PRIVACY POLICY

Effective Date: September 25, 2021

1. WELCOME

Thank you for reviewing our Privacy Policy. We are GETTR USA Inc. (referred to here as "GETTR," "we," "us," or "our"), and one of our core values is to act as your trusted partner. We respect privacy and your rights to control your personal data. Our Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the website GETTR.com (the "Site") or any mobile or desktop app we may offer (the "Apps") (both the Site and Apps together, the "Services") and our practices for collecting, using, maintaining, protecting, and disclosing that information. Our Privacy Policy also describes choices you can make about how we collect, use and share your personal data.

2. INFORMATION WE COLLECT

A. Information You Provide.

You do not have to provide personal information (PI) to access or use the Services. However, to take full advantage of the Services, you may choose to furnish us with PI through the Service. For example, if you contact us through the website "Contact us" form or create an account, you may be asked to provide contact information such as your name or email address.

We will only collect such PI through the Services when you provide it to us voluntarily. The PI we collect on or through our Services may include:

Information that you provide by filling in forms on our Services.

This includes information provided at the time of creating an account, subscribing to our communications, posting material, contacting us, or requesting further services. Such voluntarily provided information may include your name, email address, mailing address, and photograph)
Records and copies of your correspondence (including email addresses), if you use the Services to contact us or communicate with other users
Your search queries on the Services
Other information you choose to provide to use when using the Services

You also may provide information to be published or displayed or otherwise "posted" on public areas of the Services or transmitted to other users of the Services or third parties (collectively, "User Contributions"). If you wish to use the App to record video or audio User Contributions, the App may request your permission to access your device's camera and/or microphone. Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. We cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

B. Information Collected Automatically.

As you navigate through and interact with our Services, we may use automatic data collection technologies such as cookies, web beacons (also known as "tracking pixels"), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, in-app tracking methods, and other tracking technologies now and later developed (collectively, "Tracking Technologies") to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Services, including traffic data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer or device and internet connection, including your operating system and browser type.

The information we collect automatically is only statistical data and does not include PI, but we may maintain it or associate it with PI we collect in other ways or receive from third parties. It helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website.

3. USE OF YOUR INFORMATION

A. Our Use of Your Information.

We may use the PI that we collect about you or that you provide for legitimate business purposes, including:

To provide you with our Services, content, and any other information, products or services that you request from us.
To fulfill any other purpose for which you provide it.
To provide you with notices about your account.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Services or about any products or services we offer or provide though them.
To allow you to participate in interactive features on our Services.
To verify the identity of account holders.
To resolve disputes or troubleshoot problems.
In any other way we may describe when you provide the information.
For any other purpose with your consent.
We may use your PI, alone or in combination with other automatically collected information, for purposes of protecting the security and proper functioning of the Website, fraud detection and prevention, and similar purposes.

We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, you can opt-out of receiving these communications by managing your preferences in your account profile.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your PI for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

B. How We May Share Your Information.

We may disclose PI that we collect or that you provide as described in this privacy policy:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business, such as payment processors, who are bound by contractual obligations to keep PI confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which PI held by Us about our Website users is among the assets transferred.
To fulfill the purpose for which you provide it. For example, if you give us an email address to use the "email a friend" feature of our Services, we will transmit the contents of that email and your email address to the recipients.
For any other purpose disclosed by us when you provide the information.
With your consent.
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

GETTR may implement Google's Invisible reCAPTCHA technology on our Services to reduce spam and prevent abuse of our Services. Your use of the Invisible reCAPTCHA is subject to Googles' privacy policy here and Google's terms of service here.

