BzzAgent Privacy Policy

Updated and Effective as of: FEBRUARY 14, 2023

Introduction

This Privacy Policy describes our practices regarding the collection, use, sharing, and other processing of information collected through our web sites, applications, and other online features or services owned or operated by PowerReviews, Inc. d/b/a BzzAgent (“BzzAgent”), that post or include a link to this Privacy Policy (collectively, the “Platform”). This Privacy Policy also describes our information and privacy practices with regard to the Platform and information we collect offline, which we may combine with online data. The Platform is meant only for residents of the United States, United Kingdom, or Canada (excluding Quebec). If you do not reside in those territories, please do not attempt to access the Platform.

We encourage you to read this Privacy Policy carefully before accessing or providing any personal information to the Platform. Please also review our Terms of Use, which govern your use of the Platform. Please note that certain features or services discussed in this Privacy Policy may not be offered on the Platform at any particular time. By visiting our Platform, you are accepting the practices described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy and the applicable Terms of Use, do not access or use the services or provide personal information to us.

If you are a client or potential client of PowerReviews, please review its Terms and Privacy Policy by clicking the links.

Overview

1. BZZAGENT OVERVIEW

BzzAgent provides the Platform to connect its community of individuals (“Members”) with companies, including brands and product makers, with whom BzzAgent partners (“Brands”). By signing up and creating a profile, BzzAgent Members are eligible to participate in campaigns where they receive samples to try products and share their authentic and honest opinions (“Campaigns”). Campaigns may involve creating and sharing a photo or post with friends and followers via social media networking platforms including Facebook, Instagram, YouTube, TikTok, and blogs, or submitting product reviews that may be shared to brand and e-commerce sites. Through social posts and reviews, BzzAgent Members help drive brand awareness and inform purchase decisions.

2. INFORMATION WE COLLECT

We collect information about users of the Platform directly, automatically when you visit the Platform, and sometimes from third parties. Some of this information may be considered “personal information” or “personal data”, and some of which may be considered “sensitive”, under various applicable laws. We consider information that identifies you as a specific, identified individual (such as a user’s name, email address, or phone number) to be personal information. We will also treat additional information, including IP addresses and cookie identifiers, as “personal information” or “personal data” where required by applicable law. Note that we may de-identify or pseudonymize personal information so that it is non-personal, such as aggregating or converting it to a code, sometimes using a function commonly known as “hash”. We maintain and use de-identified data without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification processes satisfy legal requirements. We will treat de-identified or pseudonymized information as non-personal to the fullest extent allowed by applicable law. If we combine non-personal information with personal information, then we will treat the combined information as personal information under this Privacy Policy.

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2.1 Information that you Provide Directly

We may ask you to provide information directly, such as in connection with your account, your use of the Platform and when you otherwise interact with or contact us, including contact information (such as, name, e-mail address, and phone number). We may also collect other types of information, such as demographic information (for example, ZIP code, date of birth, gender identity, and ethnicity), information about your interests and preferences (e.g. personality, values, attitudes, interests, and health and lifestyle, including diet and exercise preferences), and information you choose to provide in connection with a feature or promotion we offer, such as an online forum or a sweepstakes or survey, or other forms or features on the Platform. When you create an account, it may include username and password.

We may also ask you to provide additional information to help us build out your profile and better match you for Campaigns that you may choose to voluntarily provide, which may include, but is not limited to, information about your annual household income, residential status, family composition, whether you have any pets, education level, industry and status of employment, relationship status, psychographic details (e.g. whether you agree or disagree with certain value statements or behaviors (e.g. a healthy diet is part of my life), and other demographic and interest-based information. Occasionally, we will offer campaigns that relate to potentially sensitive topics such as health, wellness or sexual preference. As with all of our surveys, we are only asking the questions in order to best match you with the right campaigns and your participation in any campaign is completely voluntary.

If you are invited to participate in a Campaign, you will be asked to apply to the Campaign and may be asked to provide additional information.

We also collect and keep track of data related to your participation in Campaigns, including the number of campaigns you have been invited to, applied to, or selected for, the number of reviews you have submitted, and other information about your Campaign history. We also collect information about the content of reviews you have submitted in connection with Campaigns, including your nickname, content of the review, star rating, and the date and time you submitted a review.

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2.2 Information Provided to Us by Brands

When you participate on the Platform as a BzzAgent Member or otherwise interact with Brands through the Platform, we may process information about you on behalf of the Brands, for example, when you leave a review with the Brand.

