PRIVACY POLICY

Last updated July 19., 2023

Thank you for choosing to be part of our community at Funelo Holding ApS

(“Company”, “we”, “us”, “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at ob@funelo.io.

When you visit our website https://www.funelo.io (the “Website”), use our mobile application, as the case may be (the “App”) and more generally, use any of our services (the “Services”, which include the Website and App), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

This privacy notice applies to all information collected through our Services (which, as described above, includes our Website and App), as well as, any related services, sales, marketing or events.

Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

TABLE OF CONTENTS

WHAT INFORMATION DO WE COLLECT?
HOW DO WE USE YOUR INFORMATION?
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
HOW DO WE HANDLE YOUR SOCIAL LOGINS?
HOW LONG DO WE KEEP YOUR INFORMATION?
HOW DO WE KEEP YOUR INFORMATION SAFE?
DO WE COLLECT INFORMATION FROM MINORS?
WHAT ARE YOUR PRIVACY RIGHTS?
CONTROLS FOR DO-NOT-TRACK FEATURES
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
DO WE MAKE UPDATES TO THIS NOTICE?
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

1.WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services (such as by posting messages in our online forums or entering competitions, contests or giveaways) or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by You. We collect names; phone numbers; email addresses; mailing addresses; job titles; usernames; passwords; contact preferences; contact or authentication data; billing addresses; debit/credit card numbers; and other similar information.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Apple or Google on their app stores.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: https://www.funelo.io/cookies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device

information, browser type and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports

(sometimes called ‘crash dumps’) and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers,

location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.

Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.

Information collected through our App

In Short: We collect information regarding your geolocation, mobile device, push notifications, and Facebook permissions when you use our App.

If you use our App, we also collect the following information:

Geolocation Information
We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our App, to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Access
We may request access or permission to certain features from your mobile device, including your mobile device’s camera, microphone, social media accounts, storage, reminders, calendar, contacts, bluetooth, sensors, sms messages, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Data
We automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID and information about the features of our App you accessed.

Push Notifications
We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

Facebook Permissions
We by default access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, checkins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.

This information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, as well as from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data

(or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g. Facebook or Twitter), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account’s privacy settings.

2.HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

To facilitate account creation and logon process: If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract. See the section below headed “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” for further information.

To post testimonials: We post testimonials on our Services that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at nb@funelo.io and be sure to include your name, testimonial location, and contact information.

Request feedback: We may use your information to request feedback and to contact you about your use of our Services.

To enable user-to-user communications: We may use your information in order to enable user-to-user communications with each user’s consent.

To manage user accounts: We may use your information for the purposes of managing our account and keeping it in working order.

To send administrative information to you: We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

To protect our Services: We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).

To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.

To respond to legal requests and prevent harm: If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

Fulfill and manage your orders: We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

Administer price draws and competitions: We may use your information to administer price draws and competitions when you elect to participate in our competitions.

To deliver and facilitate delivery of services to the user: We may use your information to provide you with the requested service.

To respond to user inquiries/offer support to users: We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

To send you marketing and promotional communications: We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS?” below).

Deliver targeted advertising to you: We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. For more information see our Cookie Notice: https://www.funelo.io/cookies.

For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

3.WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.

Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Google Maps Platform APIs.: We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Place API). To find out more about Google’s Privacy Policy, please refer to this link. We use certain Google Maps Platform APIs to retrieve certain information when you make location-specific requests. This includes: All legally available information; and other similar information. A full list of what we use information for can be found in this section and in the previous section titled “HOW DO WE USE YOUR INFORMATION?”. We obtain and store on your device (‘cache’) your location for six (6) months. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document. The Google Maps Platform APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Economic Area (EU countries, Iceland, Liechtenstein and Norway) or United Kingdom, please take a look at our Cookie Notice, which can be found at this link: https://www.funelo.io/cookies.

Business Partners: We may share your information with our business partners to offer you certain products, services or promotions.

Other Users: When you share personal information (for example, by posting comments, contributions or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

Offer Wall: Our App may display a third-party hosted “offer wall.” Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our App and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our App. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward. Please note that we do not control third-party websites and have no responsibility in relation to the content of such websites. The inclusion of a link towards a third-party website does not imply an endorsement by us of such website. Accordingly, we do not make any warranty regarding such third-party websites and we will not be liable for any loss or damage caused by the use of such websites. In addition, when you access any third-party website, please understand that your rights while accessing and using those websites will be governed by the privacy notice and terms of service relating to the use of those websites.

4.DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: h ttp://www.funelo.io/cookies.

5.HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Services offers you the ability to register and login using your third-party social media account details (like your Facebook or LinkedIn logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public on such social media platform. If you login using Facebook, we may also request access to other permissions related to your account, such as your friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services.

Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

6.HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7.HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8.DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at nb@funelo.io.

9.WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here:

http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

If you have questions or comments about your privacy rights, you may email us at nb@funelo.io.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/. For further information, please see our Cookie Notice: https://www.funelo.io/cookies.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may: Access your account settings and update your preferences.

10.CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

11.DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with a Service, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

every individual who is in the State of California for other than a temporary or transitory purpose and
every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve

(12) months:

Identifiers: Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name: YES

Personal information categories listed in the California Customer Records statute: Name, contact information, education, employment, employment history and financial information: YES

Protected classification characteristics under California or federal law: Gender and date of birth: YES

Commercial information: Transaction information, purchase history, financial details and payment information: YES

Biometric information: Fingerprints and voiceprints: NO

Internet or other similar network activity, Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications: YES

Systems and advertisements: YES

Geolocation data, Device location: YES

Audio, electronic, visual, thermal, olfactory, or similar information, Images and audio, video or call recordings created in connection with our business activities: YES

Professional or employment-related information: Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us: Education Information, Student records and directory information: YES

Inferences drawn from other personal information: Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics: YES

We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:

Receiving help through our customer support channels;

Participation in customer surveys or contests; and

Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice and our Cookie Notice: https://www.funelo.io/cookies.

You may contact us by email at nb@funelo.io, by visiting https://www.funelo.io, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for- profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.

Funelo Holding ApS has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding 12 months. Funelo Holding ApS will not sell personal information in the future belonging to website visitors, users and other consumers.

Your rights with respect to your personal data,Right to request deletion of the data – Request to delete:

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

Right to be informed – Request to know: Depending on the circumstances, you have a right to know:

whether we collect and use your personal information;

the categories of personal information that we collect;

the purposes for which the collected personal information is used;

whether we sell your personal information to third parties;

the categories of personal information that we sold or disclosed for a business purpose;

the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re- identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights We will not discriminate against you if you exercise your privacy rights.

Verification process: Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may

request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights:

you may object to the processing of your personal data

you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data

you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.

