PRIVACY POLICY SUMMARY
Thank you for visiting our website or otherwise engaging with us!  We encourage you to read our entire Privacy Policy for important information.  The following is a brief summary.

Information We Collect Automatically on our Website: Browsing and search history (such as pages visited, length of time on each page); language and version of your browser software; whether you are on a desktop or mobile; and your operating system.  The www.engage2excel.com website uses Google Analytics, Hubspot, LinkedIn Analytics, and Demandbase. The https://www.hinda.com/ website uses only Google Analytics. Google Analytics collects geolocation information, your IP address, country of origin, and other information about your visit to the website, but does not associate this information with your name. HubSpot tracks visitors on this website anonymously (using geolocation). If and when a visitor fills out a contact form, HubSpot will associate the visitor’s previous page views based on the tracking cookie. If the email address filled in the form is associated with an existing contact, this visitor will be identified as the contact. This includes contacts that were imported. When cookie tracking is accepted by the visitor, HubSpot will associate a cookie to their device and track their activity at the point of acceptance. If you are an applicant, we also collect information on which jobs you look at or apply for.  Please see Section 2 of this Policy.

Other Information We Collect: We do not knowingly collect other information about you unless you or your employer voluntarily provide it to us.  You may be asked to provide certain information, including your name, address, email address, phone number and product selection so that we can fulfill your product selection, address your concern, or respond to your question, and credit/debit card information if you are using a payment card to make a purchase.  If you are an applicant, you may be asked to submit certain information relevant to your job search, such as name, contact information, educational and work history, skills and interests, resume, and social security number.  If you are selecting a reward received through your employment, we also receive information about you from your employer, including your name, contact information, employer, birthday, hire date and seniority, and similar information relevant to the reward program.  Please see Section 2 of this Policy.

How We Use and Share Information: We use the information to fulfill or meet the reason you provided the information; communicate with you; send you marketing; improve our website, mobile applications, products and services; create and maintain your account with us; prevent transactional fraud; personalize your experience based on your use of the website; help maintain the safety, security, and integrity of our website, products and services, assets, and business; for testing, research, analysis, and technical and product development; as required by law or law enforcement or in connection with any ongoing or prospective audits, investigations or legal proceeding; to comply with contractual obligations; for, business continuity or disaster recovery; or to evaluate or conduct a merger or other corporate sale or restructuring.  If we receive your information through your employer’s relationship with us, we may use your information to provide services to your employer, process transactions, fulfill orders and provide analytics services.  We share your information internally to help fulfill your requests, with our service providers, our business partners, and with law enforcement if required by law.  If you are a candidate, we share your information with others subject to your consent.  Please see Section 8 of this Policy.

Your Choices:   You have certain rights with respect to accessing, correcting, transferring and deleting the information that we collect about you as set forth in Section 13 below or in the addendum to this Policy applicable to the state or country where you live.

Risks:  Although we do not intentionally share your information outside of the manner set forth in this Policy, and although we engage reasonable security measures, as with any website, we cannot guarantee that information submitted on this website will not be accessed by unauthorized persons.

By accessing or using the website or any related functionality or services, or by otherwise providing personal information to us, you acknowledge and agree to be bound by this Privacy Policy and consent to our collection, use, transfer and disclosure of your information as set forth below.  If you do not agree with these terms and conditions (including any opt-out rights), you may not submit any information and you must stop using the Site.

If you have questions, our contact information is in Sections 13 and 19 of this Policy or see the applicable addendum for your jurisdiction.

1. INTRODUCTION AND SCOPE

Scope

In this Policy, the terms “Engage2Excel,” “we,” “ours” or “us” refer to Engage2Excel, Inc. d/b/a/ Engage2Excel on behalf of itself and any direct and indirect subsidiaries, including its wholly-owned subsidiary Hinda Inc., and the terms “you” and “your” refer to you.