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2.3 Information We Collect Automatically

We and our third-party business partners (including any third-party service providers or third-party content, advertising, and analytics providers) may use a variety of technologies, including cookies and web beacons, that automatically or passively collect information whenever you access, use, or otherwise interact with the Platform (“Usage Information”). Usage Information includes the hardware model, browser, and operating system you are using, the URL or advertisement that referred you to our Platform, any search terms you entered into a search engine that led you to our Platform, the areas within our Platform that you visited, and the time of day you visited our Platform, your time zone, location information, and mobile network (if applicable), among other information. We may also automatically collect your IP address or other unique identifiers for any computer, mobile phone, or other device used to access our Platform.

Cookies: We may use cookies to identify users and to customize experiences on the Platform. We use cookies to help us understand how visitors use (and to help us to improve) the Platform. To manage your cookies preferences, visit our Cookie Preference Center by clicking the yellow cookie icon at the bottom of the screen.

Web Beacons: Additionally, we may use, and may allow third parties to use, web beacons on the Platform to monitor the effectiveness of advertising or for other legitimate purposes. Web beacons, also known as “Web bugs” “1x1 GIFs” or “clear GIFs” are small, graphic images on web pages or web-based documents or in email messages that allow us or third parties to monitor who is visiting the Platform. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons collect the IP address of the computer that the web beacon is sent to, the URL of the page the web beacon comes from and the time it was viewed. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Platform, to monitor how users navigate the Platform, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed. Web beacons may be linked to your personal information.

Embedded Scripts: An embedded script is programming code that is designed to collect information about your interactions with the Platform, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third-party service provider, is active only while you are connected to the Platform, and is deactivated or deleted thereafter.

In addition, we may use a variety of other technologies that collect Usage Information and similar information for security and fraud detection purposes and to enforce our intellectual property rights.

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2.4 Information Third Parties Provide About You

We may receive information about you from third parties in addition to Brands, such as data aggregators and other business partners. We may also supplement the information we collect with outside records from third parties, such as public databases, publicly available social media pages, and third parties who enhance the information we have about you, in order to provide you with information, services or products you have requested, to tailor content, to offer you opportunities to purchase products or services that we believe may be of interest to you, and for other purposes. The information collected and stored by third parties is subject solely to the third party’s privacy practices.

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2.5 User Content Submissions

The Platform may permit you to submit or post certain of your own content (“User Content”) through interactive or other features, such as surveys, reviews, discussion forums, blog comments, gallery posts, or promotional activities (“Submission Features”). Your submission of User Content is subject to the Terms of Use for the Platform. If you register as a BzzAgent and participate in a sampling campaign, the content you create and publish as part of that campaign is governed by the Influencer Agreement you agreed to at the time you signed up to create a BzzAgent account.

Note that anything you choose to submit or publicly post to the Platform may be public. Others may access it, use it, and share it. We are not responsible for how others use the User Content you submit or post. Personal information, such as your name, user name (from the Platform or your social media account), or where you reside, may be publicly displayed with your User Content. In addition, in connection with certain activities, your personal information may be disclosed publicly, for example, being identified as a winner of a sweepstakes or being awarded a prize.

Some features that allow users to submit User Content, such as reviews, are operated by third parties and any content submitted through such feature may be provided directly to the third party and subject to that party’s own privacy policy, as disclosed at the time of submission.

UserContent

2.6 Refer-A-Friend

We may make available a “send-to-a-friend,” “refer a friend,” “wishlist” or similar function that permits you to send Platform content directly to a third party through the Platform. If you send a friend a communication using such functionality, the information you provide about your friend (e.g., name and e-mail address) is used to facilitate the communication and is not used for any other marketing purpose unless we obtain consent from that person. If you disclose any personal information relating to other people, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

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2.7 Social Media Features

The Platform may permit you to interact with a third party platform (such as LinkedIn, Facebook, or Vimeo) and the Platform, for example “liking” or “sharing” content from the Platform, posting your social media posts to the Platform, including a hashtag associated with us in your social media post, or creating an account or registering with the Platform using existing login information from a third-party platform (“Social Media Features”). Also, both we and the third party may have access to certain information about you and your use of the Platform and the third party service. These third party companies may collect information about your visit to our Platform through the Social Media Features we have integrated into the Platform. Note that through the Social Media Features, these third party companies may be able to collect certain information about your visits to the Platform regardless of whether or not you affirmatively interact with the Social Media Features and whether or not you are logged into (or have) an account with the third party platform.

If you use Social Media Features, your interaction and personal information may be publicly disclosed on the Platform and on the third party platform. If others give us access to their profile, page, or other content on a third-party platform, we may also receive information about you if it is accessible through that content. Your use of Social Media Features is subject to our Terms of Use which give us the right to use your interaction, online or offline, in connection with our advertising, publicity, and promotional activities.

The information we collect in connection with Social Media Features is subject to this Privacy Policy; the information the third party platform collects is subject to the third party’s privacy practices (including whether the third party shares information with us, the types of information shared, and your choices about what is visible to others on the third-party platform).

