Beta Privacy Policy

Last updated: September 1, 2022

Introduction 

ESSTART ("Company" or "We") respects your privacy and is committed to protecting your  personal information through our compliance with this policy. This policy describes the types of  information we may collect from you or that you may provide when you visit ESSTART’s beta  website and platform, found at www.esstart.com (our "Platform"), register as a beta host user  or beta guest user (“User”) and to access and use ESSTART beta products (our “Products”). In  addition, this policy also describes our practices for collecting, using, maintaining, protecting,  and disclosing that information.

This policy applies to information we collect:

• On this Platform.

• In email, text, and other electronic messages between you and this Platform. • When you interact with third-party websites and services.

• Through Google Analytics.

It does not apply to information collected by:

• Us offline or through any other means, including on any other Platform operated by the  Company or any third party; or  

• Any third party, including through any application or content that may link to or be  accessible from or through the Platform.

Please read this policy carefully to understand our policies and practices regarding your  information and how we will treat it. If you do not agree with our policies and practices, your  choice is not to use our Platform. By accessing or using this Platform or using our Products, you  agree to this privacy policy. This policy may change from time to time (see Changes to Our  Privacy Policy). Your continued use of this Platform after we make changes is deemed to be  acceptance of those changes, so please check the policy periodically for updates.  

Children Under the Age of 13 

Our Services are not intended for children under 13 years of age. If you are under 13, do not  use or provide any information on this Platform, use any of the interactive or public comment  features of this Platform, or provide any information about yourself to us, including your name,  address, telephone number, email address, or any screen name or username you may use. If  we learn we have collected or received personal information from a child under 13 without  verification of parental consent, we will delete that information. If you believe we might have  any information from or about a child under 13, please contact us at data request@esstart.com.

California residents under 16 years of age may have additional rights regarding the collection  and sale of their personal information.  

Information We Collect About You and How We Collect It 

We collect several types of information from and about our Users, including information:

• By which you may be personally identified, such as name, email address, telephone  number, email address, personal photograph, ("personal information");

• About your internet connection, the equipment you use to access our Platform, and  usage details.

We collect this information:

• Directly from you when you provide it to us.

• Automatically as you navigate through the site and register as a User. Information  collected automatically may include usage details, IP addresses, and information  collected through cookies.

Information You Provide to Us  

The information we collect on or through our Platform may include:

• Information that you provide by registering as a User on our Platform. We may also ask  you for information when you report a problem with our Platform.

• Records and copies of your correspondence (including email addresses) if you contact  us.

• Your responses to surveys that we might ask you to complete for research purposes.

• Details of transactions you carry out through our Platform and of the fulfillment of your  orders. You may be required to provide financial information before purchasing a  Product through our Platform.

You also may provide information to be published or displayed (hereinafter, "posted") on public  areas of the Platform or transmitted to other users of the Platform or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your  own risk. We cannot control the actions of other users of the Platform with whom you may  choose to share your User Contributions. Therefore, we cannot and do not guarantee that your  User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Google Analytics  

As you navigate through and interact with our Platform, we or Google may use automatic data  collection technologies to collect certain information about your equipment, browsing actions,  and patterns, including:

• Details of your visits to our Platform, including and other communication data and the  resources that you access and use on the Platform.

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• Information about your computer and internet connection, including your IP address,  operating system, and browser type.

The information we collect automatically may include personal information. It helps us to  improve our Platform 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 Platform according to your individual interests.

• Speed up your searches.

• Recognize you when you return to our Platform.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your  computer. You may refuse to accept browser cookies by activating the appropriate  setting on your browser. However, if you select this setting, you may be unable to  access certain parts of our Platform. Unless you have adjusted your browser setting so  that it will refuse cookies, our system will issue cookies when you direct your browser to  our Platform.  

• Web Beacons. Pages of our Platform and our emails may contain small electronic files  known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs)  that permit the Company, for example, to count users who have visited those pages or  opened an email and for other related Platform statistics (for example, recording the  popularity of certain Platform content and verifying system and server integrity).  

We do not collect personal information automatically, but we may tie this information to  personal information about you that we collect from other sources, or you provide to us.

How We Use Your Information 

We use information that we collect about you or that you provide to us, including any personal  information:

• To present our Platform and its content to you.

• To provide you with 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 user registration.

• 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 Platform.

• To promote ESSTART’s Platform and Products to future Users.

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• To allow you to participate in interactive features on our Platform.

• In any other way we may describe when you provide the information. • For any other purpose with your consent.

Disclosure of Your Information 

We may disclose aggregated information about our users, and information that does not  identify any individual, without restriction.  

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

• On an anonymized basis to persons or business entities interested in learning about  ESSTART’s Platform and Products for promotional and educational purposes.  

• To third parties we use to support our business and who are bound by contractual  obligations to keep personal information 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 ESSTART's assets,  whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding,  in which personal information held by ESSTART about our Platform users is among the  assets transferred.

• For any other purpose disclosed by us when you provide the information. • With your consent.

We may also disclose your personal information:

• 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 and conditions 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 ESSTART, our members and guests, or others.

Choices About How We Use and Disclose Your Information 

We strive to provide you with choices regarding the personal information you provide to us. We  have created mechanisms to provide you with the following control over your information:  

• Tracking Technologies and Advertising. You can set your browser to refuse all or some  browser cookies, or to alert you when cookies are being sent. If you disable or refuse  cookies, please note that some parts of this site may then be inaccessible or not  function properly.

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Promotional Offers from the Company. If you do not wish to have your email address used by  the Company to promote our own or third parties' products or services, you can opt-out by  sending us an email stating your request to data-request@esstart.com.

• If we have sent you a promotional email, you may send us a return email asking to be  omitted from future email distributions.  

We do not control third parties' collection or use of your information to serve interest-based  advertising. However, 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 ads from  members of the Network Advertising Initiative ("NAI") on the NAI's Platform.

Accessing and Correcting Your Information 

You can review and change your personal information by logging into the Platform and visiting  your account profile page. You may also send us an email at data-request@esstart.com to  request access to, correct or delete any personal information that you have provided to us. We  cannot delete your personal information except by also deleting your user account. We may  not accommodate a request to change information if we believe the change would violate any  law or legal requirement or cause the information to be incorrect.

Data Security 

The safety and security of your information also depends on you. Where we have given you (or  where you have chosen) a password for access to certain parts of our Platform, you are  responsible for keeping this password confidential. We ask you not to share your password with  anyone.  

Unfortunately, the transmission of information via the internet is not completely secure.  Although we do our best to protect your personal information, we cannot guarantee the  security of your personal information transmitted to our Platform. Any transmission of personal  information is at your own risk. We are not responsible for circumvention of any privacy  settings or security measures contained on the Platform.

Changes to Our Privacy Policy 

It is our policy to post any changes we make to our privacy policy on this page. If we make  material changes to how we treat our users' personal information, we will notify you through a  notice on the Platform home page. The date the privacy policy was last revised is identified at  the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Platform and this privacy  policy to check for any changes.

Contact Information 

To ask questions or comment about this privacy policy and our privacy practices, contact us at:  data-request@esstart.com.

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