4. SWEEPSTAKES, CONTESTS AND PROMOTIONS

We may offer sweepstakes, contests, and other promotions (we refer to each of them as a "Promotion"), including any Promotion jointly sponsored or offered by third parties, which may require submitting your information. If you voluntarily choose to enter a Promotion, your information, including personal information, may be disclosed to GETTR, Promotion co- sponsors, service providers, and other third parties, including for administrative purposes and as required by law (on a winners list, for example). By entering, you are agreeing to the official rules that govern that Promotion, which may include consent to additional or differing data practices that will take precedence over those contained in our Privacy Policy in case of a conflict. Please review those official rules carefully.

5. THIRD-PARTY SERVICES AND SOCIAL FEATURES

Certain functionalities on the Services may permit interactions that you initiate between the Services and other websites, locations, platforms, applications, or services operated by third parties (collectively, "Third-Party Services") such as third-party social networks ("Social Features"). Examples of Social Features include enabling you to connect the Services to a Third-Party Service to pull or push information to or from the Services. If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Services or by the Third-Party Services that you use. If you post information on a Third-Party Service that references the Services (by using a hashtag associated with our family of affiliated companies in a tweet or status update, for example), your post may be used on or in connection with the Services or otherwise by our family of affiliated companies. GETTR and third parties may have access to certain information about you and your use of the Services and any Third-Party Services.

6. YOUR CHOICES

A. Opting Out of Promotional Communications.

You can make choices about how your information may be used by us to provide information and offers to you. You may opt out of commercial messages by clicking on the "opt out" or "unsubscribe" link provided with each message. These preferences do not apply to transactional communications, such as those that are related to your registration with us, required or important notices related to your use of our Services, or the fulfillment of a specific transaction.

B. Opting Out of Providing Personal Information Through the Apps.

You may be able to enable or disable certain permissions features (allowing the App to read, modify, or delete the contents of your USB storage; take pictures and videos; or view Wi-Fi connections, for example) by adjusting the permissions in your device. If you no longer want to provide any information to us through the Apps, you may uninstall them from your device.

C. Accessing and Changing Information.

We may provide web pages, other mechanisms or processes allowing you to delete, correct, or update some of the personal information that we collect from you, and potentially certain other information about you (profile and account information, for example). We will make good faith efforts to make requested changes in our then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all your information or public postings from our databases and residual and/or cached data may remain archived thereafter. We reserve the right to retain data: (a) as required by laws that apply to us; and (b) except when the laws that apply to us do not allow, for so long as we need it to reasonably achieve the purposes for which your data is maintained.

D. Your Tracking Technologies Choices.

Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Please be aware that if you disable or remove these technologies, some parts of the Services may not work and that when you revisit the Services your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.

Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer. Apple and Google mobile device settings have settings to limit ad tracking, and other tracking, but these may not be completely effective.

Your browser settings may allow you to automatically transmit a "Do Not Track" signal to online services you visit. Note, however, there is no consensus among industry participants as to what "Do Not Track" means in this context. Like many online services, we currently do not alter our practices when we receive a "Do Not Track" signal from a visitor's browser. To find out more about "Do Not Track," you can visit here, but please know we cannot take responsibility for the completeness or accuracy of this or any third-party information.

Many advertisers and service providers that may perform advertising-related services for us and third parties participate in voluntary programs that provide tools to opt-out of such interest-based advertising such as the Digital Advertising Alliance's ("DAA") Self- Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising for DAA members, visit here. Some of these companies also are members of the Network Advertising Initiative ("NAI"). To learn more about the NAI and your opt-out options for their members, see here.

Please be aware that, even if you can opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected, participating members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (from other ad networks, for example). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (mobile app, for example), your browser-based opt-out may not, or may no longer, be effective.

E. Analytics.

We may use Third-Party Services such as Google Analytics to help us analyze our performance and our delivery of Services and advertising to you. You may exercise your choices regarding the use of cookies by Google Analytics by using the Google Analytics Opt-out Browser Add-on or by going to here and following the instructions.