SocialMedia

3. HOW WE USE THE INFORMATION WE COLLECT

We may use the information we collect to:

Enable you to use the Platform and other products or services we offer, including maintaining your account information, managing Campaigns and fulfilling samples, and verifying information you provide to us, including that your email address is active and valid;
Manage our relationship with you and match you with potential Campaigns;
Send you products or samples as part of a Campaign;
Tailor the content and advertising we display to you or others, on the Platform or elsewhere, including content in emails we may send to you;
Communicate with you, including through social media messages such as Facebook Messenger or Instagram messages, including to respond to any questions, problems or complaints, or request feedback, and to send you information about us and the Platform, Campaign opportunities, specific Campaign directives, products, features, and activities, including to send you marketing communications if you have provided us your email address, as permitted by applicable law
Contact you for administrative purposes, such as changes to our Privacy Policy, Terms of Use, or other policies, or to provide customer service;
For internal business purposes, such as to organize the Platform to better serve you, including analyzing the effectiveness of Campaigns, customize or develop and improve our products and services, to conduct market research and to analyze trends and statistics, and to comply with legal requirements and our business policies;
Operate and protect the Platform from errors and misuse of the Platform, to detect, Investigate, and help prevent potential unlawful or fraudulent activity, or that violates our Terms of Use, to detect and troubleshoot problems, resolve disputes, and enforce applicable agreements and policies; and
As otherwise disclosed in this Privacy Policy, for other reasons that we disclose when you provide your information, or otherwise with your consent

Uses

4. SHARING INFORMATION

We may share non-personal information that we collect, such as certain Usage Information, aggregate user statistics, and hashed or otherwise de-identified or pseudonymized information (including email addresses), and/or our analyses derived from such information, with third parties in our discretion as permitted by law, including for targeted advertising purposes. We do not share personal information with third parties except as disclosed when you provide it, with your consent, and as described in this Privacy Policy, including:

Sharing

4.1 Parent and Affiliates

We may disclose personal information we collect from you to our parent, affiliates or subsidiaries for business and operational purposes.

4.2 Information Shared through our Partnerships with Brands

When you participate in the Platform or otherwise interact with Brands through the Platform, we may also share certain information with the Brand in order to help them understand the impact of their Campaigns. For example, we may share certain information with Brands including aggregated statistics and demographic analysis of Campaigns. In some cases, we may provide your mailing address to the Brand associated with your Campaign such that they can fulfill the samples you requested. If you consent, we will also pass along email, city, state and phone number to our client in the event that a member reports an adverse event for pharmacovigilance.

4.3 Service Providers

We may use third party service providers to assist us with the administration of the Platform or to perform other services for us or on our behalf, including transaction processing and sending emails and other communications. We give these third parties access to your personal information (or allow them to collect information from or about you) so that they can provide the services. Our third party service providers may be located in the U.S., Canada or other foreign jurisdictions.

4.4 Third Parties When You Direct Us to Share Information

We may share information when you direct us to do so. For example, you may be presented with an opportunity to receive information and/or marketing offers from one or more third parties. If you agree at that time to have your personal information shared, your personal information will be disclosed to that third party (or parties) and will be subject to their privacy practices. Or, you may engage with Social Media Features or other third party application or feature, through which information about you is shared. Please note that we are not responsible for the privacy practices of third parties. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.

4.5 Business Transfers/Merged or Acquiring Entity

Information about our users and the Platform are a business asset of BzzAgent. Therefore, information about our users, including personal information, may be disclosed without your further consent as part of any corporate restructuring, including a merger or acquisition, creation of a separate business to provide the Platform; debt financing, sale or pledge of company assets, insolvency, bankruptcy or receivership in which personal information would be transferred as one of BzzAgent’s business assets, or other transaction (including, without limitation, during the course of any due diligence process),. By providing your personal information, you agree that we may transfer such information to the new entity.

4.6 Legal and Business Purposes

We may share personal information about you to third parties in order to comply with a legal obligation and when we believe in good faith that the law requires it (e.g., a lawful subpoena, warrant or court order); to respond to lawful requests by public authorities or law enforcement, including to meet national security or law enforcement requirements; to protect the integrity of the Platform and enforce or apply our policies or any other agreement with a user; to initiate, render, bill, and collect for amounts owed to us; to protect our rights or property; to protect our users from fraudulent, abusive, or unlawful use of our Platform; to enforce contest, sweepstakes, promotions, or game rules; if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay; or to otherwise protect the rights, property, safety, or security of BzzAgent, users of the Platform, or others. We may also use Device Identifiers, including IP addresses, to identify users, and may do so in cooperation with copyright owners, Internet service providers, website service providers or law enforcement agencies, in our discretion.

