PRIVACY POLICY

EFFECTIVE AS OF MARCH 8, 2021

Your privacy, and the privacy of all users of Influenster is important to us. Influenster is committed to protecting your privacy online. Accordingly, Influenster has developed this privacy policy that describes how we collect, use, and share your data ("Privacy Policy"). This Privacy Policy sets forth the policies and procedures of personal information received from users of the Service, including but not limited to the website at www.influenster.com, www.bazaarvoice.com, and/or the mobile applications created by Influenster (collectively, the "Influenster Service" or "Service").

This Privacy Policy is applicable to all site visitors, registered users, and all other users of the Service.

The terms "We", "Us", and "Influenster " refer to the Influenster Service. The terms "You" and "Your" refer to you, as a visitor or user of the Service.

By using the Service, you are consenting to our processing of your information as set forth in this Privacy Policy, as amended from time to time.

Further, you acknowledge that this Privacy Policy is part of our Terms of Service ("TOS"), which is incorporated by reference, and by accessing or using the Service, you agree to be bound by all of its terms and conditions. If you do not agree to these terms, and the terms and conditions in our TOS, you may not access or use the Service.

HOW WE COLLECT AND USE YOUR INFORMATION

Personal Information: When registering as a user to the Service, we receive and store information you enter or provide to us in any other way. The types of personal information collected may include your name, email address, URL, phone number, Twitter, Tumblr, Google Plus and/or Facebook usernames, location, use information regarding your use of the Service, browser information, and any other data that is tied to such information (collectively, "Personal Information"). The Personal Information you provide is used for such purposes as allowing you to set up a user account and profile that can be used to interact with other users through the Service, improving the content of the Service, customizing the advertising and content you see, and communicating with you about specials and new features. We may also draw upon this Personal Information in order to adapt the Services of our community to your needs, to research the effectiveness of our network and Services, and to develop new tools for the community.

Profiles: "Public Content" refers to information that you submit or post to the Service for public display, such as photos, comments, reviews, and your public profile information.

Information Collected Automatically: When you use the Service, we automatically receive and record information on our server logs from your browser or mobile platform, including your location, IP address, cookie information, and the page you requested. This data is treated as non-Personal Information, except as required under applicable law.

HOW YOUR INFORMATION IS SHARED

Information about our users is an integral part of our business. We provide some of our services through affiliates, service providers, partners and other third parties. We may share Public Content, as well as a limited amount of Personal Information (including, but not limited to, your first name, last initial, and location) with third parties, who may in turn publicly display or publish this limited amount of Personal Information in connection with Public Content on their own website and media platforms. Personal information collected as part of the SMS program is not shared. At any time you may visit the "Account Settings" page of your Member Account and opt-out of having some or all of your Personal Information made available to such third parties as described herein.

We encourage our service partners to adopt and post privacy policies. However, the use of your Personal Information by our service partners is governed by the privacy policies of those service partners, and is not subject to our control.

We may disclose aggregated information concerning user behavior to third parties in connection with actual or prospective business relationship with those third parties, such as advertisers and content distributors. For example, we may disclose the number of users that have been exposed to, or clicked on, advertising banners.

In the future, may use third party advertising companies to serve ads when you visit the Service. These companies may use information about your Public Content (not including your name, address, email address, or telephone number) and activity related to your use of the Service to provide advertisements about goods and services of interest to you.

One of the primary reasons people use Influenster is to connect with others. Information such as your name and photo, photos of your items, location, list of friends, and the comments you write is shared with the Influenster community. Individuals reading this information may use it or disclose it to other individuals or entities without our control and without your knowledge. We therefore urge you to think carefully about including any specific information you may deem private in comments or other content (location or otherwise) that you create in the Service.

We employ other companies and people to perform tasks on our behalf, such as the creation of shipping labels, and need to share your information with them to provide services to you. Our agents do not have any right to use Personal Information we share with them beyond what is necessary to assist us, and they provide a comparable level of protection for your Personal Information.

Law Enforcement and Protection. We may disclose your Personal Information to third parties in a good faith belief that such disclosure is reasonably necessary to (a) take action regarding suspected illegal activities; (b) enforce or apply our TOS and Privacy Policy; (c) comply with legal process, such as a search warrant, subpoena, statute, or court order; or (d) protect our rights, reputation, and property, or that of our users, affiliates, or the public. Please note that we are not required to question or contest the validity of any search warrant, subpoena or other similar governmental request that we receive.

