Privacy Policy

Effective date: October 3, 2024

Dharma Initiative AG (Dharma) is committed to protecting your privacy. This Privacy Policy applies to the personal data we collect and process in the course of our business. Dharma Initiative AG (Dharma)acts in different ways when processing data:
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Dharma Initiative AG (Dharma) acts as a controller of your personal data when you sign up for our products and services, visit our websites or interact with us through other channels. We use this data for a variety of purposes, including to provide our products and services to you, contact you about relevant content, and improve and promote our products and services. 
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Dharma Initiative AG (Dharma) acts as a processor when our Users use our products and services to collect and process personal data in connection with their sales, marketing, and other business activities. In this case, we act as a processor (or service provider) on behalf of our Users (who are controllers of personal data). 
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Dharma Initiative AG (Dharma)also acts as a controller when we collect and process personal data about individuals in their professional capacity, and make that information available to Users for their own sales, marketing, and other business activities. This includes personal data we may collect indirectly about you, such as from publicly available sources, our Users, or other third parties. For more information see the “What Information We Collect and Process” section.For the purposes of this Privacy Policy "Personal Data" means any information relating to an identified or identifiable individual. This Privacy Policy describes your choices and rights with respect to your Personal Data, including your rights of access and correction.  
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For information about how to exercise your privacy rights when Dharma Initiative AG (Dharma) acts as a controller of personal data, please see the “Your Privacy Rights and Choices” section.To opt out and delete your personal data from our commercial dataset of professionals, please address your inquiry at hello@dharma.sh.
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We update this Privacy Policy from time to time and encourage you to review this Privacy Policy periodically. We will post any Privacy Policy changes on this page and, if the changes are material, notify you directly (for example, by sending you an email notification). Terms not otherwise defined in this Privacy Policy have the meaning given to them in the Dharma Initiative AG (Dharma)Terms of Service. 
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1. What Information We Collect and Process
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1.1 Information You Provide to Dharma
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When you interact with us via our websites or any sites or services that link to this Privacy Policy, we may collect Personal Data and other information from you, as further described below.
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1.1.1 When You Visit Our Websites
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We collect Personal Data from you when you submit web forms or interact with our websites, for example by subscribing to one of our services or requesting User support.

We may ask for your email address, first and last name, job title, and other similar business information. You are free to explore some of our websites without providing any Personal Data about yourself. 
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1.1.2 Payment Information 
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We collect payment and billing information when you register for paid products or services. For example, we may ask you to provide a billing address, or a billing contact for your Dharma Initiative AG (Dharma) account. If you give us payment information, we use it solely as authorized by you in accordance with this Privacy Policy. 
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1.1.3 Users may also provide payment information, such as a credit card number or bank account numbers, when purchasing products or services. We use secure third-party payment service providers to manage payment processing, which is collected through a secure payment process.  
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1.1.4 Mobile 
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When you access or use the Service via our mobile applications, we automatically collect information such as your device model and version, operating system, or device identifiers.  
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1.1.5 Log Files
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Like most websites and technology services delivered over the Internet, we automatically collect and store information about your computer hardware and software when you visit our websites, use our product and services, or visit other sites or services that link to this Privacy Policy. This information can include your IP address, browser type, domain names, internet service provider (ISP), and the files viewed on our websites (e.g., HTML pages, graphics, etc.), the files viewed on our, or our User’s websites (if those websites are hosted on Dharma Initiative AG (Dharma)e.g. HTML pages or, graphics etc.), your operating system, access times and referring website addresses.
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1.1.6 Third Parties
 
We may receive information from third party service providers, from related companies, and from our business and solution partners.
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1.1.7 Personal Data from Different Sources
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We may collect Personal Data about you from other sources, such as third party providers and publicly available sources (like social media platforms). This may include physical mail addresses, job titles, email addresses, phone numbers, IP addresses, and social media profiles. This helps us to update and improve our products, services, and records, identify new Users, create more personalized advertising, suggest products and services that may interest you, deliver personalized communications, and promote events. 
