We comply with the cross-industry Self-Regulatory Program for Online Behavioral Advertising managed by the Digital Advertising Alliance (DAA): (https://www.aboutads.info/). As part of this service, our online advertisements are sometimes delivered with icons to help you choose and control how your data is supplied and used.

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CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA) COMPLIANCE AND RELATED INFORMATION

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The Children’s Online Privacy and Protection Act (COPPA) regulates online collection of information from persons under the age of 13. It is our policy to refrain from knowingly collecting or maintaining personal information relating to any person under the age of 18. If you are under the age of 18, please do not supply any personal information through the sites. If you are under the age of 18 and have already provided personal information through the sites, please have your parent or guardian contact us immediately using the information provided under CONTACT US so that we can remove such information from our files.

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SECURITY

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We take reasonable measures, including administrative, technical and physical safeguards to protect your information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. We hold information about you both at our own premises and with the assistance of third-party service providers. Further public disclosure here of our security measures could aid those who might attempt to circumvent those security measures. If you have additional questions regarding security, please feel free to contact us directly using the information provided under CONTACT US. To ensure that our employees comply with our privacy policies, we have developed a training program that provides all employees with the tools and knowledge to protect your personal information in all aspects of their work. Any employee who violates our privacy policies is subject to disciplinary action including possible termination and civil and/or criminal prosecution.

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CALIFORNIA CONSUMERS

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The California Consumer Privacy Act (“CCPA”) permits residents of California to have the following additional rights. For more information, or if you have questions, you can contact us using the information provided under CONTACT US. For your protection, Goodway Group is required to collect certain information from you to verify your identity before we respond to any request submitted by you. The information you provide to verify your identity will only be used for verification purposes, and a record of your request including certain information contained within it will be maintained by Goodway Group for its files

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1. California Residents Have the Right To Request Goodway Group Disclose What Information It Collects, Uses and Discloses

‍California residents have the right to request that Goodway Group disclose what personal information Goodway Group collects, uses and discloses about them now and in the last twelve (12) months. The categories of personal information Goodway Group collects about California residents are listed above under WHAT INFORMATION WE COLLECT. If you are a California resident and would like to request the personal information that Goodway Group collects, uses and discloses about you, please complete this REQUEST FORM and send it to Goodway Group using the information provided under CONTACT US or contact Goodway Group at the toll-free number provided under CONTACT US.

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‍2. California Residents Have The Right To Request the Deletion of Their Personal Information Maintained by Goodway Group

‍California residents have the right to request that Goodway Group delete the personal information Goodway Group maintains about them. Goodway Group will make every effort to comply with California residents’ requests to delete their personal information, however, certain laws or other legal requirements might prevent some personal information from being deleted. If you are a California resident and would like to request the deletion of your personal information, please complete this REQUEST FORM and send it to Goodway Group using the information provided under CONTACT US or contact Goodway Group at the toll-free number provided under CONTACT US. To verify any request to delete personal information, you will be required to provide the information contained in the request form. Failure to do so could result in Goodway Group’s inability to comply with your request.

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‍3. California Residents Have the Right to Non-Discrimination for the Exercise of Their Privacy Rights Under the CCPA

‍Under the CCPA, California residents have the right not to receive discriminatory treatment by Goodway Group for the exercise of their privacy rights. However, the exercise of certain privacy rights by California residents will make it so that Goodway Group is no longer able to provide those residents with certain services. For example, if, at the request of a California resident, Goodway Group deletes all of the California resident’s personal information that it maintains, Goodway Group will no longer be able to send marketing communications to that California resident.

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‍4. DO NOT SELL MY PERSONAL INFORMATION: California Residents Can Opt Out of the Sale of Their Personal Information

‍The CCPA provides California residents the right to opt out of the sale of their personal information by Goodway Group. If you are a California resident and would like to opt out of the sale of your personal information, please complete this REQUEST FORM and send it to Goodway Group using the information provided under CONTACT US or contact Goodway Group at the toll-free number provided under CONTACT US. California residents may choose to use an authorized agent to exercise their right to opt out of the sale of their personal information, subject to the requirements in the below section on designating an authorized agent.