This Policy covers information submitted to Engage2Excel and its affiliated companies electronically or otherwise in writing as well, for example (and without limitation) through engage2excel.com (the “Site”) or by email. This policy outlines responsibilities and requirements for the implementation and maintenance of a privacy program at Engage2Excel and lets you know how Engage2Excel processes and uses your personal information.  The privacy program is designed to apply to all personally identifiable information of consumers, employees of our rewards program clients, and website visitors in the United States and Canada. This Site is not intended to promote our products or services to individuals in other countries, including the European Union.  This Policy does not apply to (i) information collected or received from individuals who are employees of Engage2Excel acting in or related to their capacity as an employee outside of their interaction with this Site; (ii) individuals who are independent contractors or consultants of Engage2Excel outside of California, acting in or related to their capacity as a contractor or consultant; and (iii) information collected or received through third party websites.  If you connect to other websites through this Site, please understand that Engage2Excel does not operate or control those other websites and this Policy does not apply to information collected through those sites.

By accessing or using the Engage2Excel websites or any related functionality or services, and by emailing and submitting information to Engage2Excel, you acknowledge and agree to be bound by this Privacy Policy and consent to our use of your information as set forth below.  If you do not agree with these terms and conditions, you should not submit any information and you should stop using this Site.  If we obtained your permission to place you on a marketing email list, you can remove yourself from the list as set out in the “Your Rights“ section below. You can also remove yourself from an email marketing list by clicking the “unsubscribe” button that appears on our emails.

Information collected on this Site, including information that you submit, is maintained and processed in the United States and in Canada.  By submitting your personal information to us on or through this Site, you agree to the maintenance, processing, transfer, and storage of your information in these countries, and you acknowledge that such privacy laws may offer different protection from those in your home jurisdiction. You acknowledge and agree that your personal information may also be subject to access by and disclosure to law enforcement and government agencies in the United States, or elsewhere, as applicable.

2. INFORMATION WE COLLECT ABOUT YOU

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, visitor or device (“personal information”). In particular, we collect (and have collected within the last 12 months) the following categories of personal information from consumers and visitors to this Site:

Identifiers such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. Social security numbers may be collected from applicants if requested on the employment application.

Contact information and background information such as name, signature, address, telephone number, education, employment, employment history. Some personal information included in this category may overlap with other categories.

Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Internet or other similar network activity, including browsing history, search history, operating system, country of origin, type of device (desktop or mobile), information on a consumer’s interaction with a website, application, or advertisement.

Professional or employment related information such as current or past job history or performance evaluations, education history, and resumes, and, if you are a job applicant, we may build skill profiles on a non-automated basis based on information provided by you.

Geolocation data includes the general location associated with your IP address (but not within 1850 feet of your location).

Sensitive personal information, including social security numbers, may be collected from applicants if requested on the employment application and the applicant voluntarily provides it.  Credit card and debit card numbers in combination with required security code may be collected if you use a credit or debit card received as a reward to purchase something from us.

Engage2Excel may use non-personal and non-identifiable (anonymized) summarized, derived, or aggregate information in any manner to the fullest extent permitted by applicable law.

3. SOURCES OF INFORMATION

Engage2Excel obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete, documents you provide, or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Site and/or from cookies on our Site.
• From your employer. For example, if you are selecting a reward from us through a program with your employer.

Engage2Excel also collects personal information when you interact with us or apply for a position with us. The personal information we collect about you will vary by context and may include:

o  Your name and contact details;

o  Your professional background;

o  Company name;

o  Your stated and inferred interests;

o  Your resume;

o  Credit or debit card number, security code and expiration date, your name, email and mailing address (for example if you use a credit or debit card received as a reward to purchase a product on our Site so that we can fulfill your request and notify you with confirmation or update messages); and

o  Your activity on the Site, both in terms of transactions (such as order history) and in terms of otherwise interacting with the Site (e.g., behavioral patterns).

o  Social security numbers may be collected from applicants if requested on the employment application.

If you are selecting a reward received through your employment, we also receive information about you from your employer, including your name, contact information, employer, birthday, hire date and seniority, and similar information relevant to the reward program.

Engage2Excel offers access to services on its Site that require registration and authentication using your username and password or certification, such as Recruiting Machine, Channel Partners, Data on Demand, Online Ordering, and Enterprise Recognition.  When you register for an account, we require the following information from you: username, email address, and password or certificate.