To exercise these rights, you can contact us by email at nb@funelo.io, by visiting h ttp://www.funelo.io, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

12.DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13.HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at nb@funelo.io or by post to:

Funelo Holding ApS

Skovmarken 3, 2800 Kongens Lyngby, Denmark

Kongens Lyngby 2800 Denmark

14.HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please visit: https://www.funelo.io .

Funelo complies with all Meta Platform Terms and policies as stated below:

Meta Platform Terms

Introduction

Our Platform is the set of APIs, SDKs, tools, plugins, code, technology, content, and services that enables others, including app developers and website operators, to develop functionality, retrieve data from Meta and any other Meta Products, or provide data to us.

To use Platform (including to Process any Platform Data), you agree to these Platform Terms (“Terms”), as well as all other applicable terms and policies. This may include the Meta Terms of Service, the Instagram Terms of Use, the Meta Commercial Terms, the Business Tools Terms, and any Meta Product terms that are applicable.

You must also comply with the applicable requirements in our Developer Policies and those made available on our Developer Site, including in our Documentation collectively, the “Developer Docs”)

These Terms will start on the earlier of the date you accept them or otherwise start accessing or using Platform, and will continue until you stop accessing and using Platform, unless ended earlier as described below. If you are accepting these Terms or accessing or using Platform on behalf of an entity, you represent and warrant that you have the authority to bind such entity to these Terms and you agree on behalf of such entity to be bound by these Terms (and for clarity, all other references to “you” in these Terms refer to such entity). For clarity, these Terms updated and replaced the Facebook Platform Policy and the Instagram Platform Policy and any references in existing terms, policies, or agreements to the “Facebook Platform Policy,” “Instagram Platform Policy,” or “Platform Policy” shall now mean these Terms.

If you fail to comply with these Terms or any other applicable terms or policies, we may suspend or terminate your App or account, as described below.

Capitalized terms not otherwise defined herein (including in Section 12 (“Glossary”) have the meaning given in our other terms and policies, including our Terms of Service and our Meta Commercial Terms. The term “including” means “including without limitation.”

Intellectual Property Rights

Our License to You. Subject to your compliance with these Terms and all other applicable terms and policies, we grant you a limited, non-exclusive, non-sublicensable (except to Service Providers as described below), non-transferable, non-assignable license to use, access, and integrate with Platform, but only to the extent permitted in these Terms and all other applicable terms and policies. You will not sell, transfer, or sublicense Platform to anyone. Except as expressly licensed herein, you will not use, access, integrate with, modify, translate, create derivative works of, reverse engineer, or otherwise exploit Platform or any aspect thereof. The Meta Companies reserve all rights, title, and interest (including the right to enforce any such rights) not expressly granted in these Terms.

Your License to Us

Your Content:

You grant us a non-exclusive, transferable, sublicensable, royalty-free, worldwide license to: host, use, distribute, modify, run, copy, publicly perform or display, translate, and create derivative works of any information, data, and other content made available by you or on your behalf (including by your Service Providers or through your App) in connection with Platform (collectively, “Your Content”) for any business purpose in connection with operating, providing, or improving Platform or any other Meta Product. This license remains in effect even if you stop using Platform. Without limitation, your license to us includes: the right to incorporate Your Content into other parts of Meta Products, the right to attribute the source of Your Content using your name, trademarks, or logos; the right to use Your Content for promotional purposes, and the right to analyze Your Content (including to make sure you’re complying with these Terms and all other applicable terms and policies).

If you use the Meta Business Tools to send us Business Tool Data, our use of that data is governed by the Business Tools Terms rather than the foregoing license for Your Content.

If you owned Your Content before providing it to us, you will continue owning it after providing it to us, subject to any rights granted in these Terms or any other applicable terms or policies and any access you provide to others by sharing it via Platform.

Your App:

You grant us a non-exclusive, transferable, sublicensable, royalty-free, worldwide license to: host, use, distribute, modify, run, copy, publicly perform or display, translate, and create derivative works of your App for any business purpose in connection with operating, providing, or improving Platform. This license remains in effect even if you stop using Platform. Without limitation, the foregoing license includes the right to frame or link to your App, to place content (including ads) around your App, and to analyze your App (including to assess your compliance with these Terms and all other applicable terms and policies).

As between the parties, in connection with Platform, we won’t be subject to any terms or policies associated with your App or Your Content (even if we click or tap agreement). Those terms and policies are considered null and void and are rejected and excluded from these Terms.

Nothing in these Terms will be interpreted as a representation or agreement that we will not develop or have not developed apps, products, features, or services that are similar to your App or compete with your App.

iii. Your Name, Trademarks, and Logos: You grant us a non-exclusive, transferable, sublicensable, royalty-free, worldwide license to use your name, trademarks, and logos for distribution, marketing, and promotional purposes, in connection with your use of Meta Products, in all formats and media. This license remains in effect for existing materials and instances even if you stop using Platform.

Protecting the Rights of Others

You will not provide or promote content in your App that infringes upon or otherwise violates the rights of any person or third party.

You will obtain (and represent and warrant that you own or have secured) all rights necessary from all applicable rights holders to (1) grant the licenses, rights, and permissions in these Terms (including those in Section 2.b (“Your License to Us”)); (2) display, distribute, and deliver all information, data, and other content in your App; and (3) otherwise operate your App. This includes satisfying all licensing, reporting, and payout obligations to third parties.

iii. If your App contains content submitted or provided by your Users or other third parties, you must have an appropriate notice and takedown process and otherwise comply with all applicable laws and regulations to respond to notices of claimed infringement. Without limiting that compliance, in the United States, you must comply with all requirements of the Digital Millennium Copyright Act.

Data Use

Prohibited Practices. You will not perform, or facilitate or support others in performing, any of the following prohibited practices (collectively, “Prohibited Practices”):

Processing Platform Data to discriminate or encourage discrimination against people based on personal attributes including race, ethnicity, color, national origin, religion, age, sex, sexual orientation, gender identity, family status, disability, medical or genetic condition, or any other categories prohibited by applicable law, regulation, or Meta policy.

Processing Platform Data to make eligibility determinations about people, including for housing, employment, insurance, education opportunities, credit, government benefits, or immigration status. By eligibility determinations, we mean determining whether to provide, deny, or take away a particular benefit (for example, housing or scholarships) as well as determining the terms under which the benefit will be provided, denied, or taken away.

iii. Processing Platform Data to perform, facilitate, or provide tools for surveillance. Surveillance includes the Processing of Platform Data about people, groups, or events for law enforcement or national security purposes.

Selling, licensing, or purchasing Platform Data.

Placing Platform Data on, or otherwise making Platform Data available to, a search engine or directory without our prior express written consent.

Attempting to decode, circumvent, re-identify, de-anonymize, unscramble, unencrypt, or reverse hash, or reverse-engineer Platform Data that is provided to you.

vii. Changing your App’s core functionality or data Processing so that Users would view it as an unfamiliar or different App, or materially changing the scope of Processing of previously collected Platform Data, unless in each case you first re-submit your App and receive our approval through App Review.

viii. Processing friend lists from Facebook to establish social connections in your App unless each person in that connection has granted you access to that information for that purpose.

