Last Updated: April 10, 2023

Welcome.

This document describes how we collect and manage your personal information, and we’ve tried to make it easy to understand. Our company’s formal name is Joinable, Inc. but we’ll refer to it as “Joinable” in this document.

At Joinable, we provide you—our member (sometimes also called a “user”)— with productivity tools that help you build and manage your community.

Joinable is a private place for you and your community members to communicate and share information. We present this Privacy Policy to you to help you understand how we collect, use, and share your personal information while you use Joinable’s online or offline offerings, such as our website, web applications, and mobile applications, which we will call our “Services” to make this Privacy Policy easier to read.

We also want you to know how to exercise your applicable legal rights when you use our Services.

We believe that trust is essential for building community. We are committed to building a platform that does not use advertising as a revenue source. Thus, as a rule, we do not share your personal information, or any content you share, with any advertisers or other third parties without your permission, except as needed for us and our vendors to provide you with the Services under terms consistent with this Privacy Policy. In other words, unless you expressly permit us, we:

• Don’t sell your personal information;

• Don’t share your personal information with advertisers or others who may use it for their own commercial or exploitive purposes;

• Don’t sell ads to capture your attention; and

• Do use industry standard security technologies designed to keep your personal information private and secure.

While we will do everything we can to protect your data, we cannot prevent other members of your community from sharing data they have access to, which may include your personal information, or content you have shared. To prevent this, be mindful of what you share with other Joinable members, and use Joinable’s privacy settings to manage what is shared with other members.

How We Collect Personal Information from You

We collect personal information in a number of ways depending on how you interact with the Services and as required by applicable law. The categories of personal information we may collect include information you provide to us directly, information collected automatically from you, and information we collect from other sources. We now describe each in detail.

Information you provide to us directly

When you create an account, we may ask for your name, email address, phone number, home address, profile picture, etc.

When you purchase premium services or anything else from Joinable, we may ask for the details of your purchase, including payment information, but since we use third-party payment processors like Apple Pay or Stripe to process your payments, we never collect your actual credit card or bank account number.

When you communicate with us, we may ask for your email, phone number, or mailing address to continue to communicate or provide you what you asked for, such as customer or technical help.

When you respond to our surveys, we may ask for specific personal information in connection with the survey.

When you use interactive features of our Services to communicate with other members —like creating Circles and Activities, messaging, uploading files or photos or videos or other content, or otherwise communicating on the Services or on our forums, blogs, or social media—we may collect personal information you submit or make available via the Services. Please note, this Privacy Policy does not protect any information you freely provide to other members using the Services. That information may become “public” to the world because people in your community may share it, or the law may require disclosure.

When you apply for a job with us, we may collect personal information, such as your job applications, CV/resume/cover letter, or any other information as required.

Information collected automatically from you

When you use our Services, we may collect certain information to help us deliver a high-quality and secure product experience, and we strive to minimize the collection and storage of this data. This may include your Internet Protocol (IP) address, cookie identifiers, browser or device information, and approximate location information derived from your IP address.

Depending on how you use our Services, we may collect information such as pages you visit before, during, and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information related to how you use our Services.

Cookie Policy. We and our third-party service providers may use cookies and other tracking technologies (together “Cookie Technologies”) to automatically collect information through your use of our Services. Examples of such Cookie Technologies include:

• Cookies, which are small text files placed in device browsers that store your preferences and facilitate and enhance your experience; or

• Other software code (sometimes called pixel tags or web beacons) that are embedded in our Services that collect information about engagement in our Services, such as generating website visit statistics or as used in emails to let us know whether an email was opened, acted on, or forwarded.

Our uses of these Cookie Technologies would fall into one of the following general categories:

• Operationally Necessary. This includes Cookie Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;

• Performance-Related. We may use Cookie Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below); or

• Functionality-Related. We may use Cookie Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed.

One of the Cookie Technologies that we may use is Google Analytics, which helps us better understand how our digital Services are used and enables us to continually improve and personalize our Services. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

Information we collect from other sources:

The Joinable Services are designed in such a way that for convenience you may use them in conjunction with some third-party services or organizations. For example, you may choose to “sign in with Google”, “sign in with Apple”, or sign in with some other third-party. Or, you may choose to connect your Joinable account to a Google Drive folder and upload files there to share with others. In these cases, Joinable may obtain personal information about you from these third-party services or organizations, including your name, contact information, or profile photo.

We may obtain personal information about you from other Joinable members, such as when they invite you to connect or to join a Circle. Correspondingly, when you are inviting members, please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

How We Use Your Personal Data

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our Services, and other purposes as described below.

We use your personal information to fulfill our contract with you and provide you with our Services, such as to:

• Manage your information and accounts;

• Providing access to certain areas, functionalities, and features of our Services;

• Answering requests for customer or technical support;

• Communicating with you about your account, activities on our Services, and policy changes;

• Processing your financial information and other payment methods for Services purchases;

• Processing applications if you apply for a job we post on our Services; and

• Allowing you to register for events.