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‍5. California Residents Can Designate an Authorized Agent To Make a Request Under the CCPA on Their Behalf

‍California residents can designate an authorized agent to make requests under the CCPA related to the residents’ personal information. Goodway Group can deny any request made by an agent who does not submit proof that he or she has been authorized by the California resident to act on the California resident’s behalf. For more information on submitting a request on behalf of a California resident as an authorized agent, you can contact us using the information provided under CONTACT US.

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‍6. Do Not Track

‍Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking across websites. Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a website should respond to this signal, so we do not take any action in response to this signal. Goodway Group does not have a mechanism in place to respond to DNT signals. Instead, in addition to publicly available third-party tools, we offer you the choices described in this Privacy Policy to manage the collection and use of information about you.

Goodway Group does track some activity across websites (including your search terms, the website you visited before you visited or used the Services and other clickstream data) and we may continue to collect information in the manner described in this Privacy Policy from web browsers that have enabled DNT signals or similar mechanisms.

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NEVADA CONSUMERS

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Nevada law provides Nevada residents the ability to opt out of the sale of their personally identifiable information collected by Goodway Group. If you are a Nevada resident and would like to opt out of the sale of your personally identifiable information, please complete this REQUEST FORM and send it to Goodway Group using the information provided under CONTACT US.

For your protection, Goodway Group is required to collect certain information from you to verify your identity before we respond to any request submitted by you. The information you provide to verify your identity will only be used for verification purposes, and a record of your request, including certain information contained within it, will be maintained by Goodway Group for its files.

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CHANGES TO THIS PRIVACY POLICY

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This Privacy Policy may be revised from time to time as we add new features and Services, as laws change and as industry privacy and security best practices evolve. We display an effective date on this Privacy Policy at the top of this Privacy Policy so that it will be easier for you to know when there has been a change. If we make any material change to this Privacy Policy regarding use or disclosure of personal information, we will provide notice on our sites. Changes will apply to information collected after the change is effective. Please check this Privacy Policy periodically for changes. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice. Your use of the sites constitutes acceptance of the provisions of this Privacy Policy and your continued usage after such changes are posted constitutes acceptance of each revised Privacy Policy. If you do not agree to the terms of this Privacy Policy or any revised Privacy Policy, please exit the sites immediately. If you have any questions about this Privacy Policy, the practices of the sites or your dealings with the sites, you can contact us by using the information provided under CONTACT US.

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CONTACT US

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Please contact Goodway Group with any questions or concerns regarding this Privacy Policy.

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Goodway Group, Inc.

228 Park Ave South

Suite 81524

New York, NY 10003-1502

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Attn: Privacy

(877) 274-9881 (toll-free)

privacy@goodwaygroup.com

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If you have any questions or concerns regarding our Privacy Policy, or if you believe our Privacy Policy or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with Goodway Group using the contact information listed above, and we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns, and may need to engage or consult with other parties in order to investigate and address your issue. We may keep records of your request and any resolution.

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INTERNATIONAL PRIVACY POLICY

Both the above general Privacy Policy and this International Privacy Policy (the “International Policy”) apply to those individuals visiting the site(s) or using our Services from Canada, Singapore and member states of the European Union except that, for such persons (and only for such persons), where the provisions of the general Privacy Policy and the International Policy cannot be construed consistently, the International Policy will govern.

The Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”), the Singaporean Personal Data Protection Act (“PDPA”), the Swiss Revised Federal Act on Data Protection 1992 and Ordinance on the Federal Act on Data Protection, the European Union General Data Protection Regulation (“GDPR”), and the United Kingdom Data Protection Act 2018 (“UK GDPR”) impose requirements regarding the collection, use and disclosure of personal data in relation to our commercial activities, as does private-sector privacy legislation in their local jurisdictions, provinces and territories.

THIS INTERNATIONAL POLICY APPLIES TO ALL PERSONAL DATA ABOUT YOU THAT WE COLLECT, HOLD, USE AND DISCLOSE, REGARDLESS OF THE WAY IN WHICH WE COLLECT IT (I.E., WHETHER THROUGH A SITE OR OTHERWISE).