Additional Terms for Restricted Platform Data

You will not request Restricted Platform Data unless it is necessary to meaningfully improve the quality of the applicable User’s experience in the specific product or service for which the User shared the data.

It must be clear to the User why you are requesting their Restricted Platform Data in order to improve the quality of their experience.

iii. For clarity, your Processing of Restricted Platform Data must comply with the applicable Developer Docs and other provisions of these Terms (including the Prohibited Practices).

Sharing Platform Data. You may only share Platform Data in compliance with these Terms (including Sections 3.a (“Prohibited Practices”), 3.b (“Additional Terms for Restricted Platform Data”), 4 (“Privacy Policy”), and 5 (“Service Providers and Tech Providers”)), applicable law and regulations, and all other applicable terms and policies, and only in the following circumstances:

With respect to Platform Data collected as a Tech Provider, solely as described below in Section 5.b (“Tech Providers”);

With respect to Platform Data not collected as a Tech Provider,

when required under applicable law or regulation (you must retain proof of the applicable legal or regulatory requirement or request and provide it to us if we ask for it);

with your Service Provider;

when a User expressly directs you to share the data with a third party (you must retain proof of the User’s express direction and provide it to us if we ask for it); or

solely with respect to Platform Data that is not Restricted Platform Data, with other third parties, so long as:

you first contractually prohibit them from using the Platform Data in a way that would violate these Terms or any other applicable terms or policies (you must retain proof of the contractual prohibition and provide it to us if we ask for it); and

you ensure that any such third parties comply with these Terms and all other applicable terms and policies as if they were in your place, and you are responsible for their acts and omissions, including their noncompliance.

Retention, Deletion, and Accessibility of Platform Data

Unless required to keep Platform Data under applicable law or regulation, you must (and must make reasonable efforts to ensure your Service Providers) do the following:

Make reasonable efforts to keep Platform Data up to date, including Platform Data that has been modified or deleted. You must update Platform Data promptly after receiving a request from us or the User to do so. You must give Users an easily accessible and clearly marked way to ask for their Platform Data to be modified or deleted.

Delete all Platform Data as soon as reasonably possible in the following cases:

When retaining the Platform Data is no longer necessary for a legitimate business purpose that is consistent with these Terms and all other applicable terms and policies;

When you stop operating the product or service through which the Platform Data was acquired;

When we request you delete the Platform Data for the protection of Users (which we will determine at our sole discretion);

When a User requests their Platform Data be deleted or no longer has an account with you (unless the Platform Data has been aggregated, obscured, or de-identified so that it cannot be associated with a particular User, browser, or device), or for Tech Providers, when a User or the Client requests their Platform Data be deleted or the Client no longer has an account with you;

When required by applicable law or regulations; or

As required under Section 7 (“Compliance Review Rights and Suspension and Termination of these Terms”).

If you are required to keep Platform Data under applicable law or regulation, you must retain proof of the applicable legal or regulatory requirement or request and provide it if we ask for it.

iii. If you have received Platform Data in error, you must immediately report this to us, delete that Platform Data, and provide proof of deletion if we ask for it.

Exceptions to Restrictions. The above provisions of this section (Section 3.a-d) do not apply to certain Platform Data as described here.

Privacy Policy

If you use Platform to Process Platform Data, you will provide and comply with a publicly available and easily accessible privacy policy.

This policy must comply with applicable law and regulations and must accurately and clearly explain what data you are Processing, how you are Processing it, the purposes for which you are Processing it, and how Users may request deletion of that data.

You may only Process Platform Data as clearly described in your privacy policy and in accordance with all applicable law and regulations, these Terms, and all other applicable terms and policies.

Your privacy policy will not supersede, modify, or be inconsistent with these Terms or any other applicable terms or policies.

You must retain all of your privacy policies in effect while using Platform and provide them to us if we ask for them.

You will maintain publicly available links to your privacy policies in the privacy policy field in the settings of your App Dashboard, as well as in any App Store that allows you to do so, if applicable, and ensure the links remain current and up to date.

Service Providers and Tech Providers

Service Providers

You will not use a Service Provider in connection with your use of Platform or Processing of Platform Data unless such Service Provider first agrees in writing to do the following:

Use Platform and Process Platform Data solely for you and at your direction in order to provide services you requested in a manner that is consistent with these Terms, all other applicable terms and policies, and your privacy policy, and for no other individual or entity and for no other purpose, including for the Service Provider’s own purposes; and

In the event the Service Provider engages another Service Provider (“Sub-Service Provider”) in order to provide the services requested, ensure the Service Provider requires the Sub-Service Provider in writing to comply with the above requirements.

You must ensure that any Service Provider and Sub-Service Provider complies with these Terms and all other applicable terms and policies as if they were in your place, and you are responsible for their acts and omissions, including their noncompliance.

iii. When you cease using a Service Provider or Sub-Service Provider, you must ensure they immediately cease using Platform and Processing Platform Data and promptly delete all Platform Data in their possession or control.

Upon our request, you must provide a list of your Service Providers and Sub-Service Providers including up-to-date contact information for each, the types and volume of Platform Data shared, and proof of written agreements with your Service Providers to demonstrate compliance with this Section.

We may prohibit your use of any Service Provider or Sub-Service Provider in connection with your use of Platform or Processing of Platform Data if we believe that (1) they have violated these Terms or other applicable terms or policies or (2) they are negatively impacting Platform, other Meta Products, Platform Data, or people who use Meta Products, and will provide notice to you if we do. Promptly upon such notice, you must stop using that Service Provider or Sub-Service Provider in connection with your use of Platform or Processing of Platform Data.

We may require that your Service Providers or Sub-Service Providers agree to these Terms or other applicable terms or policies in order to access Meta Products, Platform, or Platform Data.

Tech Providers

If you are a Tech Provider, you must comply with the other provisions of these Terms, as well as the provisions in this section with respect to your use of Platform and Processing of Platform Data as a Tech Provider. If the terms conflict, the terms that are more restrictive on you or more protective of us apply.