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1.1.8 Other Dharma Initiative AG (Dharma) Companies and Affiliates
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We may receive information about you from other companies that are owned or operated by Dharma.
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2. How We Use Personal Data
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2.1 To Communicate with You About the Product and Services
We use the account information you provide to Dharma Initiative AG (Dharma) when signing up for our products and services, to send you transactional emails or in-app notification about billing, account management, and other administrative matters.
We use your information to provide User support, such as resolving technical issues you encounter and analyzing product outages or bugs.
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If you use the Dharma Initiative AG (Dharma) mobile applications, we may send you push notifications from time to time in order to update you about events and promotions. If you no longer wish to receive such communications, you may turn them off at the device level.
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2.2 To Provide the Services
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We use your account information and User Data to provide the product and services to you. For example, we use the email address you provide when signing up for the product to create your user account, and we use your payment information to process payments for paid use of the Services. We also use this information to authenticate you when you log in and to provide User support.
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2.3 To Improve and Develop Our Product and Services
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We use professional data, log files, and usage data about how you or your users interact with our product and services to develop and improve our products and services. For example, we use usage data to assess trends and usage across the product to help us determine what new features or integrations our users may be interested in.
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We may use User Data for machine learning that supports certain products and development of features and functionality with the   Service and similar products and services. For example, machine learning helps power the business card scanner tool if you use our mobile apps and allows for easier imports of data into your Dharma Initiative AG (Dharma) account. You may opt out of having your User Data used for machine learning by following the instructions on the Opt out of Dharma's machine learning data use knowledge base article.
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We may publish data about how our product and services are being used across our User base. When we share statistical information externally in this way, the data will be aggregated and we will not identify individual users or Users. For example, we may publish blog posts on trends or insights into how users are interacting with our product. 
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2.4 To Secure and Protect our Product and Dharma Initiative AG (Dharma) Users
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We use your account information to investigate and help prevent security incidents. We may also use this information to meet legal requirements. We use your information to verify user accounts, new product sign-ups, and to detect and prevent product abuse. This includes enforcing our Acceptable Use Policy.  
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We use log files to provide general statistics regarding use of the websites by you, including how you use our websites, what country you are logging in from (for analytics, export control and regulatory purposes) and to help improve the navigation experience. Your IP addresses are also collected and logged for security and debugging purposes, for example to track access patterns, investigate security events and incidents. For these purposes we associate automatically-collected data to other personal data provided by you such as name, email address, address, and phone number. 
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2.5 To Market and Promote the Services
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We use Personal Data to advertise, market, and promote our products, services, and other offerings. For example, we use information like your email or physical address to send information or Dharma Initiative AG (Dharma) content to you we think may be of interest to you, including by post, email, or other means.  We may also send you marketing communications relating to our business.
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You may opt out of receiving this promotional content by following the instructions contained in each communication that we send to you. If you unsubscribe from our marketing lists, we will continue to contact you regarding administrative matters, and to respond to your requests.
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We may reach out to you via telephone to ask about other Dharma Initiative AG (Dharma) products or services you may be interested in. If you have a call scheduled with a Dharma Initiative AG (Dharma) representative, we may record and transcribe the call. You will be notified prior to the call that the call is being recorded, and you will be offered an opportunity to opt-out of having the call recorded.  We may also reach out to you via SMS, and you will be offered an opportunity to opt out of those communications.  
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Where required by law, we will only send marketing communications with your consent. Otherwise, we will market and advertise our products and services on the basis of our legitimate business interests.
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We may use information collected from third party service providers and other sources in combination with other information we collect through other means described in this Privacy Policy for the purposes of providing you with updates and improved services, personalized communications, event promotion, and to otherwise improve the user experience. 
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2.6 Other Purposes if We Obtain Your Consent
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We may use your data for other purposes when you give us consent to do so.