1. Personal Data

In this International Policy, personal data is as defined by applicable Canadian, Singaporean and European Union law. It generally means any information about an identifiable individual. It may include your name, age, mailing address, residential phone number or email address, personal history (including financial and credit information, donations, personal health information, billing history, personal family and relationship matters and penal or criminal information), personal information related to corporate involvements, work experience (past and present), discipline, income and benefits, medical records, tax records, security clearances and computer data (IP address, geographical location, browser type, domain names, referring website addresses, access times, length of visit and number of page views).

2. Collection of Personal Data

We collect personal data from the site(s), as well as through correspondence, faxes, live chats, emails, telephone inquiries, web forms, and other means of communication. We collect such information when we provide the Services and other lawful purposes.

We (and our affiliates and authorized service providers) may collect, store and use the information discussed above in WHAT INFORMATION WE COLLECT, INFORMATION WE COLLECT FROM THIRD PARTIES and COLLECTION OF TECHNICAL INFORMATION AND USAGE INFORMATION.

Where we are the Data Controller with regard to that data you may exercise your rights as data subject, including the right to object to the processing of your personal data when it is processed based on legitimate interests as provided in this International Policy below. However, we primarily collect and process your personal information as a processor or service provider on behalf of our customers. This means that we collect, process and disclose your personal information at the direction of our customers. Where we are collecting your personal information on behalf of another entity (i.e., we are not the data controller), we will provide you with the identity of the data controller so that you may exercise your rights as a data subject directly with them.

3. How We Use Personal Data

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In addition to the uses described above in HOW WE USE YOUR INFORMATION, as a general matter, we collect your personal data primarily to provide services to our customers, for administrative or management requirements and to enhance our relationship with customers.

Goodway Group collects and uses your personal data to operate its site(s), deliver the Services you have requested and to provide services to our customers including advertising services.

Goodway Group may also use your personal data to inform you of other products or services available from Goodway Group and its affiliates. Goodway Group may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.

Goodway Group may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your personal data (email, name, address, telephone number) is not transferred to the third party. Goodway Group may share data with trusted partners to help perform statistical analysis, send you email or postal mail or provide customer support. All such third parties are prohibited from using your personal data except to provide services to you, and they are required to maintain the confidentiality of your data.

Goodway Group may keep track of the websites and pages our users visit within Goodway Group in order to determine what Services are the most popular. This data is used to deliver customized content and advertising within Goodway Group to customers whose behavior indicates that they are interested in a particular subject area.

Goodway Group will disclose your personal data, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Goodway Group or the site; (b) protect and defend the rights or property of Goodway Group; and, (c) act under exigent circumstances to protect the personal safety of users of Goodway Group, or the public.

4. The Basis on Which We Process Your Personal Data

We will collect and process your personal information as is reasonably necessary for, or directly related to, one or more of our functions or activities including for administering our Website or providing our Services to you or our customers.

Where we are the data controller with regards to the personal information that we process, we process your personal information upon the legal bases described herein. However, we primarily collect and process your personal information as a processor or service provider on behalf of our customers. This means that we collect, process and disclose your personal information at the direction of our customers. Where we are collecting your personal information on behalf of another entity (i.e., we are not the data controller), we will provide you with the identity of the data controller upon request so that you can contact them to understand the legal basis upon which your data is processed.

Where required by law, we rely on the following legal grounds to process your personal data, namely:

1. Performance of a contract – We may need to collect and use your personal data to enter into a contract or to perform a contract that you or your Goodway Group has with us.
2. Consent – Where required by applicable laws, we will rely on your consent for collecting your personal data.
3. Legitimate interests – We may use your personal data for our legitimate interests to improve our services. Consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable laws, we may use technical information as described in this Privacy Policy and International Policy and use personal data for our marketing purposes.

We will only process personal data for a specific purpose or for any other purposes specifically permitted by applicable data protection legislation.

5. Obtaining Consent

Except when otherwise permitted by law, we obtain the requisite consent prior to collecting and, in any case, prior to using or disclosing your personal data for any purpose. You may provide your consent to us orally, in writing, by electronic communication or any other means reasonably capable of conveying your consent.

We will obtain your express consent if we collect, use or disclose sensitive personal data in our capacity as a data controller. We may also share data with third-party partners for whom you have given us consent. Your consent may also be intrinsic to the circumstances such as in the case where you have already provided personal data to us and you maintain your relationship with us or where you provide our representatives with your phone number so that we can contact you. Except when otherwise permitted by law, we will only use the data for the purpose for which it was given. From time to time, we may collect, utilize or disclose your personal data based on your consent and as otherwise permitted by law.