4. USE OF COOKIES ON THE ENGAGE2EXCEL WEBSITE

This Site may send a “cookie” to your computer. A cookie is a small piece of data sent to your browser and stored on your computer’s hard drive. A cookie cannot read data from your hard drive or read cookie files created by other websites. Engage2Excel uses cookies to identify which areas of the Engage2Excel website you have visited or customized so that those pages can be made readily available to you on your next visit.

The Services also may use data collection tools to collect information from the device used to access the Services, such as operating system type, browser type, domain and other system settings, as well as the operating system used and the country and time zone in which the computer or device is located.

For example, Engage2Excel Inc., and including Hinda Inc. utilize Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of our website (such as how often users visit this site and what pages they visit) and report on activities and trends.  Google Analytics collects specific information such as IP address rather than your name or other personally identifying information.  Google does put a cookie on your web browser to identify you as a unique user the next time you visit this site.  You can learn about Google’s practices by going to www.google.com/policies/privacy/partners and opt-out from the collection of your information by downloading the Google Analytics opt-out browser add-on https://support.google.com/analytics/answer/181881?hl=en.

We give users certain choices regarding cookies.  You can manage your cookie preferences by clicking on the “Cookie Preferences” link at the bottom of this website’s homepage.

Most browsers allow you to refuse to accept cookies. Blocking all cookies may have a negative impact upon the usability of some websites. If you block cookies, you may not be able to use all the features on our Site.

5. TRACKING

Some web browsers incorporate a “Do Not Track” feature (DNT) that signals to the websites that you visit that you do not want to have your online activity tracked. Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. We do not respond to web browser DNT signals.  If you would like additional information about online tracking and various opt-out mechanisms, please see https://allaboutdnt.com/  If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. These third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted advertising from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

6. USING YOUR PERSONAL INFORMATION

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information and/or use a debit or credit card received as a reward through your employment for a product or service on our Website, we will use that information to process the payment and facilitate delivery. We may also save your information to facilitate new product orders, notify you of a delivery or process returns.
• To provide advertising and marketing services, except for cross-context behavioral advertising.
• To send you non-marketing commercial communications.
• To send you email notifications that you have specifically requested.
• To send you marketing communications relating to our business or the businesses of carefully selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests based on your use of
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and technical and product development, including to develop and improve our Website, mobile applications, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To the extent that we are required to do so by law.
• To assess and manage risk.
• In connection with any ongoing or prospective legal proceeding.
• To facilitate internal audits, dispute resolution and investigations.
• To keep records of transactions.
• For business continuity and disaster recovery.
• As described to you when collecting your personal information.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Engage2Excel’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Engage2Excel about our Website users is among the assets transferred, in accordance with the requirements of applicable laws.
• To perform services on behalf of your employer who is our customer, including maintaining or servicing your employer’s accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytic services, or providing similar services.

 

Engage2Excel will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice and obtaining your consent, where required by law.  If you believe that we have impermissibly used your personal information, you may object to such use by contacting us.

Use and Disclosure of Sensitive Personal Information.

Engage2Excel may use or disclose sensitive personal information collected on this Site to provide the goods and services requested by you, evaluating you for employment (if you apply for a position with us), to detect security incidents, to resist malicious, deceptive, fraudulent or illegal actions directed at the business, or to perform services on behalf of Engage2Excel, such as customer service, processing or fulfilling orders or transactions, processing payments, analytic services, and similar services.

7. EMAIL AND TEXT COMMUNICATIONS

For United States residents, we undertake marketing only in compliance with the CAN-SPAM Act, the Telephone Consumer Protection Act, and other applicable law. For Canadian residents, we may send you commercial emails and texts if you have purchased goods or services from us in the prior two years or if you have an existing written contract with us, or if you expressly consented.  European Union (EU) residents, we undertake marketing to your email or phone only with your express affirmative consent and in compliance with applicable data privacy laws. EU residents will not be added to the marketing lists unless they have already provided express affirmative consent consistent with applicable data protection laws.