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2.7 Legal Basis for Processing Personal Data (EEA and UK visitors only) 
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Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only where we have your consent to do so, where we need the Personal Data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you.
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If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data). Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
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3. How We Share Personal Data
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3.1 Service Providers 
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We may share Personal Data with our third party service providers to support our websites, products, and services. For example, we use service providers for data hosting, application development, marketing, sales support and User support. We may need to share your information with service providers to provide information about products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis on your use of the   Service or interactions on our websites, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, developing and improving the product and services, and providing User service or support. These service providers are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information in this way, we explicitly require the third party service providers to acknowledge and adhere to our privacy and data protection policies and standards.
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3.2 Partners 
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We may share your personal data with trusted Dharma Initiative AG (Dharma)partners to: (i) contact you based on your communication preferences;
(ii) help us perform statistical analysis;
(iii) provide sales support;
(iv) provide User support;
and (v) to improve our partner programs and  s Services. Partners are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your data.
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We also partner with trusted third parties to provide you with co-marketing content that we think may be relevant to you. When you engage with these co-marketing partners, we will tell you who we are sharing data with, and provide a link to the co-marketing partner’s privacy policy so you can learn more about how to opt-out of the partner’s communications. These co-marketing partners are required to adhere to our privacy and data protection policies. For more information on our co-marketing program, see this page.
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3.3 Advertising Partners
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We allow advertising networks to collect information about your interactions with our websites in order to deliver Dharma’s personalized ads. We may also share Personal Data, such as your email address, with our advertising partners to deliver Dharma’s personalized ads on other companies' sites or mobile apps.  You can opt out of having your data disclosed to our advertising partners through this form.
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3.4 Corporate Events 
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If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Dharma Initiative AG (Dharma) on the websites and the   Service. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data.
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3.5 Compelled Disclosure 
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We reserve the right to use or disclose your Personal Data if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process. If you use the Services, User Data is considered Confidential Information and you should review the Confidentiality terms in the User Terms of Service for more information.
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3.6 Dharma, Other Companies, and Affiliates
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We may share your Personal Data with our current and future parents, Affiliates, subsidiaries, and other entities under common control and ownership to the extent necessary to fulfill your request or for other purposes permitted under this Privacy Policy.
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4. How We Transfer Personal Data Internationally
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4.1 International Transfers within the Dharma Initiative AG (Dharma) Group
To facilitate our global operations, we may transfer information that may include Personal Data to other Dharma Initiative AG (Dharma) Affiliates who act as subprocessors, where we have operations for the purposes described in this policy. 
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This Privacy Policy will apply even if we transfer Personal Data to other countries. We have taken appropriate safeguards to require that your Personal Data will remain protected wherever it is transferred. When we share Personal Data of individuals in the European Economic Area ("EEA"), Switzerland or the United Kingdom ("UK") within and among Dharma’s Affiliates, we rely upon the the Standard Contractual Clauses (approved by the European Commission and Swiss authorities) and UK Addendum to the Standard Contractual Clauses (approved by the UK authorities) where required.  We also have additional safeguards where appropriate (such as commercial industry standard secure encryption methods to protect User data at rest and in transit, TLS for Dharma Initiative AG (Dharma)hosted sites, web application firewall protection, and other appropriate contractual and organizational measures), as described more in detail in the Dharma Initiative AG (Dharma) Trust Center.
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4.2 International Transfers to Third Parties
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Some of the third parties described in this Privacy Policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share Personal Data of individuals in the EEA, Switzerland or UK with third parties, we use a variety of legal mechanisms to safeguard the transfer including the European Commission-approved Data Privacy Framework Standard Contractual Clauses, as well as additional safeguards where appropriate. For transfers to or from the United Kingdom, we make use of the UK Addendum. For transfers to or from Canada, we make use of the standard contractual clauses. With respect to personal data received from or transferred to Canada, Dharma Initiative AG (Dharma) is subject to the regulatory enforcement powers of the Office of the Privacy Commissioner of Canada. Please contact us if you need more information about the legal mechanisms we rely on to transfer personal data outside the EEA, Switzerland, Canada, and UK.