When your consent is required, you may withdraw your consent at any time (unless withdrawing the consent would frustrate the performance of legal obligations) upon providing to us a 30-day notice. However, the withdrawal of your consent may adversely affect our ability to provide Services to you and to maintain our relationship.

6. Third Parties

We remain responsible for all personal data communicated to third parties for processing. As such, we ensure that third parties that are engaged to provide products or services on our behalf and are provided with personal data are required to observe the intent of this International Policy by having comparable levels of security protection or, when required, by assuring us (through a confidentiality agreement) that they will not use or disclose the personal data for any purpose other than the purpose for which the personal data was communicated.

7. Limitations

We only collect the personal data necessary to fulfill the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes or as required by law.

We do not use or disclose your personal data, except for the purposes for which it was collected, or new purposes to which you have consented, or as required or otherwise permitted by applicable law.

We do not, as a condition of providing services to you or on your behalf, or as an administrative or management requirement, require consent to the collection, use or disclosure of personal data beyond what is reasonably required for such purposes, or to comply with our obligations under applicable law.

8. Retention of Personal Data

We may keep a record of your personal data, including correspondence or comments, in a file specific to you. We will utilize, disclose or retain your personal data only for as long as necessary to fulfill the purposes for which it was collected and for legal or business requirements. We will establish minimum and maximum retention periods and procedures for maintaining and destroying your personal data. When personal data is retained to make a decision about you, we will retain such information for the period required in order to comply with our internal data retention policies.

9. Access and Rights to Your Personal Data

There are a number of data privacy laws that provide specific data subject rights to residents of certain jurisdictions. This section of this International Policy describes the rights available to those individuals who are entitled to them. Not all individuals about whom we possess information will have access to these rights and we may not be able to provide these rights to everyone due to legal and jurisdictional limitations. We may not be able to comply with your request for a number of reasons including:

• you do not live in a jurisdiction that grants you the specific right that you have requested;
• the information that you’ve requested is not subject to the regulation that grants you the right to make a request in relation to your personal information;
• we are prevented by law, regulation or rule from complying with your request;
• we are not able to comply with your request without incurring disproportionate burden or expense; or
• if complying with your request conflicts with the integrity of our services or the ability to administer our business, to administer our business and related relationships or to establish, defend or administer legal claims.

If any of the above reasons apply, we will let you know in our response to your request. Note that we may be required to gather additional information from you in order to process your request. We will only use this information in the context of evaluating and responding to your request. If you fail or refuse to provide the necessary information, we may not be able to process your request.

Subject to the exceptions provided by applicable law or regulation, and depending on your country of residence, you may have the following rights regarding your personal information:

• The right to request confirmation that Goodway Group maintains or processes personal information about you.
• The right to know what categories of personal information Goodway Group maintains or processes about you.
• The right to access the personal information that Goodway Group maintains or processes about you.
• The right to request that a copy of your personal information that Goodway Group maintains or processes about you be provided to you or another data controller in a portable format.
• The right to know the purpose for Goodway Group maintaining and processing your personal information.
• The right to withdraw your consent for Goodway Group’s processing of your personal information, if our processing is based upon your consent.
• The right to request the correction of inaccurate personal information that Goodway Group maintains about you.
• The right to request that Goodway Group delete the personal information that it maintains about you.
• The right to request that Goodway Group restrict the processing of your personal information due to the following reasons:
  • That the personal information as maintained by Goodway Group is inaccurate and has not yet been corrected.
  • That Goodway Group’s processing is unlawful, but you do not want Goodway Group to delete your personal information.
  • That Goodway Group no longer needs your personal information for the purposes of its processing, but Goodway Group has stated that we need your personal information for establishment, exercise or defense of legal claims.
  • Because you object to Goodway Group’s processing of your personal information.
• The right to know the envisaged period for which Goodway Group will maintain your personal information, or, if not possible, the criteria used to determine that period.
• The right to know the categories of recipients to whom Goodway Group has disclosed your personal information including if those recipients are located outside of your country of residence.
• The right to know the safeguards put into place by Goodway Group to protect your personal information when it is disclosed outside of your country of residence.
• The right to know the sources from which Goodway Group collected personal information about you.
• The right to know whether Goodway Group engages in automated decision making, including profiling, relating to you.
• The right to opt out of Goodway Group’s automated decision making programs.
• The right to object to Goodway Group’s processing of your personal information that is based upon Goodway Group’s legitimate interests, as described herein.
• The right to object to Goodway Group’s processing of your personal information for the purposes of direct marketing.
• The right to object to Goodway Group’s processing of your personal information for the purposes of scientific or historical research or statistical analysis.