Invite Friends and Contacts. You may choose to provide us with another person's e-mail address or social network profile information so that person may be invited to create an account on this site and become your friend. We use this information to contact and, if necessary, remind that person about the invitation. By providing us with another person's e-mail address, you represent to us that you have obtained the consent of the person concerned with respect to such disclosure to us of their Personal Information. We may disclose such information if required to do so in order to comply with legal process, as described above.

Business Transfers. If Influenster or substantially all of Influenster's assets are acquired, or in the unlikely event that we cease business operations or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party.

COOKIES AND SIMILAR TECHNOLOGIES

We send cookies to your computer or mobile device through your browser to enable our systems to recognize your browser and tell us how and when pages in our site are visited and by how many people. Most browsers have an option for disabling the cookie feature, which will prevent your browser from accepting cookies, as well as (depending on your browser software) allow you to decide on acceptance of cookies in a variety of ways.

Ads appearing on the Service may be delivered to users by our advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This PrivacyPolicy covers the use of cookies by us and our service providers and does not cover the use of cookies by any advertisers.

We use analytics (and related analytics programs) to better understand who is using the Service, and how people are using it. Analytics uses cookies to collect and store anonymous information such as time of visit, pages visited, time spent on each page of the website, IP address, and type of operating system used. We use this information to improve the Service and make it appealing to as many users as possible.

Our Cookie Policy explains how you can manage cookies and similar technologies.

LOCATION INFORMATION

If your location settings are turned on when you use the Service, we use the location information from your mobile device or browser to tailor your experience. We collect and store your last known location to determine your proximity to our service partners. This location information is not shared with third parties. The Service also uses your mobile device’s background location to provide the Service, which allows us to provide you with location-based services, such as location-specific promotions, mobile-based campaign activity capabilities, and other personalized content tailored to you. If you have background location turned on, the mobile application will, from time to time, tell us about your device’s location even if you are not directly interacting with the application.

HOW WE RESPOND TO DO NOT TRACK SIGNALS

We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions. You can change your privacy preferences regarding the use of cookies and similar technologies through your browser. For more information on Do Not Track please visit http://www.allaboutdnt.org/

SECURITY

Your account is password protected for your privacy and security. You need to prevent unauthorized access to your account and Personal Information by selecting and protecting your password, and limiting access to your computer, phone and browser such as signing off after you have finished accessing your account. We use industry standard measures to protect Personal Information. However, we cannot guarantee the security of account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

The Service may contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When linking to another site, you should read the privacy policy stated on that site. This Privacy Policy only governs information collected on the Service.

INTERNATIONAL USERS

If you are located outside of the United States, please note that the Service is located on computer servers in the United States. Therefore, your information may be processed and stored in the United States. As a result, United States federal and state governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through laws applicable in the United States. Your use of the Service or your submission of any Personal Information to us will constitute your consent to the transfer of your Personal Information outside of your home country, including the United States, which may provide for different data protection rules than in your country. Please also see supplemental privacy policy section for European Economic Area residents.

CHILDREN

The Service is not directed toward children under 13 years of age nor do we knowingly collect information from children under 13. If you are under 13 years of age, you are not permitted to submit any Personal Information to us.

PRIVACY PRACTICES OF THIRD PARTIES AND THIRD PARTY SITES

The Service may contain links to third party websites to which we have no affiliation. Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. Other sites accessible through our site via links or service partnerships have their own privacy policies and data collection, use and disclosure practices. Please consult each site’s privacy policy. We are not responsible for the policies or practices of third parties. Additionally, other companies may place advertising on our site and may collect information about you when you view or click on their advertising through the use of cookies. We cannot control this collection of information. You should contact these advertisers directly if you have any questions about their use of the information that they collect.

CONTROL OF PERSONAL INFORMATION

To the extent you include Personal Information in your Public Content (such as a photo of yourself), third parties may be able to identify you, associate you with your account, and contact you. Please do not include information in your Public Content that you expect to keep private.

Third parties can also associate you with your account using the user search and browse features of the Influenster Service, which display your Public Content.

Upon your request, we will use commercially reasonable efforts to close your account, and cease displaying your Public Content on the Service; nevertheless, we may still retain your Personal Information and your Public Content in our systems. Registered users who wish to close their account should contact us.

INFLUENSTER SUPPLEMENTAL PRIVACY POLICY FOR CALIFORNIA RESIDENTS

The California Consumer Privacy Act ("CCPA"), which is effective as of January 1, 2020, regulates how we handle personal information of California residents and gives California residents certain rights with respect to their personal information.

Influenster is both a "business" and a "service provider" under the CCPA. The following supplemental privacy policy applies to information we collect in our role as a business—which is when we interact directly with you.