You, as a Tech Provider, understand and agree to the following:

You will only use Platform and Process Platform Data on behalf of and at the direction of your Client on whose behalf you access it to help such Client to use Platform or Process Platform Data in accordance with these Terms and all other applicable terms and policies (“Client’s Purpose”), and not for your own purposes or another Client’s or entity’s purposes (for example, you will not Process Platform Data to build or augment user profiles for your own purposes or another Client’s purposes);

You will ensure that Platform Data you maintain on behalf of one Client is maintained separately from that of other Clients;

You will maintain an up-to-date list of your Clients and their contact information and provide it to us if we ask for it;

You will only share Platform Data in compliance with these Terms (including Sections 3a (“Prohibited Practices”), 3b (“Additional Terms for Restricted Platform Data”), and 5a (“Service Providers”)), applicable law and regulations, and all other applicable terms and policies, and only in the following circumstances:

with your applicable Client, so long as you first contractually prohibit such Client from Processing Platform Data in a way that would violate these Terms or any other applicable terms or policies;

to the extent required under applicable law or regulation (you must retain proof of the applicable legal or regulatory requirement or request and provide it to us if we ask for it);

with your Service Provider solely to the extent necessary for your applicable Client’s Purpose; or

with your Client’s service provider solely to the extent necessary for such Client’s Purpose and when such Client expressly directs you to share the data with such service provider (you must retain proof of the Client’s express direction and provide it to us if we ask for it);

We may require that your Clients agree to these Terms or other applicable terms or policies in order to access Meta Products, Platform, or Platform Data through your App.

You will promptly terminate a Client’s use of our Meta Products, Platform, or Platform Data through your App if we request it because we believe that the Client (a) has violated these Terms or other applicable terms or policies or (b) is negatively impacting Platform, other Meta Products, Platform Data, or people who use Meta Products.

Data Security

Data Security Requirements

You must always have in effect and maintain administrative, physical, and technical safeguards that do the following:

Meet or exceed industry standards given the sensitivity of the Platform Data;

Comply with applicable law and regulations, including data security and privacy laws, rules, and regulations; and

Are designed to prevent any unauthorized (including in violation of these Terms or any other applicable terms or policies) Processing (including, for the avoidance of doubt, access, destruction, loss, alteration, disclosure, distribution, or compromise) of Platform Data.

You must have a publicly available way for people to report security vulnerabilities in your App to you, and you must promptly address identified deficiencies.

iii. You must not solicit, collect, store, cache, proxy, or use Facebook or Instagram login credentials of other Users.

You must not transfer or share user IDs or your access token and secret key, except with a Service Provider who helps you build, run, or operate your App.

Incident Reporting

If any of the following incidents happen, you must promptly, and no later than 24 hours after you become aware of the incident, notify us and provide us with information we request regarding:

Any unauthorized (including in violation of these Terms or any other applicable terms or policies) Processing (including, for the avoidance of doubt, access, destruction, loss, alteration, disclosure, distribution or compromise) of Platform Data; or

Any incidents that are reasonably likely to compromise the security, confidentiality, or integrity of your IT Systems or your Service Provider’s or Sub-Service Provider’s IT Systems.

You must immediately begin remediation of the incident and reasonably cooperate with us, including by informing us in reasonable detail of the impact of the incident upon Platform Data and corrective actions being taken, and keeping us updated about your compliance with any notification or other requirements under applicable laws and regulations.

Compliance Review Rights and Suspension and Termination of these Terms

App Review. We may require that you submit your App for our review or approval (“App Review”). Whether or not your App (including its access to any Platform Data) is approved (which will be in our sole discretion), you will ensure that your App is compliant with these Terms and all other applicable terms and policies, and we may review your App for such compliance from time to time, in our sole discretion. You will cooperate with our reviews and provide any information we request. We may verify information you provide to us during any such reviews or otherwise in your App dashboard, which you will update to keep it complete and accurate.

Regular Monitoring. We, or third-party professionals working at our direction (including auditors, attorneys, consultants, and/or computer forensics analysts) (collectively, “Third-Party Auditors”), may conduct regular monitoring of your App and its access to Platform and Processing of Platform Data using technical and operational measures.

Auditing Rights

We or Third-Party Auditors may conduct an Audit, no more than once a calendar year unless there is a Necessary Condition, to ensure that your and your App’s Processing of Platform Data is and has been in compliance with these Terms and all other applicable terms and policies.

Audits will be conducted during normal business hours after providing you with at least 10 business days’ written notice (email will suffice), unless we determine in our sole discretion a Necessary Condition requires more immediate access.

iii. You will cooperate with the Audits, including by (1) providing all necessary physical and remote access to your IT Systems and Records, and (2) providing information and assistance as reasonably requested (including making your personnel who are knowledgeable about your or your App’s Processing of Platform Data available for our questioning).

You will also use commercially reasonable efforts to get permission and cooperation from your Service Providers for us to conduct such Audits with respect to their IT Systems, Records, and applicable personnel.

You will remedy any non-compliance revealed by an Audit as soon as reasonably practicable (as we determine based on the facts and circumstances), after which we may conduct follow-up Audits to ensure proper remediation of the non-compliance.

If an Audit reveals any non-compliance by you or your Service Provider(s) then you will reimburse us for all of our reasonable costs and expenses associated with conducting the Audit and any related follow-up Audits.

vii. After these Terms have ended, our Audit rights under this Section will survive until 1 year after the later of when you affirmatively demonstrate that you have stopped Processing all Platform Data and all embodiments thereof that are in your and your Service Providers’ possession or control have been deleted. For the avoidance of doubt, nothing in this Section limits any other rights or remedies we may have by law, in equity, or under these Terms or other applicable terms or policies.

Certifications. From time to time, we may request (in writing or through your App dashboard, Platform, or any Meta Product) information, certifications, and attestations relating to your use of Platform or Processing of Platform Data, which you will provide to us in the requested time frame and form. This may include certifying: (i) your compliance with these Terms and all other applicable terms and policies, and (ii) the purpose or use for the Platform Data you have requested or have access to, and that each such purpose or use complies with these Terms and all other applicable terms and policies. All such certifications and attestations must be provided by an authorized representative of yours.

Suspension and Termination

We may take enforcement action against you and your App if we believe, in our sole discretion, that:

You have not timely responded to our requests related to monitoring or auditing;

You or your App has violated or may have violated these Terms or any other applicable terms or policies or is negatively impacting Platform, other Meta Products, Platform Data, or people who use Meta Products;

It is needed to comply with applicable laws or regulations or otherwise required or requested by a court order or governmental authority; or

It is needed to protect the Meta Companies from legal or regulatory liability.

We may take enforcement action at any time, including while we investigate your App, with or without notice to you. Enforcement can be both automated and manual. It can include suspending or removing your App, removing your access and your App’s access to Platform, requiring that you stop Processing and delete Platform Data, terminating our agreements with you, or any other action that we consider to be appropriate, including terminating other agreements with you or your ability to use Meta Products.

iii. We may suspend or end your App’s access to any Platform APIs, permissions, or features that your App has not used or accessed within a 90-day period with or without notice to you.

Notice

After you agree to these Terms, any written notice, request, or communications from us to you may be provided via email or mail (for example, to the email address or mailing address in your App account with us) or via notifications within the Meta Products (for example, in your account with us). You will keep your contact information current, including name, business name, and email.

Indemnification

In addition to and without limiting the scope of the “Indemnification” Section in our Meta Commercial Terms if anyone brings a claim, cause of action, or dispute against the Meta Companies related to your use of Platform, your Processing of Platform Data, Your Content, or your App, name or logo, products or services, or actions in connection with Platform, you will indemnify and hold the Meta Companies harmless from and against all damages, losses, and expenses of any kind (including reasonable legal fees and costs) related to any such claim, cause of action, or dispute.