4.7 Sweepstakes, Contests, Promotions

We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern the Promotion, which may contain specific requirements of you (including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, personal information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, as required by law, or as permitted by the Promotion’s terms or official rules (such as on a winners list).

5. THIRD PARTY ADVERTISING AND ANALYTICS AND SIMILAR THIRD PARTIES

We may use third party business partners, such as analytics companies, ad agencies, network advertisers, and others who provide us with information about the Platform, users, and our advertisements, and who deliver ads to you on our behalf on our Platform and elsewhere online. We and our third party business partners collect certain information about your visits to and activity on our Platform and other websites and services, including through the Social Media Features, and may use this information to target advertising to you and others and to assess the effectiveness of our advertising. We may also share (or permit third parties to collect) certain information, such as Usage Information, aggregated or de-identified, pseudonymized or hashed information (including email addresses), with these third parties for similar purposes.

These third parties may set and access their own tracking technologies on your device (including cookies, web beacons or other technology) and may otherwise collect or have access to your personal information over time, including about your visits to our Platform as well as other websites and online services, some of which may be personal information or personal data under various state laws. Companies that we share information with, including ad agencies and networks, may use the information, often in combination with their existing information, in order to present more relevant advertisements that may be of interest to you, and to help us and third parties to do the same.

Your Advertising Choices: Some of these third parties may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. Both NAI and DAA provide information regarding procedures for opting out of targeted online advertising from participating companies.

For information from NAI about opting out, click here.
For information from DAA about opting out click here.
To learn more about interest-based advertisements from participating third parties in Canada, please visit the Canadian DAA online choice page.
The European Digital Advertising Alliance (“EDAA”) has also developed a guide to online behavioral advertising and has developed an opt-out page for participating EDAA member companies available.

Note that these are cookie-based opt-outs. If you disable your cookies or upgrade your browser after opting out, or if you use different computers or browsers, you will need to indicate your opt-out choices across those other computers and browsers.

We use Google Analytics, a web analytics service provided by Google, Inc. on the Platform. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Platform, compile reports on the activity on the Platform, and provide other services related to our activity on our Platform and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, click here.

ThirdPartyAds

6. YOUR CHOICES AND ACCESS

Access

6.1 Opting Out

Cookies: Cookies are small data files that download onto your computer or other devices when you visit the Platform or otherwise access our online content on certain websites. Cookies may be used for many purposes. We use both session cookies (which are deleted when you close your browser) and persistent cookies (which remain on your computer after the browser has been closed). To learn more, visit http://www.allaboutcookies.org/.
Marketing Communications: If you receive marketing communications from BzzAgent you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in the emails. If you receive marketing communications from a BzzAgent client and would no longer like to be contacted by them, please contact that client directly.
Do-Not-Track: Please note that your browser settings may allow you to automatically transmit a "Do Not Track" signal to websites and online services that you visit. When you choose to turn on the “Do Not Track” setting in your browser, your browser will send a signal to websites, analytics providers, advertisement networks, plug-in providers, and other web service providers you encounter while browsing to stop tracking your activity. To find out more about and set up "Do Not Track," please visit www.allaboutdnt.com.
Global Privacy Control: Global Privacy Control (“GPC”) is a technical specification in your browser settings that you can use to automatically inform websites of your privacy preferences with regard to third-party online tracking. To find out more about and set up GPC, please visit https://globalprivacycontrol.org/#about.

6.2 Access and Correction

If you would like to access, correct, amend or delete personal information collected by BzzAgent through the Platform, you may do so through your account settings, if applicable, or contact us through one of the below methods.

If for any reason, you no longer wish to be a member of BzzAgent and wish to close your account with us, then please let us know by emailing us at BzzAgentPrivacy@powerreviews.com You may also have the option to pause or close your account through your account settings.

You have the right to opt-out of marketing communications we send you at any time. You can exercise by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing, then please email us at BzzAgentPrivacy@powerreviews.com or contact us using the contact details provided in the Questions and Contact Information section [Link to section]. We may still contact you even if you have opted out of receiving marketing communications for transactional purposes, such as customer service, product information, or service or reminder notices.

Attn: Privacy

PowerReviews, Inc.

1 N. Dearborn, Suite 810

Chicago, IL 60602

Phone – United States: 844-231-7540

Email: BzzAgentPrivacy@powerreviews.com

6.3 State-Specific Privacy Rights

If you are a California resident, please see our Notice to California Residents for additional information on how to exercise your privacy rights. If you are a Nevada resident, please see our Notice to Nevada Residents for more information on additional rights you may have. If you are a Virginia resident, please see our Notice to Virginia Residents for additional information about how to exercise your privacy rights.

