Data Privacy Policy

Effective: November 10, 2022
Resolute Square, PBC ("RS", "we", "our" or "us") respects the privacy of visitors to our online media property, Resolute Square (available at: resolutesquare.com ; the "Website"), and as may be available through one or more mobile apps (each, an "App") and subscribers to our online and email newsletters (the "Services"). This Privacy Policy describes our policies and practices regarding the collection, use and disclosure of Personal Information and other information when you access and use the Services. This Policy also applies to other websites or services owned or provided by RS and that post this policy.
This Privacy Policy is part of and subject to our Terms of Service. Please review this Privacy Policy carefully. By using or accessing the Website, App and/or Services, you are accepting the terms and conditions of this Privacy Policy, and you expressly consent to the treatment of your Personal Information as defined in this Privacy Policy. If you do not agree with any terms and conditions in this Privacy Policy, your only remedy is not to access the Website, the App or the Services.
If you are a resident of California or the EEA, United Kingdom, Switzerland or Canada, please see below the terms specific to these users. 

1. INFORMATION WE COLLECT

Personal information about you that is personally identifiable to you, like your name, address, and email address, as well as other non-public information
A. Information You Provide Directly to Us. We may collect Personal Information that you submit to us directly through the Website, App or Services, and via passive technologies integrated into the Website, App or Services, including via third parties. For example, if you wish to subscribe to any of our newsletters, you need to provide a valid email address. You may also be asked to provide certain Personal Information (name, email address) to register and set up an account for a subscription to access restricted, non-public parts of the Website, App or Services. However, we do not collect payment information (credit card or debit card numbers) to, for example, become a subscriber. Rather, all payments are processed by third party service providers, as described below.
We may collect the following Personal Information directly from you:

  • Your contact information
  • Your account details: user name and password
  • Demographic information, such as age and gender
  • Payment information
  • Search queries
  • Communications preferences
  • Comments and other postings 
  • Correspondence with us
  • Any other Personal Information you may give us based on your consent.

B. Passive Collection. The Website, App or Services also passively collect certain types of Personal information, including information relating to the device you use to access the Website, App, or Services, including: 

  • Email addresses 
  • Device model, operating system, browser type, and unique device identifier
  • IP address
  • Mobile phone number and network carrier
  • Mobile device advertising ID or other ID
  • Geographic location (by region, country or state)
  • Transaction data of items or services purchased
  • Pages viewed and time spent on a page(s)
  • Information collected through cookies, web beacons, and other tracking technologies
  • Information about interactions with email messages, such as the links clicked on and whether the messages were opened or forwarded
  • Sites or apps visited before or after accessing the Website, App or Services

Cookies. A cookie is a small text file that's placed on your computer or mobile device when you visit our Website. We, and some of our affiliates and third-party service providers, may use a few different types of cookies. Some are persistent cookies (cookies that remain on your device's hard drive for an extended period of time) and some are session ID cookies (cookies that expire when you close your browser). 
Cookies help us to operate our Website, enhance and customize your experience, perform analytics and deliver advertising and marketing that may be relevant to you. The following types of cookies are deployed on the Website:

  • Strictly Necessary Cookies: These cookies are strictly necessary to provide the Website. For example, they are used for security, network management, and accessibility. You cannot opt out of these types of cookies.
  • Performance and Functionality Cookies: These cookies provide statistical information on website usage, such as web analytics. They also help us to personalize and enhance your online experience.
  • Advertising and Marketing Cookies: These cookies are used to create profiles or personalize content to serve you personalized online ads that we think are most relevant to you. These cookies and resettable device identifiers use information about your use of this and other websites and apps, your response to online ads and emails, and to deliver ads that are more relevant to you.