International Transfers

This section shall apply to the extent that your Processing of Platform Data includes personal data controlled by Meta Platforms Ireland Limited (“Meta Ireland Data”) and the transfer of such Meta Ireland Data to a territory outside of the European Economic Area that, at the time of such transfer, does not have a positive adequacy decision from the European Commission under Article 45 of Regulation (EU) 2016/679 (each an “EEA Data Transfer”).

Whenever there is an EEA Data Transfer, your use of Meta Ireland Data is subject to your compliance with the Clauses in so far as they relate to controller to controller transfers (Module One). In each case, you agree that for the purposes of Section IV, Clauses 17 and 18 in the Clauses, Option 1 and Option (b) shall apply respectively and the Member State shall be Ireland. Nothing in this Section 10 (International transfers) is intended to vary or modify the Clauses. For the purposes of the Appendix to the Clauses, the following will apply:

For the purposes of Annex I(A) to the Clauses, Meta Platforms Ireland Limited is the “data exporter” and you are the “data importer” as defined in the Clauses.

For the purposes of Annex I(B) to the Clauses:

“Categories of data subjects” are the Users who visit, access, use, or otherwise interact with the App and the products and services of Meta Platforms Ireland Limited;

“Categories of personal data” are Meta Ireland Data, which includes profile information, photos and videos, location information, communications between Users, information about use of the App and other products and services, payment information, device information, information about visits to third-party websites or Apps that use a “like” or “comment” button or other service integration, information from third-party partners or the Meta Companies, or as otherwise set forth in the Data Policy;

iii. “Sensitive data” is personal data about a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation, criminal convictions or alleged commission of an offence;

“Frequency of the transfer” is on a continuous basis to the extent required to fulfil the purpose outlined in Section 10(b)(v) below;

Nature and purpose of the data transfer(s)” is the provision of the App and other products and services by you to Users pursuant to the applicable terms and conditions and Privacy Policy of you and/or your Client; and

“Period for which personal data will be retained” is as set out in Section 3(d)(i)(2) unless applicable laws require the Meta Ireland Data be retained for a longer period, in which case you shall only retain such Meta Ireland Data for the period required by such applicable laws and subject always to Section 10(d).

For the purposes of Annex I(C) to the Clauses, the competent supervisory authority will be the Data Protection Commission in Ireland; and

For the purposes of Annex II to the Clauses, you will implement and maintain the technical and organisational security measures set out in Section 6 (“Data Security”) and such other measures as we may require from time to time.

General

In accordance with our Terms of Service, you will not transfer any of your rights or obligations under these Terms to anyone else without our prior written consent. Transferring can include assignment, acquisition, merger, change of control, or other forms of transfer. Any unpermitted transfer will be considered null and void. For any permitted transfer, you can continue to Process Platform Data only for your App subject to these Terms and only after you re-submit your App and receive our approval through our App Review process.

You also must comply with all applicable laws and regulations (including the Children’s Online Privacy Protection Act (“COPPA”) and the Video Privacy Protection Act (“VPPA”)).

If there is any conflict between these Terms and any other applicable online terms, the terms that are more restrictive on you and your App or more protective of us apply. If you have previously agreed to our Supplemental Terms for Extended Platform Products and/or our Technology Provider Amendment to Supplemental Terms for Extended Platform Products, these Terms hereby supersede and replace them.

We reserve the right to amend these Terms at any time. Your continued use of or access to Platform after any such amendment will constitute your binding agreement to these Terms as amended.

We may change, suspend, or discontinue the availability of Platform at any time. In addition, we may impose limits on certain features and services or restrict your access to parts or all of our APIs or websites without notice or liability.

If we elect to provide you with support or modifications for Platform, we may discontinue either at any time without notice to you.

We do not guarantee that Platform will always be free.

We can issue a press release or otherwise make public statements or disclosures describing our relationship with you or your use of Platform.

When these Terms have ended, all rights granted to you under these Terms will immediately stop and you will immediately stop using Platform. The following Sections will remain in effect after these Terms have ended: Section 2.b, Section 2.c, Section 3, Section 4, Section 5, Section 6, Section 7, Section 9, Section 10, Section 11, and Section 12.

Glossary

“App” means any technical integration with Platform or to which we have assigned an App identification number. Any code, APIs, SDKs, tools, plugins, bots, websites, applications, specifications, and other technology made available by you or on your behalf in connection with Platform is considered part of your App.

“Audit” means a review, inspection, or audit of your and your Service Providers’ IT Systems or Records.

“Clauses” means the standard contractual clauses annexed to European Commission Decision (EU) 2021/914.

“Client” means the User of a Tech Provider’s App.

“Developer” means the person or entity that creates or operates an App.

“Developer Docs” has the meaning given in Section 1.c (“Introduction”).

“IT Systems” means information technology systems (real and virtual), networks, technologies, and facilities (including physical and remote access to data centers and cloud facilities) that Process Platform Data.

“Necessary Condition” means any of the following:

it is required by applicable law, rule, or regulation or otherwise required or requested by a court order or governmental authority;

we suspect that you or your App have Processed Platform Data in violation of these Terms or other applicable terms or policies;

iii. you enter into a change of control transaction or transfer (or request to transfer) any of your rights or obligations under these Terms or other applicable terms or policies;

we determine in our sole discretion it is necessary to ensure that you and your App have deleted Platform Data in accordance with these Terms and all other applicable terms and policies; or

we determine in our sole discretion it is necessary to ensure proper remediation of any non-compliance revealed by an Audit.

“Platform” means the set of APIs, SDKs, tools, plugins, code, technology, content, and services that enables others, including app developers and website operators, to develop functionality, retrieve data from Meta and any other Meta Products, or provide data to us.

“Platform Data” means any information, data, or other content you obtain from us, through Platform or through your App, whether directly or indirectly and whether before, on, or after the date you agree to these Terms, including data anonymized, aggregated, or derived from such data. Platform Data includes app tokens, page tokens, access tokens, app secrets, and user tokens.

“Process” means any operation or set of operations performed on data or sets of data, whether or not by automated means, including use, collection, storage, sharing, or transmission.

“Prohibited Practices” has the meaning given in Section 3.a (“Prohibited Practices”).

“Records” mean books, agreements, access logs, third-party reports, policies, processes, and other records regarding the Processing of Platform Data.

“Restricted Platform Data” means Platform Data that (i) reasonably can be used to identify a particular User or device; (ii) is accessed using the permissions listed here; or (iii) we otherwise designate as Restricted. Notwithstanding the foregoing, Restricted Platform Data does not include data that can be accessed using the permissions listed here.

“SDKs” means any object code, source code, or documentation you receive from us that helps you create Apps or content for use with the Platform.

