COMMISSIONED PRIVACY NOTICE

  1. Overview

Commissioned, LLC (“Commissioned,” “we,” “us,” and “our”) respects your privacy and is committed to protecting it through compliance with this Privacy Notice (“Privacy Notice”). This Privacy Notice describes the types of Information we may collect from you when you visit the website at www.commissioned.global (“Site”) or use the Commissioned Mobile Application (“Application”) (collectively, the “Platform”), and that you may provide in electronic messages between you and the Platform. It also describes our practices for collecting, using, maintaining, protecting, and disclosing that Information.

Please read this Privacy Notice carefully to understand our policies and practices regarding your Information and how we will handle it. If you do not agree with our policies and practices, do not use the Platform. By accessing or using the Platform, you agree to this Privacy Notice.

Commissioned may change this Privacy Notice at any time, at its discretion. Your continued use of the Platform after we make changes is deemed to be acceptance of those changes, so please check the Privacy Notice periodically for updates.

This Privacy Notice is subject to and governed by the Commissioned Website Terms of Use (“Terms of Use”) available here.

  1. The Types of Information that Commissioned Collects About You and How Commissioned Collects Information About You

Commissioned may collect two types of information from you when you visit the Platform: Personal Information and Non-Personal Information (collectively “Information”).

  • “Personal Information” refers to data by which you may be personally identified, such as name, postal address, e-mail address, and telephone number.
  • “Non-Personal Information” means data that is about you, but does not identify you specifically. If you do nothing during your visit to the Platform but browse, read pages, or view content, we will gather and store Information about your visit that does not identify you personally.

As a visitor to the Platform, you can engage in many activities without providing any Personal Information. For some optional activities, we may ask you to provide certain Information about yourself by filling out and submitting a form. Depending upon the activity, some of the Information we ask for may be mandatory and some may be voluntary. If you choose not to provide the mandatory Information, you will not be able to engage in some activities. Similarly, if you wish to delete your Information that is mandatory, you will no longer be able to engage in some activities.

When you use the Platform along with its Products and Services, the Platform may also collect certain Information about your computer to facilitate and evaluate your use of the Platform and the Products and Services. For example, the Platform may log environmental variables, such as browser type, operating system, CPU speed, referring or exit web pages, and the Internet Protocol (IP) address of your computer. The Platform also uses such information to measure traffic patterns on the Platform and usage of the Commissioned Services. Commissioned does not match such Information with any other Information held by Commissioned unless we have your consent.

Some users may have the ability to create an anonymous user account. For those accounts, a username and password and responses to challenge questions that are not personally identifying are required to access the Platform. Commissioned will not collect any Personal Information from users with anonymous accounts.

Though Commissioned is taking reasonable steps to ensure the anonymity of its users who create anonymous accounts, Commissioned cannot ensure the security and privacy of these individuals. Unfortunately, the transmission of Information via the Internet and mobile platforms is not completely secure. Due to the nature of the Internet, Commissioned cannot guarantee that Information collected, transmitted or stored will be absolutely safe from intrusion and identification. We are not responsible for circumvention of any privacy settings or security measures we provide. We recommend that, if you have an anonymous user account, you share no Personal Information over the platform. If you share your Personal Information such as by identifying yourself, providing your email address or participating in a videoconference, then you will no longer be anonymous.

If a user chooses to create an anonymous user account, not all functions of the Platform may be available.

Cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the Platform. Most web browsers allow some control of most cookies through the browser settings. When someone like you visits the Platform, standard Internet log information and details of visitor behavior patterns are collected through cookies. This is done to learn data such as the number of visitors to the various parts of the Platform. This Information is collected in a manner that does not identify anyone personally. We do not use this Information to determine the identities of those visiting the Platform and who take no further actions.

  1. How Commissioned Uses Information It Collects About You and the Purpose of the Collection and Use

Commissioned collects your Information in order to record, support and facilitate your participation on the Platform from which this policy is linked. If you subscribe to or register on the Platform, for example, the Information is used to provide access to the website and other benefits that may be made available to registered users. Your Personal Information is also used to track your website preferences and keep you informed within the community unless you have opted not to receive such communications or such communications are prohibited by law. Commissioned may collect Information about the use of the Services and the Platform, such as the number of downloads, types of Services used, how many users we receive daily, and the IP/Internet address of your computer. This Information is collected in aggregate form, without identifying any user individually. Commissioned may use this aggregate, non-identifying statistical data for improving the Platform and Services, providing more relevant experiences to our clients and for statistical analysis. Commissioned will retain your Information as long as Commissioned believes it is appropriate for the purposes of this Privacy Notice.

  1. How Commissioned Protects Your Information

We have implemented measures designed to protect your Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the internet is not completely secure. Although we are working to protect your Information, we cannot guarantee the security of your Information either in transmission or when stored. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

By using the Platform, you agree that Personal Information collected through the Platform or in connection with the services provided may be transferred across national boundaries and stored and processed in any of the countries around the world in which Commissioned maintains offices, including the United States. You also acknowledge that in certain countries or with respect to certain activities, the collection, transfer, storage, and processing of your Information may be undertaken by third-parties. Such third-parties are bound by contract with Commissioned not to use your Personal Information for their own purposes. One instance where this could occur is in conjunction with framed pages in which the URL for the pages is not visible, and the pages are hosted for Commissioned by such third parties. For example, on the sign-up pages for some newsletters, the pages may be hosted by a third-party vendor, but appear to be pages operated by Commissioned and are governed by the Commissioned Privacy Policy.