You can accept or reject cookies by amending your web browser controls. Because cookies are important for various purposes, our Website, App and Services might not work like they're intended to, and in some cases, might not work at all, if you decide to reject our cookies. You can find out more information about how to change your browser cookie settings at www.allaboutcookies.org. You also can manage your cookie settings by following your browser's instructions. Here are some links that might be of assistance:

  • Google Chrome: (https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en) 
  • Microsoft Internet Explorer / Edge: (https://support.microsoft.com/en-nz/help/17442/windows-internet-explorer-delete-manage-cookies)
  • Mozilla Firefox: (https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences)
  • Safari: (https://support.apple.com/en-nz/guide/safari/manage-cookies-and-website-data-sfri11471/mac)


We will obtain the prior consent of users in the EEA, UK and Switzerland to place cookies on their device(s) (except for Strictly Necessary Cookies, which cannot be turned off).  

Beacons and Pixels. We also use web beacons and pixels on our Website, App, and in emails. For example, we may place a pixel in our emails that notify us when you open the email or click on a link in the email. 
Online Behavioral Advertising – In some instances, you may be able to opt out of receiving online behavioral ads from third-party advertisers and ad networks. We do not control third parties' collection or use of your personal information to serve you online ads. Advertisers and ad networks that are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance's (DIA) Self-Regulatory Principles for Online Behavioral Advertising provide opt out choices at the following websites: 

Be advised that these opt-out tools are provided by third parties and may not be available with respect to all online behavioral advertising that is presented to you. We do not control or operate these tools or the choices that advertisers and others through these tools. Even if you opt out of receiving online behavioral advertising, you may still receive generic ads. 
Google Analytics. We use Google Analytics to help us manage and improve the Website and Services. For more information on how Google Analytics collects and processes data, see www.google.com/policies/privacy/partners/. Google provides a Browser Add-On that allows you to opt-out of Google Analytics by downloading and installing the add-on for your web browser, available at: https://tools.google.com/dlpage/gaoptout.
In-App Tracking. We also may use your mobile device's advertising ID or other device ID to track your use of our App. You can stop all collection of information on our App by uninstalling it from your mobile device. Also, you may be able to exercise specific privacy choices by adjusting the permissions in your mobile device.

  1. Information from Other Sources. We also obtain information about our users from third party sources and will combine that information with other information we have obtained, which combined information is subject to this Privacy Policy. We are not responsible for the accuracy of any information provided by other sources.
  2. Social Media. If you interact with us via a social media platform (such as Facebook), the platform's privacy policies regarding Personal Information you provide on the platform will apply and not this Privacy Policy. In addition, Social Media Features and Widgets (such as Facebook's "Like" button are either hosted by a third party or hosted directly on our Website. These features may collect your Internet protocol address, which page you are visiting on our Website and may set a cookie to enable the feature to function properly. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.


You also may be able to access our Website through a social media platform (e.g., Facebook, Twitter). If you link your account from a social media platform, we will collect information from your account, and any information that we collect will be governed by this Privacy Policy.

For more information on your choices and rights, please see below ("Your Rights and Options").

2. HOW WE USE YOUR INFORMATION

We may use your Personal Information for the following general business purposes:

  • To manage your subscription and account
  • To deliver our newsletters via email
  • To respond to your inquiries
  • To address our administrative needs and communications
  • To improve our products and services
  • To contact you for our business purposes or for marketing communications purposes
  • To provide notice of changes and upgrades to our products and services or policies
  • To process employment applications and inquiries
  • To detect, investigate, and prevent activities that may violate our policies or may be fraudulent or illegal
  • To serve you online advertising, including online behavioral advertising
  • As otherwise described to you at the point of collection or pursuant to your consent


We use non-Personal Information such as Website or App pages you have viewed, in order to analyze request and usage patterns so that we may improve our products and services, enhance our user experience, and gather broad demographic information for aggregate use. We may disclose non-Personal Information to third parties that promote our products and services. We reserve the right to use and disclose non-Personal Information to third parties in our discretion. 