“Service Provider” means an entity you use to provide you services in connection with Platform or any Platform Data.

“Tech Provider” means a Developer of an App whose primary purpose is to enable Users thereof to access and use Platform or Platform Data.

“Third-Party Auditors” has the meaning given in Section 7.b (“Regular Monitoring”).

“User” means the end user of an App (whether a person or an entity).

“Your Content” has the meaning given in Section 2.b (“Your License to Us”).

Funelo complies with all Linkedin terms and policies as stated below:

Our mission is to connect the world’s professionals to allow them to be more productive and successful. Our services are designed to promote economic opportunity for our members by enabling you and millions of other professionals to meet, exchange ideas, learn, and find opportunities or employees, work, and make decisions in a network of trusted relationships.

Introduction

1.1 Contract

When you use our Services you agree to all of these terms. Your use of our Services is also subject to our Cookie Policy and our Privacy Policy, which covers how we collect, use, share, and store your personal information.

You agree that by clicking “Join Now”, “Join LinkedIn”, “Sign Up” or similar, registering, accessing or using our services (described below), you are agreeing to enter into a legally binding contract with LinkedIn (even if you are using our Services on behalf of a company). If you do not agree to this contract (“Contract” or “User Agreement”), do not click “Join Now” (or similar) and do not access or otherwise use any of our Services. If you wish to terminate this contract, at any time you can do so by closing your account and no longer accessing or using our Services.

Services

This Contract applies to LinkedIn.com, LinkedIn-branded apps, LinkedIn Learning and other LinkedIn-related sites, apps, communications and other services that state that they are offered under this Contract (“Services”), including the offsite collection of data for those Services, such as our ads and the “Apply with LinkedIn” and “Share with LinkedIn” plugins. Registered users of our Services are “Members” and unregistered users are “Visitors”.

You are entering into this Contract with LinkedIn (also referred to as “we” and “us”).

We use the term “Designated Countries” to refer to countries in the European Union (EU), European Economic Area (EEA), and Switzerland.

If you reside in the “Designated Countries”, you are entering into this Contract with LinkedIn Ireland Unlimited Company (“LinkedIn Ireland”) and LinkedIn Ireland will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services.

If you reside outside of the “Designated Countries”, you are entering into this Contract with LinkedIn Corporation (“LinkedIn Corp.”) and LinkedIn Corp. will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services.

This Contract applies to Members and Visitors.

As a Visitor or Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy (which includes our Cookie Policy and other documents referenced in this Privacy Policy) and updates.

1.2 Members and Visitors

When you register and join the LinkedIn Services, you become a Member. If you have chosen not to register for our Services, you may access certain features as a “Visitor.”

1.3 Change

We may make changes to the Contract.

We may modify this Contract, our Privacy Policy and our Cookies Policy from time to time. If we make material changes to it, we will provide you notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. We agree that changes cannot be retroactive. If you object to any changes, you may close your account. Your continued use of our Services after we publish or send a notice about our changes to these terms means that you are consenting to the updated terms as of their effective date.

Obligations

2.1 Service Eligibility

Here are some promises that you make to us in this Contract:

You’re eligible to enter into this Contract and you are at least our “Minimum Age.”

The Services are not for use by anyone under the age of 16.

To use the Services, you agree that: (1) you must be the “Minimum Age”(described below) or older; (2) you will only have one LinkedIn account, which must be in your real name; and (3) you are not already restricted by LinkedIn from using the Services. Creating an account with false information is a violation of our terms, including accounts registered on behalf of others or persons under the age of 16.

“Minimum Age” means 16 years old. However, if law requires that you must be older in order for LinkedIn to lawfully provide the Services to you without parental consent (including using of your personal data) then the Minimum Age is such older age.

2.2 Your Account

You will keep your password a secret

You will not share an account with anyone else and will follow our rules and the law.

Members are account holders. You agree to: (1) use a strong password and keep it confidential; (2) not transfer any part of your account (e.g., connections) and (3) follow the law and our list of Dos and Don’ts and Professional Community Policies. You are responsible for anything that happens through your account unless you close it or report misuse.

As between you and others (including your employer), your account belongs to you. However, if the Services were purchased by another party for you to use (e.g. Recruiter seat bought by your employer), the party paying for such Service has the right to control access to and get reports on your use of such paid Service; however, they do not have rights to your personal account

2.3 Payment

You’ll honor your payment obligations and you are okay with us storing your payment information. You understand that there may be fees and taxes that are added to our prices.

Refunds are subject to our policy.

If you buy any of our paid Services (“Premium Services”), you agree to pay us the applicable fees and taxes and to additional terms specific to the paid Services. Failure to pay these fees will result in the termination of your paid Services. Also, you agree that:

Your purchase may be subject to foreign exchange fees or differences in prices based on location (e.g. exchange rates).
We may store and continue billing your payment method (e.g. credit card) even after it has expired, to avoid interruptions in your Services and to use to pay other Services you may buy.
If you purchase a subscription, your payment method automatically will be charged at the start of each subscription period for the fees and taxes applicable to that period. To avoid future charges, cancel before the renewal date. Learn how to cancel or suspend your Premium Services.
All of your purchases of Services are subject to LinkedIn’s refund policy.
We may calculate taxes payable by you based on the billing information that you provide us at the time of purchase.

You can get a copy of your invoice through your LinkedIn account settings under “Purchase History”.

2.4 Notices and Messages

You’re okay with us providing notices and messages to you through our websites, apps, and contact information. If your contact information is out of date, you may miss out on important notices.

You agree that we will provide notices and messages to you in the following ways: (1) within the Service, or (2) sent to the contact information you provided us (e.g., email, mobile number, physical address). You agree to keep your contact information up to date.

Please review your settings to control and limit messages you receive from us.

2.5 Sharing

When you share information on our Services, others can see, copy and use that information.

Our Services allow messaging and sharing of information in many ways, such as your profile, articles, group posts, links to news articles, job postings, messages and InMails. Information and content that you share or post may be seen by other Members, Visitors or others (including off of the Services). Where we have made settings available, we will honor the choices you make about who can see content or information (e.g., message content to your addressees, sharing content only to LinkedIn connections, restricting your profile visibility from search engines, or opting not to notify others of your LinkedIn profile update). For job searching activities, we default to not notifying your connections network or the public. So, if you apply for a job through our Service or opt to signal that you are interested in a job, our default is to share it only with the job poster.

We are not obligated to publish any information or content on our Service and can remove it with or without notice.

Rights and Limits

3.1. Your License to LinkedIn

You own all of the content, feedback and personal information you provide to us, but you also grant us a non-exclusive license to it.

We’ll honor the choices you make about who gets to see your information and content, including how it can be used for ads.