7. THIRD-PARTY LINKS AND CONTENT ON OUR PLATFORM

The Platform may contain links to other websites that BzzAgent does not control, and other content hosted and served by third parties. The third parties whose content appears on the Platform may collect information about you through the use of cookies and web beacons, may independently collect or solicit personal information, and may have the ability to track your use of their sites and services.

This Privacy Policy does not apply to non-BzzAgent-operated websites and mobile applications that may be linked to or from the Platform. Please review the privacy policies on those websites and applications directly to understand their privacy practices. BzzAgent is not responsible for the privacy practices of any third party.

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8. BZZAGENT CONTENT ON THIRD-PARTY SITES

Our content may be included on third-parties’ webpages and websites, including third-party sites on which you submit a review using a form powered by BzzAgent. While we do not control those third-party web pages and websites, we may collect Usage Information through BzzAgent content appearing on third-party sites.

This Privacy Policy does not apply to non-BzzAgent-operated websites and mobile applications that may link to the Platform. Please review the privacy policies on those websites and applications directly to understand their privacy practices. BzzAgent is not responsible for the privacy practices of any third party. If you have questions regarding the data practices of one of our clients, please contact them directly.

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9. CONSENT TO CROSS-BORDER TRANSFERS OF DATA

BzzAgent is a United States company. If you are a user of the Platform outside of the United States, by using the Platform and/or providing us with information, you acknowledge and agree that your personal information may be processed for the purposes identified in the Privacy Policy. In addition, we and our Canadian, UK, US and other foreign service providers, may process your personal information in the country in which it was collected and in other countries, including the United States. By using the Platform outside of the United States, you specifically consent to our collection, processing, storage, or transfer your personal information in the United States and other jurisdictions, including to countries where data protection standards may differ from those in the country where you reside. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries request to access your personal information in accordance with the laws of that jurisdiction. However, our transfer, storage, and processing of your personal data will at all times be in accordance with this Privacy Policy.

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10. GENERAL AUDIENCE SITE

The Platform is intended for users who are at least 16 years of age. We do not knowingly collect personal information from children younger than the age of 16. To use the Platform and participate in certain features and services, users may be required to be at least 18 years of age and the age of majority in their jurisdiction.

General Audience

11. SECURITY

We use commercially reasonable security measures and technologies in an effort to protect and secure the personal information we collect and store about users, including to prevent loss, misuse, and alteration of the information under our control. However, please remember that no data transmission or data storage to guaranteed to be 100% secure. As such, we cannot guarantee protection of all information against interception, misappropriation, misuse, or alteration, or that your information may not be disclosed or accessed by accidental circumstances or by the unauthorized acts of others. Furthermore, we have no control over the security of other sites you might visit, interact with or do business with. Thus, while we strive to protect your personal information, BzzAgent cannot ensure or warrant the security of any information you transmit to us. You use our Platform and provide us with your information at your own risk.

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12. RETENTION OF PERSONAL INFORMATION

We retain personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

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13. CHANGES TO THIS POLICY

To the extent allowed by applicable law, we may make changes to this Privacy Policy from time to time in our discretion. We will notify you of such changes by posting the new policy on the Platform and indicating at the top of the Privacy Policy the date it was last updated. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any changes will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified, and your continued use of the Platform after the effective date of the revised Privacy Policy (or such other act as specified in the revised Privacy Policy) will constitute your consent to those changes to the fullest extent allowed by applicable law.

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14. QUESTIONS AND CONTACT INFORMATION

If you have any questions, inquiries or complaints about this Policy, or the practices of or your dealings with the Platform, please contact us at the following address, phone, or email:

PowerReviews, Inc.

1 N. Dearborn, Suite 810

Chicago, IL 60602

Phone – United States: 844-447-6112, Ext.6112

Email: BzzAgentPrivacy@powerreviews.com

Questions

15. Notice to Nevada Residents

BzzAgent does not currently sell your covered information as those terms are defined under applicable Nevada law. However, you may still submit an opt-out request and we will honor that request as required by Nevada law if BzzAgent were to ever engage in such a sale in the future. If you are a Nevada resident and would like to opt-out of future sales of your covered information, please submit your request to BzzAgentPrivacy@powerreviews.com. You may also be required to take reasonable steps as we determine from time to time in order to verify your identity and/or the authenticity of the request. BzzAgent will respond to your request within sixty (60) days either confirming that your request has been processed or indicating that we need an additional thirty (30) days to complete the request.