Your IP address is a code which is assigned to your computer every time you connect to the Internet. IP addresses are used to help diagnose problems with our server and to administer our Website or App. We use aggregated IP address information to compile reports on the demographics of the usage of the Website, App and Services for purposes of system administration, marketing, and to track potential abuse of our Terms of Service and this Privacy Policy

3. HOW WE SHARE YOUR INFORMATION

We may share Personal Information with our corporate subsidiaries or affiliated entities. Any Personal Information provided to our subsidiaries or entities affiliated with us will be treated by those subsidiaries and affiliated entities in accordance with the terms of this Privacy Policy.
We may share your Personal Information with designated third-party vendors and suppliers to provide you with our products and services, such as to send you our newsletters or to send you information regarding a webinar you have registered to attend. You expressly consent to the sharing of your Personal Information with our contractors and third-party service providers for the sole purpose of providing products and services to you. These service providers are contractually obligated to ensure the confidentiality of Personal Information and implement appropriate security measures.
We use third-party payment processors for any purchases you make through the Website, App or Services. Be advised that we do not have access to or store any Personal Information, including credit card numbers or other financial information, you provide to these processors. This Privacy Policy does not apply to them, and we do not accept any responsibility or liability for their policies or practice.
In addition, we may participate in co-branding or co-promotional agreements with third parties pursuant to which we may share Personal Information with such third parties ("Partner Companies"). For example, we may participate in agreements with Partner Companies pursuant to which we provide the Partner Companies with a URL and a customer registration page co-branded with, or private labeled by, the Partner Companies, such as for a sponsored webinar, and the Partner Companies distributes and promotes the URL to its customers. A Partner Company may have access to Personal Information that we collect with respect to their customers. As a result, if you register for the Website, App or Services through a Partner Company, we may provide your Personal Information to the Partner Company. We do not control the privacy policies or practices of these Partner Companies.
We may use your Personal Information in order to provide to third parties non-personal aggregated information about you that does not allow you to be identified or contacted and that is combined with the Personal Information of other users ("Aggregate Information"). For example, we might inform third parties regarding the number of users of the Services and the activities they conduct while on the Services. We might also inform a company that performs services or that provides products and/or services to us (that may or may not be a business partner or an advertiser on the Services) that 95% of our users live in the USA" or that "75% of our users have purchased products and/or services which can be downloaded from the Services." Depending on the circumstances, we may or may not charge third parties for this Aggregate Information. 
Under the following scenarios, we also may share your Personal Information:

  • If we believe it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving possible threats to the physical safety of any person, violations of our Terms of Service, this Privacy Policy or as otherwise required by law.
  • To respond to subpoenas, court orders or legal process, or if we need to establish or exercise our legal rights or defend against legal claims.
  • If we believe it is necessary to restrict or inhibit any user from using any of the Services, including, without limitation, by means of "hacking" or defacing any portion thereof.
  • If we are involved in a merger, reorganization, dissolution, or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by a third party.


4. DO NOT TRACK

Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. Our Website does not currently recognize or respond to browser-initiated DNT signals.

5. LEGAL BASIS

Other legal bases for collecting Personal Information are: (i) where we need the Personal Information for performance of a contract or requested service; (ii) where the collection and use is in our or another's legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms; or (iii) with your consent. In some cases, we may also have a legal obligation to collect the Personal Information in question. If we collect your Personal Information with your express consent, you may withdraw your consent at any time as provided below.
If you reside or are located outside of the United States, you understand and agree that we may (i) collect, use, disclose and otherwise process the Personal Information you provide even if you are located outside the United States and (ii) collect, use, maintain, store, disclose and otherwise process your Personal Information using servers and systems located within the United States.