As between you and LinkedIn, you own the content and information that you submit or post to the Services, and you are only granting LinkedIn and our affiliates the following non-exclusive license:

A worldwide, transferable and sublicensable right to use, copy, modify, distribute, publish and process, information and content that you provide through our Services and the services of others, without any further consent, notice and/or compensation to you or others. These rights are limited in the following ways:

You can end this license for specific content by deleting such content from the Services, or generally by closing your account, except (a) to the extent you shared it with others as part of the Service and they copied, re-shared it or stored it and (b) for the reasonable time it takes to remove from backup and other systems.

We will not include your content in advertisements for the products and services of third parties to others without your separate consent (including sponsored content). However, we have the right, without payment to you or others, to serve ads near your content and information, and your social actions may be visible and included with ads, as noted in the Privacy Policy. If you use a Service feature, we may mention that with your name or photo to promote that feature within our Services, subject to your settings.

We will get your consent if we want to give others the right to publish your content beyond the Services. However, if you choose to share your post as “public, everyone or similar”, we will enable a feature that allows other Members to embed that public post onto third-party services, and we enable search engines to make that public content findable though their services.

While we may edit and make format changes to your content (such as translating or transcribing it, modifying the size, layout or file type or removing metadata), we will not modify the meaning of your expression.

Because you own your content and information and we only have non-exclusive rights to it, you may choose to make it available to others, including under the terms of a Creative Commons license.

You and LinkedIn agree that if content includes personal data, it is subject to our Privacy Policy.

You and LinkedIn agree that we may access, store, process and use any information and personal data that you provide in accordance with, the terms of the Privacy Policy and your choices (including settings).

By submitting suggestions or other feedback regarding our Services to LinkedIn, you agree that LinkedIn can use and share (but does not have to) such feedback for any purpose without compensation to you.

You promise to only provide information and content that you have the right to share, and that your LinkedIn profile will be truthful.

You agree to only provide content or information that does not violate the law nor anyone’s rights (including intellectual property rights). You also agree that your profile information will be truthful. LinkedIn may be required by law to remove certain information or content in certain countries.

3.2 Service Availability

We may change or end any Service or modify our prices prospectively.

We may change, suspend or discontinue any of our Services. We may also modify our prices effective prospectively upon reasonable notice to the extent allowed under the law.

We don’t promise to store or keep showing any information and content that you’ve posted. LinkedIn is not a storage service. You agree that we have no obligation to store, maintain or provide you a copy of any content or information that you or others provide, except to the extent required by applicable law and as noted in our Privacy Policy.

3.3 Other Content, Sites and Apps

Your use of others’ content and information posted on our Services, is at your own risk.

Others may offer their own products and services through our Services, and we aren’t responsible for those third-party activities.

By using the Services, you may encounter content or information that might be inaccurate, incomplete, delayed, misleading, illegal, offensive or otherwise harmful. LinkedIn generally does not review content provided by our Members or others. You agree that we are not responsible for others’ (including other Members’) content or information. We cannot always prevent this misuse of our Services, and you agree that we are not responsible for any such misuse. You also acknowledge the risk that you or your organization may be mistakenly associated with content about others when we let connections and followers know you or your organization were mentioned in the news. Members have choices about this feature.

LinkedIn may help connect Members offering their services (career coaching, accounting, etc.) with Members seeking services. LinkedIn does not perform nor employs individuals to perform these services. You must be at least 18 years of age to offer, perform or procure these services. You acknowledge that LinkedIn does not supervise, direct, control or monitor Members in the performance of these services and agree that (1) LinkedIn is not responsible for the offering, performance or procurement of these services, (2) LinkedIn does not endorse any particular Member’s offered services, and (3) nothing shall create an employment, agency, or joint venture relationship between LinkedIn and any Member offering services. If you are a Member offering services, you represent and warrant that you have all the required licenses and will provide services consistent with our Professional Community Policies.

Similarly, LinkedIn may help you register for and/or attend events organized by Members and connect with other Members who are attendees at such events. You agree that (1) LinkedIn is not responsible for the conduct of any of the Members or other attendees at such events, (2) LinkedIn does not endorse any particular event listed on our Services, (3) LinkedIn does not review and/or vet any of these events, and (4) that you will adhere to these terms and conditions that apply to such events.

3.4 Limits

We have the right to limit how you connect and interact on our Services.

LinkedIn reserves the right to limit your use of the Services, including the number of your connections and your ability to contact other Members. LinkedIn reserves the right to restrict, suspend, or terminate your account if you breach this Contract or the law or are misusing the Services (e.g., violating any of the Dos and Don’ts or Professional Community Policies).

3.5 Intellectual Property Rights

We’re providing you notice about our intellectual property rights.

LinkedIn reserves all of its intellectual property rights in the Services. Trademarks and logos used in connection with the Services are the trademarks of their respective owners. LinkedIn, and “in” logos and other LinkedIn trademarks, service marks, graphics and logos used for our Services are trademarks or registered trademarks of LinkedIn.

3.6 Automated Processing

We use data and information about you to make relevant suggestions to you and others.

We use the information and data that you provide and that we have about Members to make recommendations for connections, content and features that may be useful to you. For example, we use data and information about you to recommend jobs to you and you to recruiters. Keeping your profile accurate and up to date helps us to make these recommendations more accurate and relevant.

Disclaimer and Limit of Liability

4.1 No Warranty

This is our disclaimer of legal liability for the quality, safety, or reliability of our Services.

LINKEDIN AND ITS AFFILIATES MAKE NO REPRESENTATION OR WARRANTY ABOUT THE SERVICES, INCLUDING ANY REPRESENTATION THAT THE SERVICES WILL BE UNINTERRUPTED OR ERROR-FREE, AND PROVIDE THE SERVICES (INCLUDING CONTENT AND INFORMATION) ON AN “AS IS” AND “AS AVAILABLE” BASIS. TO THE FULLEST EXTENT PERMITTED UNDER APPLICABLE LAW, LINKEDIN AND ITS AFFILIATES DISCLAIM ANY IMPLIED OR STATUTORY WARRANTY, INCLUDING ANY IMPLIED WARRANTY OF TITLE, ACCURACY OF DATA, NON-INFRINGEMENT, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE.

4.2 Exclusion of Liability

These are the limits of legal liability we may have to you.

TO THE FULLEST EXTENT PERMITTED BY LAW (AND UNLESS LINKEDIN HAS ENTERED INTO A SEPARATE WRITTEN AGREEMENT THAT OVERRIDES THIS CONTRACT), LINKEDIN, INCLUDING ITS AFFILIATES, WILL NOT BE LIABLE IN CONNECTION WITH THIS CONTRACT FOR LOST PROFITS OR LOST BUSINESS OPPORTUNITIES, REPUTATION (E.G., OFFENSIVE OR DEFAMATORY STATEMENTS), LOSS OF DATA (E.G., DOWN TIME OR LOSS, USE OF, OR CHANGES TO, YOUR INFORMATION OR CONTENT) OR ANY INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL OR PUNITIVE DAMAGES.