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16. CALIFORNIA PRIVACY RIGHTS

California

16.1 Notice to California Residents

This California Privacy Notice is effective as of February 14, 2023

This notice supplements the information contained in our Privacy Policy and applies only to California residents. This California Privacy Notice sets forth the disclosures and rights for California Consumers regarding their Personal Information, as required by the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act of 2020 (“CPRA”), and any implementing regulations adopted thereunder. Terms (including defined capitalized terms) used in this California Privacy Notice have the same meanings given in the CCPA and CPRA and the associated regulations, unless otherwise defined.

EXERCISING YOUR CALIFORNIA RIGHTS

California Consumers have the right to request: (1) that we disclose to you what Personal Information we collect, use, disclose, and sell, including the right to request that we provide to you the categories and specific pieces of Personal Information we have collected about you (“Right to Know”); (2) that we delete the Personal Information we collect about you (“Right to Delete”); (3) that we correct inaccurate Personal Information we hold about you (“Right to Correct”), (4) to opt-out from the sharing of your Personal Information and Sensitive Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising) (“Right to Opt-Out of Sharing”), (5) to opt-out from the sale of their Personal Information and Sensitive Personal Information (“Right to Opt-Out of Sale”), and (6) that we limit the use or disclosure of your Sensitive Personal Information to purposes set forth in the statute, including that use which is necessary and anticipated to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services (“Right to Limit The Use and Disclosure of Sensitive Personal Information”), all subject to the meanings nd exceptions set forth in the CCPA and CPRA. More information on each of these rights is below.

In your request, you must provide enough information to allow us to verify you are the person about whom we collected personal information, or their authorized representative. You must also describe your request with enough detail so that we can understand, evaluate, and respond to it. We can’t respond to your request if we can’t verify your identity. Making such a request does not require you to create an account with us, and we will only use the information you provide in a request to verify your identity.

Verifying Your Requests

We will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making.

When you exercise your Right to Know, Right to Delete, and/or Right to Correct, please provide us with information to verify your identity and fulfill your request, including your full name, the email address you have used to interact with BzzAgent, and mailing address or phone number (if you have provided it). If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request.

Agents

If you are an authorized representative submitting a request on a user’s behalf, please complete the applicable request per the instructions below. We will follow up to request a signed, written permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request and needs to be clear about the permission granted. Alternatively, you may submit a copy of a power of attorney under Probate Code sections 4000-4465. In either case, please also indicate in your email the nature of your request. The consumer’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may also ask the consumer to directly confirm with us that they provided you permission to submit a request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the consumer’s behalf, we may deny the request.

Right to Know

California Consumers have the right to know what information we have collected about you (the categories and the specific pieces of information).

If you are a California Consumer and would like to exercise your Right to Know, you may access personal information collected by BzzAgent through the Platform in your account settings, if applicable, or you may submit your request at BzzAgentPrivacy@powerreviews.com.

In order to have us provide specific pieces of information, we may require a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.

Right to Delete

California Consumers have the right to request that we delete the information we have collected from you. If you are a California Consumer and would like to exercise your Right to Delete, you may delete personal information collected by BzzAgent through the Platform in your account settings, if applicable or you may submit your request at BzzAgentPrivacy@powerreviews.com.

Please note that as part of the verification process, once you submit a request to delete, we may follow up and require you to confirm that you want your information deleted.

Right to Correct Inaccurate Information

California Consumers have the right to request that we correct inaccurate information we hold about you. If you are a California Consumer and would like to exercise your Right to Correct, you may correct information collected by BzzAgent through the Platform in your account settings, if applicable, or you may submit your request at BzzAgentPrivacy@powerreviews.com.

Right to Opt-Out of Sale of Personal Information or Sharing for Cross-Contextual Behavioral Advertising

California Conusmers have the right to opt-out of the sale of your Personal Information or Sensitive Personal Information (BzzAgent does not sell Personal Information or Sensitive Personal Information for monetary compensation) and to opt-out of the sharing of your Personal Information or Sensitive Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising). BzzAgent does not use your contact infromation in a manner that would be considered a "sale" or a "share", but BzzAgent engages in online advertising practices (and certain analytics or similar activities), which may be considered a "sale" or a "share" for cross-context behavioral advertising as defined in the CCPA and CPRA. To exercise your right to opt out of certain tracking cookies set by third parties that may be considered "sales" or shaing" under the CCPA and CPRA, click on the yellow cookie icon at the bottom of the screen.

In addition, the Digital Advertising Alliance also offers tools for California consumers to send requests under the CCPA and CPRA to opt out of the sale of person information by some or all of the participating companies at: https://www.privacyrights.info/.

Right to Limit The Use and Disclosure of Sensitive Personal Information

Under the CPRA Regulations, a business must only provide the Right to Limit The Use and Disclosure of Sensitive Personal Information when Sensitive Personal Information is collected or processed for the purpose of inferring characteristics about a consumer or does not fall under certain statutory exceptions, pursuant to CPRA §1798.121. BzzAgent’s use and disclosure of Sensitive Personal Information is not used for such purpose and/or falls within the statutory exceptions, and we therefore do not offer this right at this time.