6. YOUR RIGHTS AND OPTIONS  

Subject to applicable law, an individual has the right to request from us a copy of what Personal Information that we have collected or to ask to correct or update it. Individuals can also request that we delete their Personal Information from our systems and records. We strive to respond to these requests within 30 days or as required by applicable law. 
Whenever you directly provide us with your Personal Information, please be sure it is accurate and complete. We cannot be responsible for any information you provide to us that is incomplete or incorrect. 
We will not collect, use, or disclose your Personal Information in any ways or for any purposes that are materially different from the purposes described in this Privacy Policy. However, if we wish to do so in the future, we will obtain your consent first and offer you the choice to opt-out of new collection, use, or disclosure. 
Our communications also provide you with the opportunity to update your preferences to select what messages to receive from us and their frequency.  
If you provide Personal Information for a certain reason, we may use the Personal Information in connection with the reason for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Information you provide to answer your question or resolve your problem and will respond to the email address from which you contacted us.
If you have elected to allow us to track your location information on your mobile device, and you later decide you no longer want us to collect your location information, you can disable location services through your mobile device's application settings.
You can stop all collection of information by the App by uninstalling the App. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

7. PROMOTIONAL AND MARKETING MESSAGING

When you receive promotional communications from us, you may specify a preference to stop receiving further promotional communications from us and you will have the chance to "opt-out" by following the unsubscribe instructions indicated in the communication you receive. You may also contact us at privacy@resolutesquare.com to opt-out of receiving any promotional communications. (Please include "Opt-Out" in the subject line.) Despite your selected preferences, we may need to send you non-marketing communications regarding the services we provide to you, such as notices about administrative updates, transaction reports, and notices regarding changes to the Services, this Privacy Policy or the Terms of Service. You cannot opt out of receiving these types of communications.
Should you no longer wish to receive our any of our newsletters to your inbox, you may click on the unsubscribe link located at the bottom of each message received, and/or contact us at privacy@resolutesquare.com, and we will immediately remove you from our distribution list and will not retain your email address on our distribution list.
We may share your personal information with certain third party partners for their direct marketing. You may contact us at privacy@resolutesquare.com to opt-out, or may unsubscribe from any such communications.
For users in the EEA, UK or Switzerland, we will obtain your consent prior to sending promotional or other marketing messages, and you may unsubscribe at any time from our email newsletters.

8. CALIFORNIA PRIVACY RIGHTS

California "Shine The Light" – As provided by California Civil Code 1798.83, if you are a California resident, you have the right to receive (a) information identifying any third party company(ies) to whom we have disclosed your Personal Information to in the past year; and (b) a description of the categories of Personal Information disclosed. To obtain such information, please email your request to privacy@resolutesquare.com with "California Privacy Rights Request" in the subject line.
For California residents under the age of 18 and registered users, California law (Business and Professionals Code § 22581) provides that you can request the removal of content or information you posted on the App or Site. Any such request should be sent to us at privacy@resolutesquare.com. along with a description of the posted content or other information to be removed. Be advised, however, that applicable law may not permit us to completely or comprehensively remove your deleted content or for other reasons as set forth in this California law.
Further, the Website does not currently recognize "Do Not Track" settings or technologies.
California Consumer Privacy Act – The California Consumer Privacy Act (CCPA) (as amended by the California Privacy Rights Act) gives California consumers enhanced rights with respect to their personal information that is collected by businesses. The CCPA provides California consumers with three rights regarding their personal information.
First, California consumers can opt out of the sale of their Personal Information. To do so, please send an email to legal@resolutesquare.com.
Second, California consumers may opt out of having their personal information sold to other persons or parties. California consumers can request to know:

  • What specific pieces of information a business has collected about the consumer;
  • Categories of personal information it has collected about the consumer;
  • Categories of sources from which the personal information is collected;
  • Categories of personal information that the business sold or disclosed for a business purpose about the consumer;
  • 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.

Third, California consumers can request that a business delete Personal Information about the consumer that a business has collected from the consumer.
This Privacy Policy provides the required notices to California consumers. The CCPA also prohibits covered businesses from providing discriminatory treatment to California consumers if they exercise their rights under the CCPA.
In the preceding twelve (12) months, we have: (1) collected the following categories of Personal Information; and (2) disclosed such categories of personal information for a business purpose. (For the categories of third parties with whom we may disclose or sell personal information, please see the section above, "How We Share Your Information".)