LINKEDIN AND ITS AFFILIATES WILL NOT BE LIABLE TO YOU IN CONNECTION WITH THIS CONTRACT FOR ANY AMOUNT THAT EXCEEDS (A) THE TOTAL FEES PAID OR PAYABLE BY YOU TO LINKEDIN FOR THE SERVICES DURING THE TERM OF THIS CONTRACT, IF ANY, OR (B) US $1000.

4.3 Basis of the Bargain; Exclusions

The limitations of liability in this Section 4 are part of the basis of the bargain between you and LinkedIn and shall apply to all claims of liability (e.g., warranty, tort, negligence, contract and law) even if LinkedIn or its affiliates has been told of the possibility of any such damage, and even if these remedies fail their essential purpose.

These limitations of liability do not apply to liability for death or personal injury or for fraud, gross negligence or intentional misconduct, or in cases of negligence where a material obligation has been breached, a material obligation being such which forms a prerequisite to our delivery of services and on which you may reasonably rely, but only to the extent that the damages were directly caused by the breach and were foreseeable upon conclusion of this Contract and to the extent that they are typical in the context of this Contract.

Termination

We can each end this Contract, but some rights and obligations survive.

Both you and LinkedIn may terminate this Contract at any time with notice to the other. On termination, you lose the right to access or use the Services. The following shall survive termination:

Our rights to use and disclose your feedback;
Members and/or Visitors’ rights to further re-share content and information you shared through the Services;
Sections 4, 6, 7, and 8.2 of this Contract;
Any amounts owed by either party prior to termination remain owed after termination.

You can visit our Help Center to close your account.

Governing Law and Dispute Resolution

In the unlikely event we end up in a legal dispute, depending on where you live, you and LinkedIn agree to resolve it in California courts using California law, Dublin, Ireland courts using Irish law, or in your local courts using local law.

If you live in the Designated Countries, the laws of Ireland govern all claims related to LinkedIn’s provision of the Services, but this shall not deprive you of the mandatory consumer protections under the law of the country to which we direct your Services where you have habitual residence. With respect to jurisdiction, you and LinkedIn agree to choose the courts of the country to which we direct your Services where you have habitual residence for all disputes arising out of or relating to this User Agreement, or in the alternative, you may choose the responsible court in Ireland.

For others outside of Designated Countries, including those who live outside of the United States: You and LinkedIn agree that the laws of the State of California, U.S.A., excluding its conflict of laws rules, shall exclusively govern any dispute relating to this Contract and/or the Services. You and LinkedIn both agree that all claims and disputes can be litigated only in the federal or state courts in Santa Clara County, California, USA, and you and LinkedIn each agree to personal jurisdiction in those courts

General Terms

Here are some important details about the Contract.

If a court with authority over this Contract finds any part of it unenforceable, you and we agree that the court should modify the terms to make that part enforceable while still achieving its intent. If the court cannot do that, you and we agree to ask the court to remove that unenforceable part and still enforce the rest of this Contract.

This Contract (including additional terms that may be provided by us when you engage with a feature of the Services) is the only agreement between us regarding the Services and supersedes all prior agreements for the Services.

If we don’t act to enforce a breach of this Contract, that does not mean that LinkedIn has waived its right to enforce this Contract. You may not assign or transfer this Contract (or your membership or use of Services) to anyone without our consent. However, you agree that LinkedIn may assign this Contract to its affiliates or a party that buys it without your consent. There are no third-party beneficiaries to this Contract.

You agree that the only way to provide us legal notice is at the addresses provided in Section 10.

LinkedIn “Dos and Don’ts”

LinkedIn is a community of professionals. This list of “Dos and Don’ts” along with our Professional Community Policies limit what you can and cannot do on our Services.

8.1. Dos

You agree that you will:

Comply with all applicable laws, including, without limitation, privacy laws, intellectual property laws, anti-spam laws, export control laws, tax laws, and regulatory requirements;

2 Provide accurate information to us and keep it updated;

Use your real name on your profile; and
Use the Services in a professional manner.

8.2. Don’ts

You agree that you will not:

Create a false identity on LinkedIn, misrepresent your identity, create a Member profile for anyone other than yourself (a real person), or use or attempt to use another’s account;
Develop, support or use software, devices, scripts, robots or any other means or processes (including crawlers, browser plugins and add-ons or any other technology) to scrape the Services or otherwise copy profiles and other data from the Services;
Override any security feature or bypass or circumvent any access controls or use limits of the Service (such as caps on keyword searches or profile views);
Copy, use, disclose or distribute any information obtained from the Services, whether directly or through third parties (such as search engines), without the consent of LinkedIn;
Disclose information that you do not have the consent to disclose (such as confidential information of others (including your employer));
Violate the intellectual property rights of others, including copyrights, patents, trademarks, trade secrets or other proprietary rights. For example, do not copy or distribute (except through the available sharing functionality) the posts or other content of others without their permission, which they may give by posting under a Creative Commons license;
Violate the intellectual property or other rights of LinkedIn, including, without limitation, (i) copying or distributing our learning videos or other materials or (ii) copying or distributing our technology, unless it is released under open source licenses; (iii) using the word “LinkedIn” or our logos in any business name, email, or URL except as provided in the Brand Guidelines;
Post anything that contains software viruses, worms, or any other harmful code;
Reverse engineer, decompile, disassemble, decipher or otherwise attempt to derive the source code for the Services or any related technology that is not open source;
Imply or state that you are affiliated with or endorsed by LinkedIn without our express consent (e.g., representing yourself as an accredited LinkedIn trainer);
Rent, lease, loan, trade, sell/re-sell or otherwise monetize the Services or related data or access to the same, without LinkedIn’s consent;
Deep-link to our Services for any purpose other than to promote your profile or a Group on our Services, without LinkedIn’s consent;
Use bots or other automated methods to access the Services, add or download contacts, send or redirect messages;
Monitor the Services’ availability, performance or functionality for any competitive purpose;
Engage in “framing,” “mirroring,” or otherwise simulating the appearance or function of the Services;
Overlay or otherwise modify the Services or their appearance (such as by inserting elements into the Services or removing, covering, or obscuring an advertisement included on the Services);
Interfere with the operation of, or place an unreasonable load on, the Services (e.g., spam, denial of service attack, viruses, gaming algorithms); and/or
Violate the Professional Community Policies or any additional terms concerning a specific Service that are provided when you sign up for or start using such Service, and the Bing Maps terms where applicable.

Complaints Regarding Content

Contact information for complaint about content provided by our Members.

We respect the intellectual property rights of others. We require that information posted by Members be accurate and not in violation of the intellectual property rights or other rights of third parties. We provide a policy and process for complaints concerning content posted by our Members.

How To Contact Us

Our Contact information. Our Help Center also provides information about our Services.

For general inquiries, you may contact us online. For legal notices or service of process, you may write us at these addresses.

PRIVACY POLICY

Last updated July 19., 2023

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