8. DISCLOSING PERSONAL INFORMATION

Engage2Excel may disclose your personal information to our service providers with whom we have a contract to process your personal information for a specific business purpose, such as to help us provide our services to you, to deliver to you the product that you selected, or to protect or improve our website.  These service providers include shipping vendors; customer service vendors; order fulfillment companies; product creation vendors; consumer and market research service providers; and fraud detection, security and technical support providers. We may disclose your credit or debit card information to our payment card processors in connection with the processing of the transaction where applicable. As noted above, Google Analytics has access to certain information about your use of the Site for purposes of providing analytics to us.  We may also disclose your personal information for a business purpose to our contractors with whom we have a contract, including professional advisors and insurers.  When we disclose personal information to a service provider or a contractor, we enter a contract with it that requires it to use the information only for that business purpose and prohibits it from taking certain actions with your information, such as selling your information and from sharing it with others for cross-context behavioral advertising.

Your personal information may be used or stored by us or our service providers and our corporate affiliates in the U.S.A., Canada, or other countries.  We require that our service providers and our corporate affiliates safeguard your personal information. However, your personal information could be subject to the laws of the country in which it is stored.

We also disclose your personal information (and sensitive personal information if applicable) with the following categories of third parties:

• Prospective employers, if you are an applicant using our Recruitment Solutions Services.
• Your current employer if the employer is a client of Engage2Excel.
• Other third parties to facilitate and conduct internal audits, dispute resolutions, investigations and remediation, for fraud detection, to comply with various laws or pursue our legal rights or facilitate our merger or acquisition activities.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose.  These categories are more fully described in the “Information We Collect About You” Section in this Privacy Policy.

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category I: Employment History.

Category L: Sensitive Personal Information.

Sales or Sharing of Personal Information

Engage2Excel does not knowingly disclose your personal information to third parties for money or other valuable consideration.

In the preceding twelve (12) months, Engage2Excel has not sold or shared personal information, as defined by the California Privacy Rights Act.

We do not sell or share Personal Information to third parties or process Personal Information for purposes of targeted advertising, as defined by the Colorado Privacy Act, the Connecticut Data Privacy Act, the Virginia Consumer Data Protection Act, and the Utah Consumer Privacy Act.

9. RETAINING PERSONAL INFORMATION

Our intent is to not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information, and in most cases we use the purpose for which we collected the personal information to determine the length of time that we need to retain it.  In some instances, such as when required by law or authorized by you, we may retain the information for a longer period.

Notwithstanding the any other provisions we will retain documents (including electronic documents) containing personal data:

1. to the extent that we are required to do so by law;
2. if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
3. to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to conclude that the purposes for which that information is in our possession are no longer being served by retention of the information and retention is no longer necessary for legal or business purposes. We will take due care when destroying personal information so as to prevent unauthorized access to the information.

10. SECURITY OF YOUR PERSONAL INFORMATION

1. We will take reasonable technical, administrative and organizational precautions designed to prevent the loss, misuse, or alteration of your personal information;
2. Under our policies, all personal information should be stored on secure (password- and firewall-protected) servers;
3. All electronic financial transactions entered through our website will be protected by encryption technology;
4. While we implement security measures to help safeguard your data, no physical or electronic security system is impenetrable. We cannot guarantee the security of our servers or databases, the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet; and
5. You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).

11. CHILDREN’S PRIVACY

This Engage2Excel website is not intended for children. We do not knowingly collect personal information directly from children under the age of 16, and in the event that we learn that a child under the age of 16 has provided information, we will delete that information as soon as possible.  If you are the parent or guardian of a child under the age of 16 and believe that they have provided us with personal information, you may contact us by one of the methods set forth below and request deletion of the data.

12. DATA QUALITY, STORAGE, AND ACCESS

While our goal is to ensure that all information we hold about you is accurate, complete and up to date, you can help us by promptly notifying us if there are any changes to your personal information. Please let us know if the personal information that we hold about you needs to be corrected or updated. You can also update your information by visiting your account information page.

13. YOUR RIGHTS

We provide users with the following rights:  (i) to request access to and rectification or erasure of their personal data; (ii) to obtain restriction of processing or to object to processing of their personal data;  (iii) to data portability; and (iv) to deletion of personal data. Individuals may also have the right to lodge a complaint about the processing of personal data with a data protection authority.  These rights are explained in more detail below.