Arranged by category:


A. Identifiers

Name, postal address, e-mail address, IP address.
Collected? Yes
Disclosed for Business Purpose? Yes


B. Personal information categories listed in the California Customer Records statute 

Examples: Name, telephone number, credit card and debit card information or other financial information
Collected? Yes (but with respect to credit card and debit card information, only for purposes of payment processing) 
Disclosed for Business Purpose? Yes (but with respect to credit card and debit card information, only to third party payment processors).


C. Protected classification characteristics under California or federal law

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, gender, sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected? No
Disclosed for Business Purpose? No


D. Commercial information

Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Collected? No
Disclosed for Business Purpose? No


E. Biometric information

Examples: Genetic, physiological, biological or behavioral characteristics.
Collected? No
Disclosed for Business Purpose? No


F. Internet or other similar network activity

Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Collected? Yes
Disclosed for Business Purpose? No


G. Geolocation data

Examples: Physical location or movements.
Collected? Yes
Disclosed for Business Purpose? No


H. Sensory data

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected? No
Disclosed for Business Purpose? No


I. Professional or employment-related information

Examples: Current or past job history or performance evaluations.
Collected? No
Disclosed for Business Purpose? No


J. Non-public education information collected by certain federally funded institutions

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf.
Collected? No
Disclosed for Business Purpose? No


K. Inferences drawn from other personal information

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected? No
Disclosed for Business Purpose? No

To make a "Request to know" or "Request to Delete" your personal information, please send your request to: legal@resolutesquare.com. Authorized agents may also complete and submit the online Request Form on behalf of a California Consumer. You can also send your request to email at privacy@resolutesquare.com (and indicate "CCPA Request" in the email subject line).
We will confirm receipt of your request within 10 business days. We will provide the requested information or delete your personal information within 45 days of receipt of your request, but we can use up to an additional 45 days if we let you know that additional time is needed.
Before responding, we must verify that the person making the request is the person about whom we have collected their personal information. We may ask you to provide certain, limited personal information, such as your name and email address to verify and match your identity with our records and systems. If you have an account with us, we may ask that you verify your identity through our account authentication process. This is also to protect against fraud. We will not retain this Personal Information or use it for any other purpose. Also please be advised that we need to search our records and systems only for the preceding 12 months. There may be cases where we do not have any Personal information about you or we are not able to verify your identity for matching purposes. Deleting your Personal Information may result in the closing of your account and inability to access the Website, App, or Services. However, you can always re-register at any time.

9. OTHER STATES' PRIVACY RIGHTS

Nevada. If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third-party for the third-party to license or sell the personal information to other third parties. You can exercise this right by emailing us at privacy@resolutesquare.com, indicating "Nevada Do Not Sell Request" in the email subject line, and providing us with your name and the email address associated with your account.
Colorado. Effective July 2023, the Colorado Privacy Act ("CPA") provides Colorado consumers certain rights over the personal information. Similar to the CCPA, Colorado residents to access, obtain a copy, correct and delete their personal information. They may also opt out of targeted online advertising, the sale of their personal information or profiling. Users in Colorado may submit these requests via email at privacy@resolutesquare.com with the subject line "Colorado Privacy Request" and providing us with your name and the email address associated with your account. We will implement your request to the extent applicable.
Connecticut, Effective July 2023, the Connecticut Data Privacy Act ("CDPA") enables Connecticut residents to have a business confirm what personal information was collected about them, obtain a copy, correct and delete it. Connecticut residents also can opt out of processing for purpose of targeted online advertising, sale of their personal information and using it for automated decision making. Users in Connecticut may submit these via email at privacy@resolutesquare.com with the subject line "Connecticut Privacy Request" and providing us with your name and the email address associated with your account. We will implement your request to the extent applicable.
Utah. Effective December 2023, the Utah Consumer Privacy Act ("UCPA") also grants to consumers in Utah rights of access to their personal information, delete their personal information, "port" their personal information to another business, and to opt out of the sale of their personal information and online targeted advertising. Users in Utah may submit these requests via email at privacy@resolutesquare.com with the subject line "Utah Privacy Request" and providing us with your name and the email address associated with your account. We will implement your request to the extent applicable.
Virginia. Virginia's Consumer Data Protection Act ("CDPA"), effective January 1, 2023, provides similar rights to Virginia consumers regarding their collected personal information: confirmation of processing use of personal information, access to, correction of, deletion, portability of personal information and the right to opt out of processing for online targeted ads, sale of personal information and profiling. Users in Virginia may submit these requests via email at privacy@resolutesquare.com with the subject line "Utah Privacy Request" and providing us with your name and the email address associated with your account. We will implement your request to the extent applicable.