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5. How We Store and Secure Personal Data
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5.1 Data Storage and Security 
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We use a variety of security technologies and procedures to help protect your Personal Data from unauthorized access, use or disclosure. We secure the Personal Data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Data is protected using appropriate physical, technical and organizational measures. 
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5.2 Retention of Personal Data
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How long we keep information we collect about you depends on the type of information and how we collect and store it. After a reasonable period of time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
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We retain Personal Data that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
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When we have no ongoing legitimate business need to process your Personal Data, we securely delete the information or anonymize it or, if this is not possible, securely store your Personal Data and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request, as described in the "Privacy Rights and Choices" section.
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If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your Dharma Initiative AG (Dharma) account.  We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
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The data we process on behalf of Users connection with the Services is stored and secured according to the Terms of Service.
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6. Cookies and Similar Technologies
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6.1 Cookies 
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When you visit our websites, sign up for a Dharma Initiative AG (Dharma) account, attend a Dharma Initiative AG (Dharma)virtual event, or request more information about Dharma, we collect information automatically using tracking technologies, like cookies and tracking pixels. For more information, and to learn how to opt out, please refer to our Cookie Policies below.
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Dharma Initiative AG (Dharma) may use cookies or similar technologies (such as web beacons and JavaScript) to analyze trends, administer the website, monitor how visitors navigate around the websites, and to gather demographic information about our user base as a whole. 
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6.2 Advertising 
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We partner with third party ad networks to display advertising on our website or to manage our advertising on other sites. Our ad network partner uses cookies and web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests.  If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by using these services by sending a message to us. Please note this does not opt you out of being served advertising you will continue to receive generic ads. 
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7. Your Privacy Rights and Choices
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7.1 Personal Data Requests
 
Depending on your location and applicable laws, you may have the following data protection rights:
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Access, Correction or Deletion. You can request access, correction, updates or deletion of your Personal Data.
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Objection or Restriction. You can object to our processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data.
Withdraw Consent. If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
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To exercise any of these rights, you may write to us by mail.
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Please note that to protect Personal Data, we may verify your identity by a method appropriate to the type of request you are making. Depending on where you reside, you may be entitled to empower an “authorized agent” to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.
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We will respond to your request to change, correct, or delete your data within a reasonable timeframe and notify you of the action we have taken. In some instances, your rights may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. Depending on your location, and applicable laws, you may have the right to complain to a data protection authority about our collection and use of your Personal Data. Contact details for data protection authorities in the EEA are available on the European Data Protection Board member page here.
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If you are a User, prospect, or otherwise interact with a Dharma Initiative AG (Dharma) User that uses our   Service and would like to access, correct, amend or delete your data controlled by the User, please contact the relevant User directly. Dharma Initiative AG (Dharma)acts as a processor for our Users in most cases and will work with our Users to fulfill these requests when applicable.
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7.2 Anti-Spam Policy 
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Our Acceptable Use Policy applies to us and to our Users and, among other things, prohibits use of the   Service to send unsolicited commercial email in violation of applicable laws, and requires the inclusion in every email sent using the   Service of an "opt-out" mechanism and other required information. We require all of our Users to agree to adhere to the Acceptable Use Policy at all times, and any violations of the Acceptable Use Policy by a User can result in immediate suspension or termination of the Services.
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8. California Privacy Rights
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8.1 Applicability 
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This section applies only to California consumers. For purposes of this section "Personal Information" has the meaning given in the California Consumer Privacy Act (“CCPA”). It describes how we collect, use, and share California consumers' Personal Information in our role as a business, and the rights applicable to such residents.
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If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will arrange to supply you with the information you need in an alternative format that you can access.