• Marketing E-mails: You may sign up for our mailing list in order to receive promotional and other materials that may be of interest to you. If you do not want to receive marketing, advertising or promotional emails from us in the future, you can opt-out via the opt-out link found on any of the emails you have received from us. This opt-out applies to marketing, advertising and promotional emails only and does not impact online or digital advertising that does not rely on your email address and does not apply to emails that we may send to you primarily regarding your account or transactions with us.
• Text Messaging and Alerts: Unless prohibited by applicable law, US residents agree that by submitting your telephone number on any of our Sites, you expressly consent (opt-in) to receiving marketing and informational texts and calls, including without limitation auto dialed or pre-recorded messages, to the telephone numbers that you provide, including any mobile telephone number, by us or others on our behalf. Different requirements may apply in Canada. Such messages may include responses to your requests for information on the Services, appointment and account status and reminders, alerts, fraud prevention or investigation efforts, and/or information about promotions, new products and events.  We also may provide you with other opportunities to opt-in to receiving such text messages on the mobile phone number(s) you have shared with us. We will not contact you via text messages or alerts for marketing purposes without your prior affirmative consent.
  You do not have to opt-in to text messages and alerts to use the services on this Site or to make purchases.  If you opt-in, standard messaging and data rates may apply. You can always opt-out of text messages by replying STOP and can adjust the settings on your mobile device to turn off push notifications. For more information regarding our text messaging and alerts, please contact us the email or number set forth in the “Contact Information” section below.
• Cookies Settings and Preferences: You may disable cookies and other tracking technologies through the settings in your browser. While doing so may negatively affect your experience with the use of our Sites, it will not prevent us from transacting with you.
• Automated Decision-Making: You have the right to opt out of Engage2Excel’s use of automated decision-making technology for profiling, with respect to your personal information. See below for the process for submitting a verifiable consumer request to opt-out of such automated decision-making.
• Complaint: You may contact us using the information below if you have any questions, or would like to submit a complaint about our practices.
• Access to Specific Information and Data Portability Rights. You can request that Engage2Excel provide certain information to you about our collection and use of your personal information over the past 12 months or such other period required by applicable law. Once we receive and confirm your verifiable consumer request, subject to applicable exemptions, we will disclose to you:

• • The categories of personal information we collected about you, including sensitive personal information (if any).
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or sharing that personal information. We will also disclose our business or commercial purpose if E2E engages in selling of personal information in the future.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you.
  • In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:
    • The categories of personal information about you that we sold or shared (if any) and the categories of third parties to whom the personal information was sold or shared; and
    • The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose.

You may also request that Engage2Excel deliver the specific pieces of personal information obtained from you in a format that is easily understandable, subject to certain exceptions.  If we cannot comply with your request, we generally will provide an explanation of why we cannot do so in the particular context, such as if responding to the request would be unreasonably expensive.

• Correction. You have the right to request correction of inaccurate personal information maintained by us about you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information. In addition, users with accounts with us may access, verify the accuracy of, update or change the information that they submitted to a Site by logging into their account and editing the information, as applicable.

If appropriate, we will send the amended information to third party service providers or other third parties to whom the information has been disclosed.

• Deletion Request Rights,

You have the right to request that Engage2Excel delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
3. Debug products to identify and repair errors that impair existing intended functionality;
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
8. Comply with a legal obligation; or
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If you are not a resident in one of the jurisdictions that afford you these rights under the jurisdictions’ laws, we will normally afford you the same control over your information on a voluntary basis unless we deem it unreasonably burdensome for us to do so.

To exercise the rights described above, please submit a verifiable consumer request to us by either:

• Complete a data subject request form available here https://e2egroup-privacy.my.onetrust.com/webform/e770dd15-9844-40e2-9168-db9957989ac2/044abd2a-2f47-4b50-9545-9f9f9d857af5 ; or
• Emailing us at us-privacy@Engage2Excel.com

Only you may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.  In particular, a California consumer may authorize a person registered with the California Secretary of State to act on their behalf.