10. LOCATED IN THE UNITED STATES

RS, the Website, App and the Services are located in the United States and governed by US law. If you are outside the United States when you visit the Website, App or Services or engage in communications with us, please be aware that your Personal Information may be transferred to, stored and processed in the United States where our servers are located. Any information you provide to us, or that we collect through your use of the Website, App or Services and will be stored, processed, and transferred within, or to, the United States. Please be aware that the United States and jurisdictions other than the one in which you are located may not provide the same level of data protection as considered adequate in your country. Note that your Personal Information may be available to the US Government or its agencies under legal process in the United States.

11. USERS IN THE EUROPEAN ECONOMIC AREA (EEA), UNITED KINGDOM AND SWITZERLAND

The Legal Basis for Using EEA, UK and Swiss Personal Information
For residents of the European Economic Area (EEA), United Kingdom (UK) and Switzerland, we advise that your Personal Information will be transferred to and processed in the United States, which has data protection laws that are different than those in your country and may not be as protective. The United States has not received a finding of "adequacy" from the European Union under Article 45 of the General Data Protection Regulation ("GDPR") or from the UK under Article 45 of the UK GDPR. 
Our legal basis for collecting and using your Personal Information is to do so with your consent; where we need the Personal Information for performance of a contract or requested service, including to provide you with our newsletter, or where the collection and use is in our or another's legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the Personal Information in question. If we collected your Personal Information with your express consent for a specific purpose, you may withdraw your consent at any time.
To exercise rights under the GDPR or UK GDPR, please send us an email at privacy@resolutesquare.com.
Our retention of your Personal Information and any marketing or promotional communications are based on our legitimate interest in providing you with new and potentially relevant materials based on your use of the Services, geography, role, or company. As always, you can elect to opt out from receiving marketing or promotional communications.
To the extent that we transfer Personal Information from the EEA, UK or Switzerland to a jurisdiction outside the EEA, UK or Switzerland that has not been determined by the European Commission or UK Secretary of State or Information Commissioner's Office as providing adequate data protections (such as the United States), we will ensure that such Personal Information is safeguarded through appropriate contractual terms or other approved mechanisms.
Rights for EEA. UK or Swiss Residents
In addition, if you are a resident of the EEA, UK or Switzerland, you have the right to:

  • Find out if we use your Personal Information, to access your Personal Information, and receive copies of your Personal Information.
  • Withdraw any express consent that you have provided to the processing of your Personal Information at any time without penalty.
  • Access your Personal Information and have it corrected or amended if it is inaccurate or incomplete.
  • Obtain a transferable copy of some of your Personal information which can be transferred to another provider when the Personal Information was processed based on your consent.
  • If you believe your Personal Information is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your Personal Information, you also have the right to request that we restrict the processing of your data pending our investigation and/or verification of your claim.
  • Request your Personal Information be deleted or restricted under certain circumstances. For example, if is using your Personal Information on the basis of your consent and has no other legal basis to use such, you may request your Personal Information be deleted when you withdraw your consent.

