Plural Privacy Policy

Effective as of June 1, 2023

This “Privacy Policy” describes the privacy practices of Plural Policy, Inc. and our subsidiaries and affiliates (collectively, “Plural,” “we,” “us” or “our”) in connection with the www.pluralpolicy.com website (the “Site”), any other website, app, or software that we own or control and which posts or links to this Privacy Policy (collectively, the “Service”), and the rights and choices available to individuals with respect to their information.

Personal Information We Collect

Information you give us. Personal information that you may provide through the Service or otherwise includes:

• Company/Organization information, such as the legal name of the business or
  organizational entity, address, email; government policy initiatives and strategy;
• Contact information, such as your first name, last name, email address and telephone number;
• Profile information, such as your username, password and preferences;
• Communications, such as information you provide when you report a problem with Service or receive customer support or otherwise communicate with us;
• Transaction information, such as the credit card or other payment card details that you use to pay for the Service, and your Service-related billing information and transaction history;
• Marketing information, such your preferences for receiving marketing communications and details about how you engage with them; and
• Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city or town.
• Other information that you choose to provide but is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Information from third party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as our data providers; business partners, such as joint marketing partners; and publicly accessible sources, such as social media platforms.

Data collected automatically. We, our service providers, and our business partners may automatically log the following information about you, your computer or mobile device, and your activity over time on the Site and other online services:

• Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city or town.
• Usage data, such as the website you visited before browsing to the Site, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

Some of our automatic collection is facilitated by:

• Cookies, which are text files stored on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently and remembering your preferences, enabling functionality, helping us understand user activity and patterns.
• Javascript libraries, which are snippets of code within web pages that execute when certain actions take place.
• Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content within it was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.

Sensitive personal information. We ask that you not share with us any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or union membership) on or through the Service or otherwise. If you do anyway, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy.

Changes to your personal information. It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us by updating your registration profile or emailing us at support@pluralpolicy.com.

How We Use Your Personal Information
We use your personal information for the following purposes or as otherwise described to you at the time of collection:

• Provide, operate, maintain, and improve the Service;
• Communicate with you regarding the Service, including by sending you Service announcements, technical notices, updates, security alerts, and support and administrative messages;
• Process your Service transactions and process your related payments:
• Understand your needs and interests, and personalize your experience with the Service; and
• Provide support for the Service and respond to your requests, questions, and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and develop other products and services. As part of these activities, we may create aggregated, de- identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Marketing. We and our third party advertising partners may collect and use your personal information for marketing and advertising purposes:

• Direct marketing. If you request information from us, use the Service or participate in our surveys, promotions or events, we may send you Plural-related marketing communications as permitted by law but will provide you with the ability to opt out.
• Interest-based advertising. We may contract with third-party advertising and social media companies to display ads on our Service and other sites. These companies may use cookies and similar technologies to collect information about you (including the device data and online activity data described above) over time across our Service and other sites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. These ads are known as “interest-based advertisements.” You can learn more about your choices for limiting interest-based advertising, in the “Advertising choices” section below.

Compliance and protection. We may use your personal information to:

• Protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims);
• Audit our internal processes for compliance with legal and contractual requirements and internal policies;
• Enforce our Terms of Use;
• Protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
• Comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

Other purposes with your consent. In some cases we will ask for your consent to collect, use or share your personal information for other purposes. For example, we may ask for your consent to send you marketing emails where required by law or to post your testimonial or endorsement.

How We Share Your Personal Information

We do not share the personal information that you provide us with other organizations without your express consent, except as described in this Privacy Policy. We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

• Service providers. We may employ companies and individuals to help provide the Site or Service on our behalf or help us operate our business (such as IT, customer support, hosting, website analytics, email delivery, marketing and advertising, research, event management). They are permitted to use your personal information only as authorized to perform these tasks in a manner consistent with this Privacy Policy.
• Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processor, Stripe, and we never physically receive or store your full payment card information. Stripe commits to complying with the Payment Card Industry Data Security Standard (PCI-DSS) and using industry standard security. Stripe may use your Payment Information in accordance with its own Privacy Policy here: https://stripe.com/privacy.
• Affiliates. We may disclose your personal information to our subsidiaries and corporate affiliates for use consistent with this Privacy Policy.
• Professional advisors. We may disclose your personal information to professional
  advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services they render to us.
• Compliance and protection. We may disclose your personal information as we believe appropriate to government or law enforcement officials or private parties (a) for the compliance and protection purposes described above; (b) as required by law, lawful requests or legal process, such as to respond to subpoenas or requests from government authorities; (c) where permitted by law in connection with any legal investigation; and (d) to prosecute or defend legal claims.
• Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.

Your Choices

Access, Update, Correct or Delete Your Information. Customers may review, update, correct or delete the personal information in their registration profile by logging into their account or emailing us at support@pluralpolicy.com.

Marketing communications. You may opt out of marketing-related emails by following the opt- out prompt in the email. You may continue to receive Service-related and other non-marketing emails.

Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Service and our Site may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

Advertising choices. You can limit use of your information for interest-based advertising by:

• Browser settings. Blocking third party cookies in your browser settings using or ad-blocking browser plug-ins/extensions.
• Mobile device settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Platform settings. Using Google’s and Facebook’s interest-based advertising opt-out features:
  • Google: https://adssettings.google.com/
  • Facebook: https://www.facebook.com/about/ads
• Ad industry tools. Opting out of interest-based ads from companies participating in the following industry opt-out programs:
  • Network Advertising Initiative:
    http://www.networkadvertising.org/managing/opt_out.asp
  • Digital Advertising Alliance:
    • optout.aboutads.info, which lets you opt-out of interest-based ads on websites.

The opt-out preferences described above must be set on each device for which you want them to apply. Not all companies that serve interest-based ads participate in the ad industry opt-out programs described above, so even after opting-out, you may still receive some cookies and interest-based ads from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide your personal information. If you do not provide information indicated as required or mandatory within the Service, or that is otherwise necessary to provide a requested service or feature within the Service, that portion or all of the Service may be unavailable to you and we may deactivate your account.

Security

The security of your personal information important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.

International Data Transfers

Plural is headquartered in the United States and has affiliates and service providers in other countries, and your personal information may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country.

Third Party Sites and Services

The Service may contain links to other websites and services operated by third parties, such as social media platforms, advertising services and other websites and applications. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites, applications or services, and are not responsible for their actions. Other websites and services follow different rules regarding their collection, use and disclosure of your personal information. We encourage you to read their privacy policies to learn more.

Children

The Service is not directed at, and Plural does not knowingly acquire or receive personal information from, children under the age of 13. If we learn that any user of the Service is under the age of 13, we will take appropriate steps to delete that individual’s personal information and restrict that individual from future access to the Service.

SUPPLEMENTAL NOTICE FOR RESIDENTS OF CERTAIN U.S. STATES

This Supplemental Notice is for residents of states that have adopted comprehensive privacy legislation and others that may come into effect from time to time, including, but not limited to, California, Connecticut, Colorado, Utah and Virginia (collectively, “Applicable State Laws”). The following table describes the categories of personal information Plural has collected and whether
Plural disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months.

Category of Personal Information Collected by Plural	Category of Third Parties Personal Information is Disclosed to for a Business Purpose
Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	– Service providers – Business partners – Affiliates – Other users or third parties you share or interact with – Advertising networks – Internet service providers – Data analytics providers
Personal information categories A name, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories.	– Service providers – Business partners – Affiliates – Other users or third parties you share or interact with – Advertising networks – Data analytics providers
Protected classification characteristics under California or federal law Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	We do not expressly collect this data but to the extent it is disclosed to us, we may add it to our CRM software which, for business purposes, may be disclosed to: – Service providers – Business partners – Affiliates – Other users or third parties you share or interact with – Advertising networks
Commercial information Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	– Service providers – Business partners – Affiliates – Other users or third parties you share or interact with – Advertising networks
Biometric information Physiological, biological, or behavioral, characteristics (including DNA) that can be used to establish individual identity, or imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template such as a faceprint, a minutiae template, or a voiceprint, can be extracted and keystroke patterns or rhythms, gait patterns, or rhythms, and sleep, health or exercise data that contain identifying information.
Internet or other electronic network activity Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement.	– Service providers – Business partners – Affiliates – Other users or third parties you share or interact with – Advertising networks – Internet service providers – Data analytics providers – Operating systems and platforms
Geolocation data Physical location or movements.
Sensory data Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information Current or past job history or performance evaluations.	– Service providers – Business partners – Affiliates – Other users or third parties you share or interact with – Advertising networks – Internet service providers – Data analytics providers
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g, 34 C.F.R. Part 99)) Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	We do not collect this data.
Inferences drawn from other personal information to create a profile about a consumer Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	– Service providers – Business partners – Affiliates – Other users or third parties you share or interact with – Advertising networks – Internet service providers – Data analytics providers – Operating systems and platforms

“Sales” of Personal Information under the CCPA

For purposes of certain state law, Plural does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age as the term “sell” is commonly understood. That said, we may share information with third-party advertising partners for the purpose of promoting our Services as described above, such as for cross-context behavioral advertising. To the extent that such sharing is considered a “sale” under California law, you may limit such sharing by contacting us as set forth in “Contact Us” below.

Additional Privacy Rights for Residents of Certain States

• Non-Discrimination. Residents of certain states have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by applicable law.
• Authorized Agent. Only you, or someone legally authorized to act on your behalf, 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. To authorize an agent, provide written authorization signed by you and your designated agent and contact us as set forth in “Contact Us” below for additional instructions.
• Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, or to answer questions regarding your account and use of our Services.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy we will notify you by email (if you have an account linked to a valid email address) or another manner through the Service that we believe is reasonably likely to reach you.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes in the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any updated Privacy Policy indicates your acceptance of the update.

Supervisory Authority. If your personal information is subject to the applicable data protection laws of Virginia, you have the right to lodge a complaint with the competent supervisory authority or attorney general if you believe our processing of your personal information violates applicable law.

Contact Us

If you have any questions or concerns about our Privacy Policy, please contact us.

Plural Policy, Inc.
1357 Harris Way NE
Brookhaven, GA 30319

Email: support@pluralpolicy.com