Your authorized agent may submit a request by completing our webform, available here  https://e2egroup-privacy.my.onetrust.com/webform/e770dd15-9844-40e2-9168-db9957989ac2/044abd2a-2f47-4b50-9545-9f9f9d857af5 . To protect the privacy and security of your data, we may contact you or your authorized agent to collect additional data to verify your identity, your agent’s authorization and to verify the request.

Consumers have the right to appeal our decisions on their data subject requests. To appeal our decision on your data subject requests, please email us-privacy@Engage2Excel.com. Please enclose a copy of or otherwise specifically reference our decision on your data subject request, so that we may adequately address your appeal. We will respond to your appeal in accordance with applicable law.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period or such other period required by applicable law. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Unless a shorter period is required by applicable law, we endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing. We may withhold personal information that you request to the extent permitted by law.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period or such other period required by applicable law preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

You may instruct us at any time not to process your personal information for marketing purposes.

14. ADDITIONAL DISCLOSURES FOR NEVADA RESIDENTS

Under Nevada law, Nevada residents may opt out of the sale of certain “covered information” collected by operators of websites or online services. We currently do not sell covered information, as “sale” is defined by such law, and we don’t have plans to sell this information. However, if you would like to be notified if we decide in the future to sell personal information covered by the Act, please email us-privacy@Engage2Excel.com to provide your name and email address. You are responsible for updating any change in your email address by the same method and we are not obligated to cross-reference other emails you may have otherwise provided us for other purposes. We will maintain this information and contact you if our plans changes. At that time, we will create a process for verifying your identity and providing an opportunity to verified consumers to complete their opt-out. Please become familiar with our data practices as set forth in this privacy policy. We may share your data as explained in this privacy policy, such as to enhance your experiences and our services, and those activities will be unaffected by a Nevada do not sell request. You may also have other choices regarding our data practices as set forth elsewhere in this privacy policy.

15. ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to us-privacy@Engage2Excel.com.

16. PROTECTION AGAINST DISCRIMINATION

You have the right not to be discriminated against by us because you exercised any of your rights. This means we cannot, among other things:

• Deny goods or services to you;
• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Provide a different level or quality of goods or services to you; or
• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate, or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to us by your personal information.

17. AMENDMENTS

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you understand any changes to this policy. We may notify you of changes to this policy by email or through the private messaging system on our website.

18. INDIA PRIVACY RIGHTS

Residents of India, please also see the addendum to this policy located here: https://www.engage2excel.com/additional-disclosure-for-india-residents/

19. THIRD-PARTY WEBSITES

Our website may include hyperlinks to, and details of, third-party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

Our Site also may have links to and embedded video from YouTube. Engage2Excel’s website uses YouTube’s API services in connection with embedding video thumbnail images and descriptions provided by YouTube LLC (“YouTube”). As such, you acknowledge and agree that by accessing the videos linked through the embedded video thumbnail images and descriptions, you are also bound by YouTube’s Terms of Service and Google’s Privacy Policy. Using YouTube’s offering requires a connection to be established to YouTube’s servers in the United States. During this process, certain information is transmitted to YouTube. We do not control the collection, storage or use of any of your information by YouTube and do not have access to any information collected. You should review Google’s and YouTube’s Privacy Policies carefully before you use any YouTube features. Further information about how your data are collected and used by YouTube and your rights in relation to this can be found in Google/YouTube’s privacy policy at https://policies.google.com/privacy?hl=en-GB.  By loading an embedded video or otherwise linking to one of these sites, the sites (and their advertising partners) may be able to compile information about you.    We are not responsible for the content, the security or the privacy practices employed by other sites.  Such third party sites are not under our control, and we do not endorse or make any representation regarding any information, software or other materials on such third party sites. Access and use of these sites is at your own risk.

20. ADDITIONAL INFORMATION

Please also refer to the website’s Terms and Use for more information about the Engage2Excel website.

Effective Date: 2/1/2024

Contact information: Engage2Excel.com – us-privacy@Engage2Excel.com

Original approval: 12/19/2023