7. LINKS AND OTHER SITES

Our Privacy Policy applies only to our information practices on the Services. Our Privacy Policy does not apply to the other websites and social media websites you access and use, including those you may access from the Services. Other websites or apps may have their own privacy policies or notices that you should review to understand how they may collect, use, or disclose your personal information. GETTR is not responsible for the content or privacy practices of any linked websites that it does not control.

8. SECURITY

We take steps to help protect your personal information. We require password protection as well as physical, electronic, and procedural safeguards to protect personal information. We limit access to personal information to employees and authorized users who need to know that information to operate, develop or improve our Services. However, we cannot guarantee that your information will never be disclosed in a manner inconsistent with our Privacy Policy (because of unauthorized acts by third parties that violate law applicable to us or our policies, for example).

9. CHANGES TO THIS PRIVACY POLICY

We may our Privacy Policy from time to time, so please review our Privacy Policy from time to time, too. If our Privacy Policy changes, we will post the revised Privacy Policy on our Services. We will indicate changes to the Privacy Policy by updating the "Effective date" at the beginning of the Privacy Policy. Your continued use of this Site after any update to this Privacy Policy will constitute your acceptance of the changes.

10. HOW TO CONTACT US

If you have questions or concerns that do NOT directly relate to our Privacy Policy or its implementation and you are a user of our platform, please contact us by opening a support ticket, and review the useful information about our platform available in our Help Center at support.gettr.com.

Copyright and trademark infringement-related notices and inquires only: please contact DMCArep@gettr.com.

Official requests from law enforcement authorities: please contact legal@gettr.com.

Press inquiries: please contact press@gettr.com.

Interested in working at GETTR? Inquiries about job openings should be addressed to: jobs@gettr.com and info@gettr.com.

If you have any questions or concerns about our Privacy Policy or its implementation, or if you believe there are inaccuracies in your account information, please contact us at privacy@gettr.com.

11. JURISDICTION-SPECIFIC TERMS

A. For Users Located in the European Economic Area ("EEA") and/or the United Kingdom ("UK").

I. Controller of your Personal Data.

The controller of your personal data under our Privacy Policy is GETTR USA, Inc., with an address of GETTR USA, Inc., c/o LegalInc Corporate Services Inc., 651 N. Broad St., Suite 206, Middletown, DE 19709.

II. Purposes and Legal Bases for Using Personal Data.

We process your personal data only if we have a legal basis to do so, including:

to comply with our legal and regulatory obligations;
for the performance of our contract with you or to take steps at your request before executing a contract;
for our legitimate interests or those of a third party; and
where you have given consent to our specific use.

The purpose for which we use and process your information and the legal basis on which we carry out each type of processing is further explained here:

Purposes for processing the information	Legal basis for processing the information
To deliver Services and features you desire.	It is necessary for us to process your personal data to deliver the Services and process transactions according to the applicable contract between us.
To improve our Services to you.	It is necessary for us to process your personal data to improve our Services to you according to the applicable contract between us.
To personalize content and offers and serve you advertising that may be of interest to you.	We will personalize content and offers to you and serve you advertising based on your interests and online activities if you have consented to this processing.
To respond to your inquiries.	It is necessary for us to process your personal data in this manner to respond to your inquiries according to the applicable contract between us.
To fulfill your request for products or Services.	It is necessary for us to process your personal data to fulfill your request for products or Services according to the applicable contract between us.
To provide you with updates and other information regarding the Services.	It is necessary for us to process your personal data to provide you with updates and other information regarding the Services according to the applicable contract between us.
To share your information with the third party that employed you, engaged you, or authorized you to access and use the Services.	It is in the legitimate interests of the third party that employed you, engaged you, or authorized you to access and use the Services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
To analyze statistically Service usage and to customize our Service’s content, layout and services.	It is in our legitimate interests to process your personal data to analyze our Service usage and to customize our Service’s content, layout and services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
To enable our service providers to perform certain activities on our behalf.	It is necessary for us to process your personal data in this manner to deliver the Services and process transactions according to the applicable contract between us. It is also in our legitimate interest to enable our service providers to perform certain activities on our behalf. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
To administer our Services, including troubleshooting, data analysis, testing, research, statistical and survey purposes.	For all these categories, it is in our legitimate interest to continually monitor and improve our Services and your experience of the Services and to ensure network security. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
To keep our Services safe and secure and to prevent detect fraud and abuse; and to comply with our legal obligations, policies, and procedures. We may process your personal data to respond to: governmental requests or legal process (a court order, search warrant or subpoena, for example); to other circumstances in which we have a good faith belief that a crime has been or is being committed by a user; an emergency that poses a threat to the safety of you or another person; protect our property; and in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, asset sale or in the unlikely event of bankruptcy.	We conduct this processing to comply with our legal obligations and to protect the public interest.
To process otherwise for internal administrative and analytics purposes.	It is in our legitimate interest to process your personal data for internal administrative or analytics purposes. We consider this use to be proportionate and will not be prejudicial or detrimental to you.