  1. When Commissioned Shares Your Information

We may use and disclose Non-Personal Information about our users without restriction. We may disclose Personal Information that we collect or you provide as described in this Privacy Notice:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business, as described elsewhere in this Notice.
  • To a buyer or other successor (potential or actual) in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Commissioned’s assets, including any related due diligence.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the Information.
  • With your consent.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms of Use.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Commissioned or others.

Except as described above, Commissioned does not sell your information.

  1. Third Parties Providing Services On Our Behalf

We use third parties to host the Platform, design and operate the Platform features, and perform administrative, analytics, payment processing, communications, and shipping services. Services these third parties provide include enabling Commissioned to send you email newsletters and providing information to Commissioned about the use of the Platform and viewing of our content. We may disclose your Information to these companies so they can carry out these services. These companies are bound by contractual obligations to keep Information confidential.

  1. Information From Children Under 13

Commissioned complies with the requirements of the Children’s Online Privacy Protection Act and related regulations. The Platform is not directed at children, and Commissioned does not knowingly collect any Information from children under 13 years of age. If Commissioned learns that a child under 13 years of age has provided Information, Commissioned will delete this Information from our databases. If you are under 13, do not use the Platform or provide any Information about yourself to Commissioned, including your name, address, telephone number or email address. If you become aware that Information of a child under 13 years of age has been provided, please contact us at connect@commissioned.io. Please see the Terms of Use for further guidance.

  1. Links to Other Websites and Services

Unless expressly provided to the contrary, Personal Information that you provide while you are visiting a third-party provider’s website will be subject to the privacy notice posted on that site, and Personal Information that you provide while on the Platform will be subject to this Privacy Notice. The Platform contains links to other sites at which Personal Information is collected. In such instances, unless expressly provided otherwise, the collection and use of your Personal Information will be governed by the privacy notice applicable to that site. That privacy notice should identify the entity that is collecting your Personal Information.

  1. Do Not Track

Some browsers incorporate a “Do Not Track” (“DNT”) feature that, when turned on, signals to websites and online services that you do not want to be tracked. At this time, the Platform does not respond to DNT signals.

  1. Your Choices About Information

We send promotional and marketing communications only with your consent. If you no longer wish to receive these or other communications, you can stop these communications by clicking on the “unsubscribe link” provided in such communications.

Please report your concerns about collection or use of Personal Information available on the Platform to connect@commissioned.io.

  1. Residents of the European Economic Area (“EEA”)

If you are located in the EEA, you may have certain rights under European law with respect to your personal data that is described below. The Application is not intended for users located in the EEA who are under the age of 16. If you are located in the EEA and are under the age of 16, do not use the Platform.

Controller of Personal Information. Commissioned is the Controller of your Personal Information. Commissioned’s primary place of business is 11730 118th Ave NE, #200, Kirkland, WA 98034.

Processing. Commissioned may process your Personal Information on one or more of the following legal bases:

  • as necessary to enter into a contract with you or a legal entity you represent, to perform our contractual obligations, to provide services, to respond to requests from you, or to provide customer support;
  • where we have a legitimate interest, as described in this Privacy Notice (see “How Commissioned Uses Information It Collects About You and the Purposes for Collection and Use”);
  • as necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders; or
  • with your consent.

Your Rights. Subject to applicable law, you may have the right to:

  • ask whether we hold personal information about you and request copies of such Personal Information and information about how it is processed;
  • request that inaccurate Personal Information is corrected;
  • request deletion of Personal Information that is no longer necessary for the purposes underlying the processing, processed based on withdrawn consent, or processed in non-compliance with applicable legal requirements;
  • request us to restrict the processing of Personal Information where the processing is inappropriate;
  • object to the processing of Personal Information;
  • request portability of Personal Information that you have provided to us (which does not include information derived from the collected Personal Information), where the processing of such Personal Information is based on consent or a contract with you and is carried out by automated means; and
  • lodge a complaint with the appropriate data protection authorities.

You can exercise your rights of access, rectification, erasure, restriction, objection, and data portability by contacting us at the email address in section 13 of this Privacy Notice.

When our processing of Personal Information is based on your consent for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.

The categories of Personal Information that Commissioned collects are identified in section 2, “The Types of Information That Commissioned Collects About You and How Commissioned Collects Information About You.” Additional information about how long Commissioned will retain your Information and how it shares your Information is found in section 3, “How Commissioned Uses Information It Collects About You and the Purpose for the Collection and Use,” and section 5, “When Commissioned Shares Your Information” above.

  1. Your California Privacy Rights

If you are a California consumer, you have additional rights. Visit our Your California Privacy Rights page for more information.

  1. How To Contact Us About This Privacy Notice

To ask questions or comment about this Privacy Notice and our privacy practices, please contact us at connect@commissioned.io.

EFFECTIVE DATE: May 18, 2020