Withdrawing your prior express consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
If we ask you to provide Personal Information to us to comply with a legal requirement or enter into a contract, we will inform you of this and let you know whether providing us with your Personal Information is required and if not, the consequences of not sharing your Personal Information with us.
Similarly, if we collect and use your Personal Information in reliance on our or a third party's legitimate interests and those interests are not already described above, we will let you know what those legitimate interests are.
We endeavor to apply suitable safeguards to protect the privacy and security of your Personal Information and to use it only consistent with your relationship with us and the practices described in this Privacy Policy.
To withdraw consent or exercise these rights, please contact us via email at privacy@resolutesquare.com.
If you are not satisfied with our response, or believe we are processing your personally identifiable information in violation of the law, you have the right to lodge a complaint with the Supervisory Authority (also known as Data Protection Authority) or other appropriate governmental authority in your EEA Member State, UK or Switzerland. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en. The data controller is Resolute Square, PBC.

12. USERS IN CANADA


Users of the Website, App and Services in Canada are informed we take appropriate steps to comply with applicable Canadian data privacy requirements, including the Anti-Spam Legislation (CASL) and the Personal Information Protection and Electronic Documents Act (PIPEDA). Note, however, that Personal Information stored or processed outside of Canada, including in the US or another foreign country, may not be subject to the PIPEDA. In addition, personally identifiable information stored or processed outside of Canada is subject to the laws of that other country and may be available to the foreign government of the country in which the Personal Information or the entity controlling it is located pursuant to a lawful order in that jurisdiction. This Privacy Policy is intended to provide the required notices regarding our collection and use of personally identifiable information, including transfer to the United States. 

You may request to access, correct, or delete your personally identifiable information, or withdraw consent to our collection, use or disclosure of your personally identifiable information, by contacting us at privacy@resolutesquare.com, and indicating you are a user based in Canada.

These rights are subject to applicable contractual and legal restrictions and reasonable notice. We may take reasonable steps to verify your identity before honoring any such requests.

13. SECURITY AND DATA RETENTION

RS has implemented technical, administrative and physical security measures to protect your information from unauthorized access and use as described. While we strive to protect your information, no data transmission over the Internet is 100% secure and, consequently, we cannot guarantee or warrant the security of any information you transmit you provide, and you do so at your own risk. We cannot promise that your information will remain absolutely secure in all circumstances. We are not responsible for the circumvention of any privacy settings or security measures we may provide.
We will retain your information for the time necessary to provide a requested service, realize our legitimate business purposes or to comply with the law. We will only retain personal information for the longer of the period if: (a) required by law, or (b) there is a time-bound determination business need. If you unsubscribe to a newsletter, we do not retain your email address on our distribution list. 

14. NO RIGHTS OF THIRD PARTIES


This Privacy Policy does not create rights enforceable by third parties or require disclosure of any Personal Information relating to users of the Website, App or Services.

15. CHILDREN'S INFORMATION

The Website and Services are not directed or intended to be used by children under the age of 13 (in the United States) or under 16 (in the EEA, UK or Switzerland), and we will not knowingly collect Personal Information from children under this age. We do not use an application or other mechanism to determine the age of users of the Website, App or Services, except where a payment is required. All information provided to RS will be treated as if it was provided by an adult. If, however, we learn that a child has submitted information about himself/herself to us, we will delete the information as soon as possible.

16. LINKS TO THIRD-PARTY WEBSITES

The Website, App, or Services may contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check their individual privacy policies before you submit any Personal Information to those websites.
Our provision of a link to any other website or location is for your convenience and does not indicate our endorsement of such other website or location or its contents. We have no control over, do not review, and cannot be responsible for these outside websites or their content. Please be aware that the terms of our Privacy Policy do not apply to these outside websites.

17. UPDATES TO PRIVACY POLICY

We may modify this Privacy Policy from time to time. We will notify you of changes by posting changes to the Website, App, or Services or by other appropriate means and the effective date of the updated policy. Your continued access to and use of the Website, App, or Services after the effective date constitutes your consent to the updated policy.   

18. CONTACT US

Should you have any questions, concerns or feedback regarding this Privacy Policy, please contact us by email at privacy@resolutesquare.com.