III. International Transfers.

Some of our processing of your data will involve transferring your data outside the EEA or UK, as applicable. Some of our service providers are also based outside of the EEA or UK, and their processing of your personal data will involve a transfer of data outside the EEA or UK, applicable. This specifically includes to the United States. Where personal data is transferred to and stored in a country not determined by the European Commission as providing adequate levels of protection for personal data, we take steps to provide appropriate safeguards to protect your personal data, including entering into standard contractual clauses approved by the European Commission, obliging recipients to protect your personal data.

IV. Retention of Personal Data.

GETTR will retain your personal data only for as long as necessary for the purposes it was retained, such as to enable you to use the Services. In some instances, we may retain data for longer periods to comply with applicable laws (including those regarding document retention), resolve disputes with any parties, and otherwise as necessary to allow us to conduct our business. All personal data we retain will be subject to our Privacy Policy and our internal retention guidelines.

V. Data Subject Access Rights.

You have the following rights:

Right of access to your personal data: You have the right to ask us for confirmation on whether we are processing your personal data, and access to such personal data and related information.
Right to correction: You have the right to have your personal data corrected, as permitted by law.
Right to erasure: You have the right to ask us to delete your personal data, as permitted by law.
Right to withdraw consent: You have the right to withdraw consent that you have previously provided.
Right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with a supervisory authority in the member state of your habitual residence.
Right to restriction of processing: You have the right to request the limiting of our processing under limited circumstances.
Right to data portability: You have the right to receive the personal data that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible.
Right to object: You have the right to object to our processing of your personal data, as permitted by law, under limited circumstances.

To exercise any of these rights, please contact us privacy@gettr.com or GETTR USA, Inc., ATTN: Privacy Rights, GETTR USA, Inc., c/o LegalInc Corporate Services Inc., 651 N. Broad St., Suite 206, Middletown, DE 19709. Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.

B. California Consumer Privacy Rights.

I. The California Consumer Privacy Act ("CCPA") provides California Consumers certain rights regarding their personal information ("PI") as those terms are defined in the CCPA. We are providing you with notice of the PI we collect, and our purposes for that collection of data that may be subject to the CCPA ("CCPA Notice"). This CCPA Notice does not cover information that is outside of the scope of the CCPA. This notice also does not apply to data collected from employees, applicants, or contractors or to data collected from individuals acting as representatives of another business in connection with business communications or transactions.

We collect PI directly from you, your device or browser, and our service providers. We use and share PI for the following business purposes:

to provide requested products and Services;
to advertise and offer new products and services;
to improve our products and services;
for quality assurance;
for research development;
for prevention of fraud and illegal activity; and
for marketing purposes.

We may also collect, use, and share PI for our operational purposes as set forth in our Privacy Policy.

II. We collect the following categories of PI from California Consumers, which we share with service providers:

identifiers (e.g., name, phone number, email address, I.P. address);
personal records (e.g., name, phone number, email address);
internet usage information (e.g., information regarding your interaction with our online services);
geolocation data (e.g., your general location based on your I.P. address); and
inferences from PI collected (e.g., your preferences).