When we act as a service provider, we follow the instructions of the business that engaged us with respect to how we process your personal information. If you would like more information about how your personal information is processed by other companies, including clients that engage us as a service provider, please contact those companies directly.

This supplemental privacy policy is effective as of March 8, 2021, shall apply only to residents of California, and may be subject to change. The general privacy policy shall continue to apply to the extent that it applies to you as a resident of California. If you are a resident of California, we are required to disclose certain uses and disclosures in a certain format, as well as to inform you of certain rights you may have. Any capitalized terms used in this supplemental privacy policy shall have the same meaning as in the general privacy policy.

INFORMATION WE MAY COLLECT

We may collect the following categories of information:

BUSINESS DISCLOSURES BY INFLUENSTER

We have disclosed the following categories of personal information for a business purpose (auditing interactions with consumers, security, debugging/repair, certain short-term uses, performing services, internal research for tech development, and/or quality and safety maintenance and verification) in the 12 months prior to this Policy’s last update:

COMMERCIAL DISCLOSURES AND PERSONAL INFORMATION SALES BY INFLUENSTER

We have disclosed the following categories of personal information for commercial purpose or for valuable consideration in the 12 months prior to this Policy’s last update:

AGGREGATED OR DEIDENTIFIED DATA

Please take note note we may aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, deidentified data with third parties.

Your Rights as a California Resident:

You may have certain rights with respect to your personal information, including:

• The right to access, including the right to know the categories and specific pieces of personal information we collect;
• The right to deletion of your personal information, subject to certain limitations under applicable law;
• The right to request disclosure of information collected;
• The right to disclosure of information disclosed for valuable consideration
• The right to opt out of sales of personal information;
• The right not to be discriminated against for exercising certain rights under California law; and
• Under California’s "Shine the Light" law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing use. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2020 will receive information regarding 2019 sharing activities). Please be aware that not all sharing activities are covered by the Shine the Light law and only covered information will be included in our response.

Methods to Exercise Your Rights as a California Resident:

To exercise any of these rights, please submit a request by filling out this Web Form or alternatively by emailing privacy@influenster.com. Please be as specific as possible in relation to the personal information you wish to access. Once we receive your request, we will review it, determine whether we can verify your identity, and process the request accordingly. If we need additional information to verify your identity, we will let you know. We will respond to your request within 45 days of receipt, or notify you if we require additional time.

If you would prefer, you may designate an authorized agent to make a request on your behalf.

Contact:

If you have questions regarding this Policy or about the Influenster’s privacy practices, please contact us by email at privacy@influenster.com, or at:

Voxpop Inc. d/b/a Influenster

435 Hudson St. #400 

New York, NY 10014

Opting Out of Personal Information Sales for California and Nevada Residents:

Please click this link or button below if you would like to exercise your right under California or Nevada to opt out of personal information sales:

DO NOT SELL MY PERSONAL INFORMATION

INFLUENSTER SUPPLEMENTAL PRIVACY POLICY FOR EUROPEAN ECONOMIC AREA RESIDENTS

If the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 known as the General Data Protection Regulations ("GDPR") is applicable to you, e.g. you are a natural person residing within the European Economic Area or your personal data is processed by us on behalf of a controller residing in European Economic Area ("Data Subject"), the following additional rights are applicable to you:

Controller: Influenster is the controller of your personal data and you can contact us at privacy@influenster.com or by postal mail at Voxpop Inc. d/b/a Influenster 435 Hudson St. #400 New York, NY 10014.

Personal Data: For the purposes of this section, "Personal Data" means collectively personal data as defined by Art. 4 Nr. 1 GDPR, which you have provided to, or otherwise collected by, Influenster when you use and otherwise access the Service, listed above in section "Influenster Supplemental Privacy Policy for California Residents", subsection "Information we may collect".

Purpose of the processing is (i) to provide you with the possibility to view our website and (ii) in case of ratings and reviews, to collect ratings and reviews of products.

Legal Basis for Processing Personal Data for our website: (i) in case of just viewing our website the legal basis for processing your personal data is our legitimate interest (Art. 6 section 1 sentence 1 lit. f GDPR) and which includes, but is not limited to, providing you with the possibility to view our website, operation of our business and services, improving products and services, analysing performance of our systems, debugging, troubleshooting and providing customer support; in case this includes cookies or other technology to which you have given consent, the legal basis of our processing of your personal data insofar is your consent. You must be at least the age of 16 to consent to the processing of you Personal Data. If you are under the age of 16, you must obtain you parent’s or legal guardian’s permission to consent to the processing. In other occasions, we may process information when we need to do so to fulfill a contract or where it is necessary for compliance with a legal obligation to which we are subject to.