Data Retention

We will retain all categories of personal information described in this California Privacy Notice for as long as it is reasonably necessary for the purposes set out in this California Privacy Notice, considering the time period reasonably necessary to: provide the Services to you; exercise the choices and rights you have requested; comply with our contractual obligations; enforce our terms for use of the Services; and, comply with legal and regulatory requirements. Except as noted differently on specific pages or apps, we retain your personal information while you have an account with us, or while you are using our Services or continuing to visit us.

Users Younger than 16

BzzAgent does not knowingly Sell or Share Personal Information of users younger than under 16 years of age.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

California consumers have the right to not receive discriminatory treatment for exercising CCPA and CPRA rights. We will not discriminate against you for exercising your CCPA and CPRA rights.

Notice of Finance Incentive

Under California regulation, certain aspects of our loyalty and similar programs, which provide benefits to consumers, may be considered a financial incentive program. We collect personal information from you in connection with our loyalty program, e.g. contact information (name, email address, residential address) and commercial information (like purchase history) for a number of reasons, including to administer the program, contact you with regard to your account (if any), to provide the benefits to you, to better serve you, and to fulfill your requests associated with the program.

To opt into our loyalty or similar programs, as set forth herein you will need to provide certain information, register for an account and agree to the applicable program terms, or otherwise follow the instructions associated with the loyalty or other similar programs. Participation in our loyalty or other similar programs is voluntary and you can withdraw at any time. To withdraw from the BzzAgent program, please follow the same process for deleting your account.

To the extent that we provide programs that may be considered a financial incentive because the program is directly or reasonably related to the collection, deletion or retention of consumer personal information, the value is reasonably related to the overall value we receive from the personal information participants provide specific to the program minus the costs and expenses we incur in providing the program.

PERSONAL INFORMATION WE COLLECT

The Personal Information we collect about you will depend upon how you use our Services or otherwise interact with us. Accordingly, we may not collect all of the below information about you.

In addition to the below, we may collect and/or use additional types of information and will do so after providing notice to you and obtaining your consent to the extent such notice and consent is required by the CCPA and CPRA.

QUESTIONS AND CONTACT INFORMATION

If you have questions about any of these rights, please email us at bzzagentprivacy@powerreviews.com.

16.2 California “Shine the Light” Law

California’s “Shine the Light” law (Civil Code Section 1798.83, also known as S.B. 27) allows California residents to request from companies conducting business in California certain information relating to third parties to which the company has disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes.  Alternatively, the law provides that a company may comply, as BzzAgent does, by disclosing in its privacy policy that it provides consumers choice (opt in or opt out) regarding sharing personal information with third parties for those third parties’ direct marking purposes, and information on how to exercise that choice.  As stated in this Privacy Policy, BzzAgent provides you choice prior to sharing your personal information with third parties for their direct marketing purposes.  If you do not opt-in or if you opt-out at the time we offer that choice, we do not share your information with that identified third party for its direct marketing purposes.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please write to us at 1 N. Dearborn, Suite 810, Chicago, IL 60602. You must put the statement “Your California Privacy Rights” in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and zip code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

17. Notice to Virginia Residents

We set forth above in our Privacy Policy the categories of personal data we process, the purpose for processing personal data, the categories of personal data shared, and the categories of third parties with whom personal data is shared.

If you are a Virginia Consumer and would like to exercise your rights (including correcting, amending or deleting personal information), pursuant to the Virginia Consumer Data Protection Act (VCDPA), and any implementing regulations adopted thereunder you may do so through your account settings, if applicable, or contacting us at BzzAgentPrivacy@powerreviews.com.

Virginia Consumers have the following rights, all subject to the meanings and exceptions set forth in the VCDPA:

To confirm whether we are processing your Personal Data and request to access such data ("Right to Access").
That we correct inaccurate Personal Data we hold about you (“Right to Correct”).
That we delete the Personal Data provided by you or obtained about you ("Right to Delete").
To obtain a copy of the Personal Data previously provided by you to us and, to the extent feasible, in a readily usable format to allow data portability (“Right to Obtain”).
To opt-out out of:
1. the processing of your Personal Data for the purposes of targeted advertising (“Right to Opt-Out of Targeted Advertising”). *BzzAgent engages in online advertising practices (and certain analytics or similar activities) that may be considered “targeted advertising” under the VCDPA. To disable sharing through cookies set by 3rd parties that may be considered targeted advertising under the VCDPA, click the yellow cookie button at the bottom of the screen.
2. the processing of your personal data for the purposes of a sale (“Right to Opt-Out of Sale”). *BzzAgent does not sell Personal Data to third parties for monetary compensation.