If you are a California Consumer and would like to register a request under your "right to know about personal information collected, disclosed or sold" (including the right to obtain copies of specific pieces of information about categories of PI practices), "right to request deletion of personal information," or "right to opt-out of the sale of personal information," you can contact us at privacy@gettr.com or GETTR USA, Inc., ATTN: Privacy Rights, GETTR USA, Inc., c/o LegalInc Corporate Services Inc., 651 N. Broad St., Suite 206, Middletown, DE 19709. You have the right to not receive discriminatory treatment in a manner prohibited by the CCPA because of you exercising your rights under the CCPA.

To fulfill your CCPA request, we may require you to provide sufficient information to reasonably verify you are the California Consumer about whom we collected PI. This verification process may include providing us at least two unique data points, depending on the type of request.

California Consumers have the right to exercise CCPA privacy rights via an authorized agent who meets the agency requirements of the CCPA. Authorized agent requests must include a copy of the agency agreement between the authorized agent and the California Consumer. We will ask you to independently confirm the agency relationship if this section applies to you.

III. The Right to Know.

a. Categories. You have the right, subject to statutory exceptions, to send us a request, no more than twice in a twelve-month period, for any of the following, for the period that is twelve months prior to the request date:

the categories of PI we have collected about you;
the categories of sources from which we collected your PI;
the business or commercial purposes for our collecting or selling

your PI
the categories of third parties to whom we have shared your PI; and
a list of the categories of PI disclosed for a business purpose in

the prior 12 months, or that no disclosure occurred.

b. Specific Pieces. You have the right, subject to statutory exceptions, to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining.

IV. The Right to Deletion.

You have the right, subject to statutory exceptions, to request that we delete your PI that we have collected directly from you and are maintaining. Note also that we are not required to delete your PI that we did not collect directly from you.

V. The Right to Opt-Out of the Sale of Personal Information.

We do not "sell" PI that we collect from California Consumers, including PI of minors under the age of 16, in accordance with the definition of "sell" in the CCPA.

We may work with service providers and partner with advertising companies that use Tracking Technologies to collect information about your visits to the Site and Third-Party Services, and then use that information to deliver advertisements relevant to your interests. There is not yet a consensus as to whether third party cookies and/or other Tracking Technologies associated with our Site and Apps constitute a "sale" of your PI as defined by the CCPA. You may opt out of Interest-based Advertising using ad industry opt out tools by visiting here or here. To effectively manage cookies via this cookie settings tool, you must set cookie preferences on all browsers and all devices that you use. If you clear the cookies on your device, you may need to set your cookie preferences again.

We are not responsible for the completeness, accuracy or effectiveness of any third-party programs, tools or frameworks, or the information they provide.

VI. California's "Shine the Light" law.

If you are a California resident, in addition to the rights set forth above, California's "Shine the Light" law permits customers in California to request certain details about how their personal information is shared with third parties if that personal information is shared for those third parties' own direct marketing purposes. We do not share personal information with third parties for those third parties' own direct marketing purposes. Californians may request information about our compliance with this law by contacting us at privacy@gettr.com or GETTR USA, Inc., ATTN: Privacy Rights, GETTR USA, Inc., c/o LegalInc Corporate Services Inc., 651 N. Broad St., Suite 206, Middletown, DE 19709.

To make a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident, and provide your current California address to which we will send our response. Your inquiry must specify "California Privacy Rights Request" in the subject line of the email or the first line of the letter and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year.

C. Your Nevada Privacy Rights.

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 do not 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 this Nevada law, please email your name and email address to privacy@gettr.com. 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 change. 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 Privacy Policy. We may share your data as explained in our Privacy Policy, such as to enhance your experience 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 our Privacy Policy.

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