(ii) Legal Basis for Processing Personal Data for services we perform on behalf of our clients: if you take part in one of our offerings we provide to clients (e.g. ratings and reviews, vox box, tryIt and others) the legal basis normally is your consent. We may also process personal data on behalf of our clients as it is necessary for compliance with a legal obligation to which the controller is subject to.

Recipients in case of viewing our website only: if you only view our website we are recipients of your personal data.

Recipients for ratings and reviews and services we perform on behalf of our clients: in case of ratings and reviews and services we perform for our clients, we, our respective clients and those third parties they provide the information to are the recipients. Please contact us or respective client for details. As long as we provide the data to third parties on behalf of our clients and as part of our standard services to them, we only distribute a limited set of information. In case of ratings and reviews left on our site this is: username (the nickname you have provided to us), occasionally email addresses, the actual rating and the actual review. We will provide, on behalf of our clients, the information necessary for the shipping company to actually send the box to you, including your postal address. If you rate and review the products sent to you, this rating and review will be handled as described in this paragraph before. Depending on their services to us, our subcontractors can be recipients to your personal data. All of them are bound be respective agreements.

Transfer to third countries:

• Consent: In case you visit our website oder enter a rating and/or review, you have access to our systems in the USA. As this is legally a connection between you as a user of our systems and us as operator of our systems no additional safeguards are needed, as your actions are deemed to form consent to this data transfer. You can withdraw this consent at any time by sending an email toprivacy@influenster.com.
• Standard data protection clauses: We may, in accordance with Article 46 of the GDPR, transfer personal information from European Union to countries outside the European Union or the European Economic Area to recipients that have entered into the European Commission approved Standard Contractual Clauses for the transfer of personal data outside the European Economic Area.
• Other means: We may, in accordance with Articles 45 and 46 of the GDPR, transfer personal information to recipients that are in a country the European Commission or a European data protection supervisory authority has confirmed, by decision, offers an adequate level of data protection, pursuant to an approved certification mechanism or code of conduct, together with binding enforcement commitments from the recipient to apply the appropriate safeguards, including as regards data subjects’ rights, or to processors which have committed to comply with binding corporate rules.

Storage period: Generally we will retain your personal data for the period necessary to fulfill the purposes for which your personal information has been collected (as outlined in this privacy policy) unless you make an applicable request otherwise. Please note we may be required to retain data for a longer period if required by law.

Access, rectification: You may access, correct, or modify the Personal Data you provided to Influenster and associated with your account. You may do so by filling out this Web Form or emailing privacy@influenster.com.

Forgotten: You may request to have your Personal Data erased, or otherwise request that your Personal Data not be processed. Please note that the Service, or parts of the Service, may become inaccessible or otherwise not function properly if you request to have your Personal Data erased or not be processed. You may do so by filling out this Web Form or emailing privacy@influenster.com.

Object, Restrict, or Withdraw Consent: You may withdraw consent you previously provided to Influenster or otherwise object to or restrict the processing of your Personal Data. Please note that the Service, or parts of the Service, may become inaccessible or otherwise not function properly if you withdraw certain consents or otherwise object to ro restrict the processing of your Personal Data. Your withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. You may do so by filling out this Web Form or emailing privacy@influenster.com.

Portability: You may request to receive a copy of the Personal Data you have previously provided to us during your use of our Services. You may do so by filling out this Web Form or emailing privacy@influenster.com.

Supervisory Authority: If you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.

In case of any rating and review you provide to a client of us via our services, the provision of your personal data is a statutory requirement, as we are required by law to authenticate your rating and review. You are not obliged to provide this data but failing to do so has the consequence that your rating and review will be rejected and deleted.

There is no automated decision making as described in Art. 22 GDPR to your personal data.

CHANGES TO THE PRIVACY POLICY

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make material changes in the way we use Personal Information, we will notify you by posting an announcement, sending you an email, or updating the Privacy Policy on the site. You are encouraged to review the Privacy Policy from time to time in the event changes have been made. Users are bound by any changes to the Privacy Policy when they use the Service after such changes have been first posted.

PRIVACY FRAMEWORK

Influenster commits to resolve complaints about our collection or use of your personal information. Individuals with inquiries can first contact Influenster by email at privacy@influenster.com.

QUESTIONS OR CONCERNS

If you have any questions or concerns regarding your privacy, please send a detailed message to: privacy@influenster.com. We will make every effort to resolve your concerns.