You can request to exercise these rights by using the information provided under REQUEST FORM. Please be as specific as possible in your request so that we can meet the applicable handling timelines.

Finally, you have the right to raise a complaint with Goodway Group or the appropriate data protection authority of your country of residence if you feel that Goodway Group’s processing of your personal information violates your individual rights, is not in line with this International Policy or violates the privacy principals, laws or regulations of your country of residence.

• You can contact Goodway Group’s data protection officer by using the information provided under Contact Us. We will promptly investigate any complaint and will respond within the time frames described in this International Policy.
• If you are a resident of the European Union, you can find your appropriate data protection authority by following this link.
• If you are a resident of the United Kingdom, you can contact your data protection authority through the information provided in this link.
• If you are a resident of Switzerland, you can contact your data protection authority through the information provided in this link.
• If you are a resident of Australia, you can contact your data protection authority through the information provided in this link. You can view the Australian Privacy Principles through this link.
• If you are a resident of Canada, you can contact your data protection authority through the information provided in this link.

An interactive map showing the various Data Protection Authorities around the world and how to contact them can be found here.

10. Response Times

We will make every reasonable effort to respond to each of your written requests no later than 30 days after receipt of such requests. When applicable, we will advise you in writing if we cannot meet your requests within this time limit. When applicable, you have the right to make a complaint to the appropriate supervisory authority with respect to this time limit.

11. Costs

We expect to be able to respond to your request without charge as a general matter. However, we reserve the right to collect a reasonable charge when you request the transcription, reproduction or transmission of such information. We will notify you, following your request for transcription, reproduction or transmission of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request.

12. Identifying You in Connection With Requests

We may require that you provide to us sufficient information to identify yourself before we provide information about the existence, use or disclosure of your personal data in our possession. Any such information shall be used only for this purpose.

13. Opt Out and Unsubscribe

We respect your privacy and give you an opportunity to opt out of receiving certain information. Users may opt out of using the instructions located in emails sent by Goodway Group or by contacting us using the information under Contact.

14. Accuracy

We will use reasonable efforts to ensure that your personal data is kept as accurate, complete and up to date as possible. We will not routinely update your personal data unless such a process is necessary. In order to help us maintain and ensure that your personal data is accurate and up to date, you must inform us, without delay, of any change in the data you provided to us.

You can at any time, challenge the accuracy or completeness of the personal data we have about you, subject to the exceptions provided by applicable law. If you demonstrate that the personal data we have on you is inaccurate or incomplete, we will amend the personal data as required. Where appropriate, we will transmit the amended data to third parties to whom we have communicated your personal data.

15. Safeguards

We use security safeguards appropriate to the sensitivity of personal data to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures such as restricted access to offices and equipment, organizational measures such as security clearances and publishing this policy to appropriate personnel with instructions to act in accordance with its principles (for example, limiting access on a “need to know” basis) and technological measures such as the use of passwords and/or encryption.

Personal data is generally located at our corporate or divisional offices. A list of corporations, divisions, subsidiaries and affiliates to which this Privacy Policy and International Policy apply is available upon request.

16. Contact

Please direct all complaints or other inquiries regarding personal information, the Privacy Policy or the International Privacy Policy to our Privacy Manager as follows.

For residents of the EU and Singapore:

Ruben Tienhooven
Ruben.Tienhooven@bdo.nl
GSM: +31 (0)623214871

For residents of Canada:

Goodway Group, Inc.
228 Park Ave South
Suite 81524
New York, NY 10003-1502

Attn: Privacy
(877) 274-9881 (toll-free)
privacy@goodwaygroup.com

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