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8.2 How We Collect, Use, and Disclose your Personal Information 
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We have collected the following statutory categories of Personal Information in the past twelve (12) months:
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Identifiers, such as name, e-mail address, mailing address, and phone number. We collect this information directly from you or from third party sources.Commercial information, such as   records. We collect this information directly from you.Internet or network information, such as browsing and search history. We collect this information directly from your device.Geolocation data, such as IP address. We collect this information from your device.Financial information, such as Payment Information or financial account numbers in the process of providing you with a  . We collect this information from you.Professional data, such as your job title and company.Other Personal Data, in instances when you interact with us online, by phone or mail in the context of receiving help through our help desks or other support channels; participation in User surveys or contests; or in providing the Service.Inferences drawn from any of the above categories, alone or in combination. The business and commercial purposes for which we collect this information are described in this Privacy Policy. The categories of third parties to whom we "disclose" this information for a business purpose are described in the “How We Share Personal Data” section of this Privacy Policy. The period of time for which we retain this information is described in the “How We Store and Secure Personal Data” section of this Privacy Policy.
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In the preceding 12 months, we have “sold” or “shared” (as defined under the CCPA) certain information, including identifiers, to our advertising partners. We have also “sold” or “shared” certain information, including identifiers, approximate location data, and professional data to our Users. 
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8.3 Your California Rights 
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You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.

These rights include:
The right of access means that you have the right to request that we disclose what Personal Data we have collected and maintained about you in the past 12 months.The right of deletion means that you have the right to request that we delete Personal Data collected or maintained by us, subject to certain exceptions.The right of correction means that you have the right to request that we correct any inaccurate Personal Data that we maintain about you.The right to request information concerning the categories of Personal Data (if any) that we disclose to third parties or affiliates for their direct marketing purposes.The right to limit the use of sensitive personal information means that you have the right to direct businesses to only use your sensitive personal information for limited purposes. We only collect sensitive personal information (such as your payment information), as defined by applicable laws for the purposes allowed by law or with your consent. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.The right to appeal means that you can appeal any decision by us to deny your privacy rights under applicable laws.The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights. We respond to all appeal requests as soon as we reasonably can, and no later than legally required.
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8.4 How to Exercise your California Rights 
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You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your Personal Data, we will verify your identity by a method appropriate to the type of request you are making. Depending on your request, we will ask for information such as your name and your email address. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent's identity to protect your Personal Data. We may deny a request from an agent that does not submit proof that they have been authorized to act on your behalf. 
We will respond within the time frame permitted by applicable law. Please note that we may charge a reasonable fee for multiple requests in the same 12-month period, as permitted by law.
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Please use the contact details below, or see the "Your Privacy Rights and Choices" section above for more details.
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8.5 Right to Opt-Out of "Sale" or "Sharing" 
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Dharma Initiative AG (Dharma) collects data from publicly available sources or other third-party sources and discloses that information to our Users who purchase our enrichment products. This may be considered a “sale” or “sharing” under certain state privacy laws, such as the CCPA. Please see the "Information We Collect and Process in connection with our enrichment products” section for more information.
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We may also "share" your Personal Data, as defined under the CCPA, with third party advertising partners to deliver personalized ads on Dharma's behalf on other companies' sites or mobile apps. 
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If you’d like your information to be removed from our commercial dataset, or would like to opt out from the "sharing" of your Personal Data for our advertising and marketing activities, please fill out this form.
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We do not knowingly “sell” or “share” Personal Data of children under 16 years of age.
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9. Other Important Privacy Information 
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9.1 Information About Children 
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The websites, product and services are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect Personal Data about children under 16. If you believe that we have collected Personal Data about a child under 16, please contact us here, so that we may delete the information.
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9.2 Third Party Dispute Resolution 
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If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us for more details.
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10. Contact Us
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If you have any questions about this Privacy Policy or our privacy practices, or if you have a disability and need to access this notice in a different format at hello@dharma.sh.