VCDPA Appeals

Pursuant to the VCDPA, if, for any reason, you would like to appeal our decision relating to your request, you have the right to submit an appeal and can do so by submitting your notice of appeal to BzzAgentPrivacy@powerreviews.com. Please include your full name, the basis for your appeal, and any additional information to consider.

Virginia

18. Notice to Canadian Residents

Canadian residents may withdraw consent at any time (subject to legal or contractual restrictions and reasonable notice). Subject to certain limits set out in the applicable laws, Canadian residents also have the right to request access to the personal information that BzzAgent collects and to update or correct personal information if it is inaccurate. We may need to verify your identity before implementing your request.

Subject to applicable law, if you are a Canadian resident and would like to submit a request to access your personal information or to withdraw consent to the processing of your personal data, you must submit your request to BzzAgent by sending an email to BzzAgentPrivacy@powerreviews.com. You may also use this contact to submit any requests for information on our privacy practices or to submit a complaint regarding our practices.

Your request or complaint must include your full name, street address, city, province, postal code, and an email address so that we are able to contact you if needed regarding this request.

We cannot properly process requests or complaints that do not come through the designated request mechanism or do not contain sufficient information to allow us to process your request. You may also be required to take reasonable steps as we determine from time to time in order to verify your identity and/or the authenticity of the request. Once your request is processed, absent exemptions, we will provide you with details regarding what personal information we have, how it is used, and with which third parties it is shared.

18. Notice to UK Residents

If you are a resident of the United Kingdom (“UK”), the following information applies.

Purposes of processing and legal basis for processing: We process personal data on the following legal bases: (1) with your consent, (2) as necessary for our legitimate interests in providing the Platform where those interests do not override your fundamental rights and freedoms related to data privacy such as providing the Platform; to prevent fraud; sending you marketing communications; customizing or developing and improving our products and services; conducting market research; sharing with our business partners; business transfers; to ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution; to support internal administration with our affiliated entities; to conduct data analytics analyses to review and better understand trends and statistics; and complying with applicable law, (3) as necessary for the performance of a contract between BzzAgent and you (for example, to send you products or samples as part of a Campaign, and (4) as necessary to comply with legal requirements (for example, to make mandatory disclosures to law enforcement).

Data Subject Rights:

Under the UK General Data Protection Regulation (“UK GDPR”) and Data Protection Act, you have the following rights:

Withdraw consent: If we have collected personal data with your consent, you have the right to withdraw that consent at any time.

Access: You have the right to request access to personal data we collected about you and information about its sources, purposes, and sharing.
Correction: You have the right to request that we correct the personal data we hold about you if it is inaccurate or incomplete.
Erasure: You have the right to request that we erase data we have collected from you. Please note that we may have a reason to deny your deletion request or delete data in a more limited way than you anticipated, e.g., because of a legal obligation to retain it.
Portability: You have the right, in certain circumstances, to request that we provide your personal data to you in a format that can be transferred to another entity.
Restrict Processing: You have the right, in certain circumstances, to request that we limit our processing of your personal data if you are contesting the accuracy of your personal information; asserting that our processing is unlawful; asserting that we need to keep the information for reasons related to the establishment, exercise, or defense of legal claims, or you object to our processing.

Object: You have the right to object to our processing if we are processing your personal data based on legitimate interests, using your personal information for direct marketing (including profiling), or processing your personal data for purposes of scientific or historical research and statistics.

To make any of the above requests, please contact us at BzzAgentPrivacy@powerreviews.com.

Transfers: Personal data we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our subcontractors maintain facilities. We ensure that transfers of personal data to a third country or an international organization are subject to appropriate safeguards such as standard contractual clauses (for example, the UK International Data Transfer Agreement or any approved successor set of clauses).

Third-Party Advertising. As discussed above, we work with certain third-party advertising companies in connection with our online advertising and those companies may set cookies or other tracking technologies in connection with providing advertising related services to us. The EDAA has developed a guide to online behavioral advertising and has developed an opt-out page to manage online behavioral advertising preferences with participating EDAA member companies available for UK residents at https://www.youronlinechoices.com/uk/.

Data Retention. We retain personal information for as long as your account is active or as needed to provide you the Platform. We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, and as permitted by applicable law. To close your account, please see Section 6.2 (Access and Correction).

Right to lodge a complaint. UK residents have the right to lodge a complaint about our data collection and processing actions with the national supervisory authority, the Information Commissioner’s Office (“ICO”) if you believe we have not resolved your concerns. Contact details for UK’s ICO are available here: https://ico.org.uk/global/contact-us/.

Canada