PRIVACY POLICY

Effective Date: December 2, 2019

1. Introduction and Overview.

This Privacy Policy provides a comprehensive description of how REGROUP Inc. (“REGROUP,” “we,” “our,” or “us”) collects, uses, and shares information about you as well as your rights and choices regarding such information. It applies to any online location that links to this Privacy Policy (the “Service”).

By using the Service, you agree and consent to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree and consent, discontinue use of the Service.

If you are a California resident or data subject in Europe, please see the “Additional Disclosures for California Residents” and “Additional Disclosures for Data Subjects in Europe” sections. If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section.

2. Information Collection.

A. Information You Provide.

We collect information about you when you use the Service, including when you access our content, contact our customer support, or apply for a job. The categories of information we collect, including in the last 12 months, are:

· Contact Data, including you and/or your employer’s name, email address, postal address, and phone number.

· Content, including content within any messages you send to us (such as feedback and questions to customer support).

· Job Applicant Data, including your employment, education and professional history, and documents necessary to eligibility such as resume and transcript.

You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.

B. Information Collected Automatically.

In addition, we automatically collect and have collected in the last 12 months, the following categories of information:

Service Use Data, including data about the features you use, the pages you visit, the emails and ads you view, the products and services you view, the time of day you browse, and your referring and exiting pages.

Device Connectivity and Configuration Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address.

Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level).

We use various current – and later – developed tracking technologies to automatically collect information when you use the Service, including the following:

· Log Files, which are files that record events that occur in connection with your use of the Service.

· Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Also, persistent cookies allow us to bring you ads both on and off the Service. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.

· Pixels (also known as web beacons), which is code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or ad that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from separate entities that allow us track our conversions and bring you advertising both on and off the Service.

For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.

C. Information on Behalf of Our Clients.

We provide marketing and advertising products and services for our clients, and process information about individuals at the direction of our clients (“Client Data”). Client Data has historically included contact data, content, service use data, device connectivity and configuration data, and location data, among other information. Our processing of Client Data is governed by the master service agreements with our clients, and not this Privacy Policy. We are not responsible for how our clients treat the information we collect on their behalf, and we recommend you review their own privacy policies.

For further information on your rights and choices regarding Client Data, see the “Your Rights and Choices” section below.

D. Information from Other Sources.

We also collect information from other sources which in the last 12 months has included publicly-available sources, such as data in the public domain.

3. Use of Information.

We collect and use the categories of information described in this Privacy Policy for business and commercial purposes. The business purposes for which we use information include:

Operate and manage our Service.

Perform services requested by you, such as respond to your comments, questions, and requests, and provide customer service.

Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.

Preventing and addressing fraud, breach of policies or terms, and threats or harm.

Monitoring and analysing trends, usage, and activities.

Improving the Service or other REGROUP websites, apps, marketing efforts, products and services.

Developing and sending you direct marketing and advertising, including ads and communications about our and other entities’ products, offers, promotions, rewards, events, and services.

Fulfilling any other business or commercial purposes at your direction or with your consent.

REGROUP discloses the following categories of personal information for commercial purposes: contact information and identifiers such as cookies, service use data, and internet or other electronic network activity information such as IP Address. Our disclosure of this information is more fully described in the “Analytics and Advertising” section below.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

4. Sharing of Information.

We share information we collect in accordance with the practices described in this Privacy Policy. The following are the categories of entities to whom we disclose and have shared information with in the last 12 months:

Service Providers. We share information with entities that process the information on our behalf. Service providers assist us with services such as data analytics, marketing and advertising, website hosting, and technical support. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.

Vendors and Other Parties. We share information with vendors and other parties, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process information. For more information, see the “Advertising and Analytics” section below.

Clients. We share information with our clients in connection with us processing information on their behalf. For example, we share information with our clients in order to address your requests, market and advertise to you, and otherwise comply with applicable law.

· Merger or Acquisition. We share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.

· Security and Compelled Disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security and safety of us, the Service or anyone else.

· Consent. We share information at your request or direction or with your consent.

Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.

5. Social Media and Technology Integrations.

We offer parts of our Service through websites, platforms, and services operated or controlled by separate entities. In addition, we integrate technologies operated or controlled by separate entities into parts of our Service. For example, we hyperlink from our Services to websites, social media platforms, and other services not operated or controlled by us.

Please note that when you interact with other entities, including when you leave our Service, those entities may independently collect information about you and solicit information from you. The information collected and stored by those entities remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

6. Analytics and Advertising.

We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.

As part of this process, we may incorporate tracking technologies into our own Service (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and, delivering relevant ads and/or other content to you (“Interest-based Advertising”).

For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, Interest-based Advertising, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.

7. Your Rights and Choices.

A. Tracking Technology Choices.

Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.

Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly.

B. Analytics and Interest-Based Advertising.

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/ .

The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; and (ii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).

Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt-out options or programs.

C. E-mail Communications.

You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or REGROUP’s ongoing business relations.

Please note that your opt out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions.

8. Children.

The Service is intended for a general audience, and, is not directed at children under (13) years of age. We do not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at the email address in the “Contact Us” section below. We will remove the data to the extent required by applicable laws.

9. Data Security.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

10. International Transfer.

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy.

11. Changes to this Privacy Policy.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address.

12. Contact Us.

If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us:

By email:

admin@regroup.us

By mail:

REGROUP, Inc.

213 W. Liberty, Suite 100

Ann Arbor, MI 48104

13. Additional Disclosures for California Residents.

A. Roles.

Our Service is intended to provide information to our business clients and job applicants. You understand and agree that information collected about you is solely within the context of (i) your role as an employee, job applicant, owner, director, officer, or contractor or (ii) REGROUP conducting due diligence regarding, or providing or receiving a product or service to or from your employer.

If you are a California resident and we as a service provider have processed personal information about you on behalf of our clients and you wish to exercise your CCPA rights, please inquire with our client directly. If you wish to make your request directly to us, please provide the name of our client on whose behalf we processed your personal information. We will refer your request to that client, and, will support them to the extent required by California privacy law in responding to your request.

B. Shine the Light.

If you are a resident of California, you may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light” request. We may require additional information from you to allow us to verify your identity and are only required to respond to such requests once during any calendar year.

14. Additional Disclosures for Data Subjects in Europe.

A. Roles.

Data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”).

REGROUP acts as a controller with respect to personal data collected as you interact with our websites, emails, and advertisements. However, in most instances, REGROUP acts a processor on behalf of a client, a separate legal entity, which is the controller. For example, REGROUP helps provide agency services to its clients and processes personal data on their behalf to help them target and understand the success of their advertising campaigns. Please visit the applicable client’s privacy policy for information about their privacy practices. Any questions that you may have relating to the processing of personal data by REGROUP on behalf of the client and your rights under data protection law should be directed to the client as the controller, not to REGROUP.

B. Lawful Basis for Processing.

Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers, partners, or clients; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.

C. Your Data Subject Rights.

If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

Please note that we retain information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

If your personal data has been processed by us on behalf of a client and you wish to exercise any rights you have with such personal data, please inquire with our client directly. If you wish to make your request directly to us, please provide the name of our client on whose behalf we processed your personal data. We will refer your request to that client, and, will support them to the extent required by applicable law in responding to your request.

D. Complaints.

If you have a complaint about our use of your personal data or response to your requests regarding your personal data, you may submit a complaint to the data protection regulator in your jurisdiction. We would, however, appreciate the opportunity to address your concerns before you approach a data protection regulator, and would welcome you directing an inquiry first to us.