We use your personal information for various administrative purposes, such as:

• Pursuing our legitimate interests such as research and development (including marketing research), network and information security, and fraud prevention;

• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

• Measuring interest and engagement in our Services;

• Improving, upgrading, or enhancing our Services;

• Developing new products and services;

• Ensuring internal quality control and safety;

• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;

• Debugging to identify and repair errors with our Services;

• Auditing relating to interactions, transactions, and other compliance activities;

• Sharing personal information with third parties as needed to provide the Services;

• Enforcing our agreements and policies; and

• Carrying out activities that are required to comply with our legal obligations.

We use your personal information to directly market to you from us in a limited way to provide with you with commercial notices as permitted by applicable law to promote our own Services. Reminder: we will not engage with other advertisers to sell your information for our marketing purposes.

We may use your personal information for other purposes with your consent, but only when they are clearly disclosed to you at the time just prior to collection and you have provided your consent.

We may use your personal information for other purposes as requested by you or as required by law.

We may use your personal information in de-identified (i.e., not personally identifiable) and/or aggregate form to perform analyses. If we create or receive de-identified information, we will not attempt to reidentify such information, or provide it in any form that allows any third party to re-identify it, except to comply with applicable law.

How We Share Your Personal Information

We are very careful in sharing your personal information. We share your personal information when needed for the business purposes described below.

The categories of third-parties with whom we share your personal information include:

• Service Providers, who assist us with the provision of our Services to you, such as vendors that provide us with IT support, hosting, payment processing, customer service, and related services.

• Business Partners, who we rely on to provide you with a product or service you have requested, such as third-party services that you choose to connect your Joinable account to. We may also share your personal information with business partners with whom we jointly offer products or services.

• Other Users You Share or Interact With, such as your direct Connections, and people in your Circles and Activities.

We may disclose personal information we store associated with you if we, in good faith, believe doing so is required or appropriate to: comply with a legal process (like as a court order or subpoena); protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; or assist with an investigation or prosecution of suspected or actual illegal activity.

If Joinable is involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, we’ll continue to protect the confidentiality of your personal information and give you notice before any of your personal information is transferred to another party or becomes subject to a new privacy policy.

How We Store Your Personal information

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

How We Keep Your Personal Information Secure

We take a number of steps to ensure your personal information is treated securely and in accordance with this Policy, both in transit and at rest. For example, we use Transport Layer Security (TLS) when sending your data to and from our servers, and we use administrative and technical access controls to limit which of our employees have access to non-public data. That said, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide us, and if we learn of a security system’s breach that affects your personal information, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

What Choices and Rights You May Have Regarding Your Privacy. Under applicable laws or by the design of our Services or both, you may have privacy choices and rights.

Your privacy choices about your personal information may be either determined by applicable law or by our design and are described below:

• Personal Settings on your Account. Please review our documentation [https://docs.joinable.us] detailing how to set your account settings to customize your privacy options and limit the sharing of personal information with other members of your community.

• Email Communications. We may send you two different types of email: email notifying you about activity in your community (“Transactional Email”), and email about Joinable products and services (“Promotional Email”). If you receive an unwanted Promotional Email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future Promotional Emails. If you receive an unwanted Transactional Email from us, you can update your notification settings, or delete your Joinable account completely. Note that when unsubscribing from Promotional Emails you may continue to receive Transactional Emailsor certain non-promotional emails regarding us and our Services, and you will not be able to opt out of those emails (for example, emails regarding our Services or updates to our Terms or this Privacy Policy).

• Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by replying “STOP’ at any time, or by updating your notification settings, or by otherwise contacting us as set forth in “Contact Us” below.

• Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by updating your notification settings, or by changing the notification settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.

• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers which tries to send a signal to the web server. It is not widely supported. Joinable does not have the mechanisms in place to receive and respond to these signals. Instead of using DNT technologies, Joinable lets users decide how they would like cookies used as described in this document.

• Cookies. You may stop or restrict the placement of Cookie Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications.

In accordance with applicable law, you may have the right to:

• Access to and Portability of Your Personal Information, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”);

• Request Correction of Your Personal Information Where It Is Inaccurate or Incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;

• Request Deletion of Your Personal Information. If you decide to delete your account, you can reach out to us at support@joinable.com. However, please note that when you delete your account, it does not affect the information you have added to the community or the information other users have relating to you;

• Request Restriction of or Object to our Processing of Your Personal Information, where the processing of your personal information is based on our legitimate interest or for direct marketing purposes; and

• Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

We May Conduct International Data Transfers. All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws. For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth in “Contact Us” below.

Supplemental Notice for Nevada Residents. If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in Contact Us below.

We Do Not Collect Children’s Personal Information. The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent and wish to review information collected from your child, or have that information modified or deleted, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.

Other Provisions for You To Know About

Your Use of Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

Supervisory Authorities. If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law:

• EEA Data Protection Authorities (DPAs)

• Swiss Federal Data Protection and Information Commissioner (FDPIC)

• UK Information Commissioner’s Office (ICO)

We May Change or Modify this Privacy Policy Whenever. We may revise this Privacy Policy from time to time. You should pay attention to any future changes by reviewing our Privacy Policy from time to time because by continuing to use our Services, you accept any updates made to our Privacy Policy. Of course, if there are any major changes to this Privacy Policy, we will notify you as required by applicable law.

How You May Contact Us

Joinable is the controller of the personal information we process under this Privacy Policy.

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

Joinable, Inc.

support@joinable.us