Welcome! The following Privacy Policy governs the online information collection practices of PrimeMinds Inc. (“PrimeMinds,” “we,” “our,” “us,” We,” Our,” Us”).  Specifically, it outlines the types of information that we gather about you while you are using the website “www.getprimeminds.com”, the mobile application “PrimeMinds”, and all related products and/or services (collectively, the “Platform”) provided to you by the Company, and the ways in which we use this information. This Privacy Policy, including our children’s privacy statement, applies primarily to information which we collect online; however, the portion of this Privacy Policy that relates to the European Union’s General Data Privacy Regulation may apply to some of the data that you provide to us offline and/or through other means, as well (for example, at a live event, via telephone, or through the mail).

We have created this Privacy Policy to demonstrate our firm commitment to privacy and security. This Privacy Policy describes how our Company collects information from all end users of our internet services, including those who access our Platform but do not have accounts (“Visitors”) and those who may purchase products and/or pay a monthly service fee to subscribe to the Platform (“Members”).

Please read this Privacy Policy carefully. By visiting and using the Platform, you agree that your use of our Platform and any dispute over privacy is governed by this Privacy Policy. In an effort to comply with changes in technology and the adoption of new regulations and laws, we may need to change our Policy at some point in the future, in which case we’ll post the changes to this Privacy Policy on the Platform and update the effective date of the policy to reflect the date of the changes. By continuing to use the Platform after we post any such changes, you accept the Privacy Policy as modified.

DO NOT USE ANY OF OUR SERVICES IF YOU ARE UNWILLING OR INELIGIBLE TO ACCEPT THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY.

1. Introduction:

1.1  By using Our Services, submitting information to us, or purchasing any of our other products or services, You consent to be governed by this Privacy Policy, and you consent to the collection, storage, use, and disclosure of such information in accordance with this Privacy Policy.

1.2 We may collect and store personal or other information that you voluntarily supply to us online while using the Platform (e.g., while on the Platform or in responding via email to a feature provided on the Platform). The Platform only contacts individuals who specifically request that we do so or in the event that they have signed up to receive our messaging, attended one of our events, or have purchased one of our services or products. The Platform collects personally identifying information from our users during online registration and online purchasing. Generally, this information includes name and email address for registration or opt-in purposes and name, postal address, and credit card information when registering for our events or purchasing our products. All of this information is provided to us by you.

1.3 We also collect and store information that is generated automatically as you navigate online through the Platform. For example, we may collect information about your computer’s connection to the internet, which allows us, among other things, to improve the delivery of our web pages to you and to measure traffic on the Platform. If you have accessed our Platform via a social media platform, such as Facebook and Instagram, we may collect information related to your social media account, such as your handle or identifier on that platform. We also may use a standard feature found in browser software called a “cookie” to enhance your experience with the Platform, and web beacons, to access cookies, count users who visit the Platform, or open HTML-formatted email messages.

1.4 We use the information we collect from you while you are using the Platform in a variety of ways, including using the information to customize features; advertising that appear on the Platform; and, making other offers available to you via email, direct mail or otherwise. We also may provide your information to third parties, such as service providers, contractors and third-party publishers and advertisers for a variety of purposes. Unless you inform us in accordance with the process described below, we reserve the right to use, and to disclose to third parties, all of the information collected from and about you while you are using the Platform in any way and for any purpose, such as to enable us or a third party to provide you with information about products and services.

1.5 Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties online – for example on message boards, web logs, through email, or in chat areas – that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.

1.6 Some of our third-party advertisers and ad servers that place and present advertising on the Platform also may collect information from you via cookies, web beacons or similar technologies. These third-party advertisers and ad servers may use the information they collect to help present their advertisements, to help measure and research the advertisements’ effectiveness, or for other purposes. The use and collection of your information by these third-party advertisers and ad servers is governed by the relevant third-party’s privacy policy and is not covered by our Privacy Policy. Indeed, the privacy policies of these third-party advertisers and ad servers may be different from ours. If you have any concerns about a third party’s use of cookies or web beacons or use of your information, you should visit that party’s Platform and review its privacy policy.

1.7 The Platform also includes links to other Platforms and provides access to products and services offered by third parties, whose privacy policies we do not control. When you access another Platform or purchase third-party products or services through the Platform, use of any information you provide is governed by the privacy policy of the operator of the Platform you are visiting or the provider of such products or services.

1.8 Please also note that as our business grows, we may buy or sell various assets. In the event that we sell some or all of our assets, or one or more of our Platforms is acquired by another Company, information about our users may be among the transferred assets.  Your consent to transfer such assets or any of your information shall not be required.

2. Personal Information Our Company Collects And How It Is Used:

2.1 Introduction: Members may be asked to provide certain personal information when they sign up for our products or services, including, but not limited to, name, address, telephone number, billing information (such as a credit card number), and the type of personal computer being used to access the services. The personal information collected from Members during the registration process (or at any other time) is used primarily to provide a customized experience while using our products and services. Your information will never be disclosed, traded, licensed or sold to any third party. However, we may make limited disclosure of personal information under the specific circumstances described below.  The information you provide to us will never be disclosed, traded, licensed or sold to a third party. However, there are specific instances, described below, where your information could be provided to a known third party.

2.2 The Types of Information We Collect and Store: Some of the information we may collect about you and store in connection with the provision and fulfillment of our services to you may include, but is not limited to:

• Name;

• Email address;

• Mailing address;

• Billing address;

• PayPal email address;

• Masked credit card information (for refunds);

• Age;

• Gender;

• Other responses to surveys and questionnaires;

• Sign-up source;

• Date of account creation;

• Date of account updates;

• IP address;

• Timestamp;

• Device type;

• Browser;

• Email open clicks;

• User ID;

• User behavior and data;

• Login history;

• Order details;

• Location;

• Facebook ID;

• Photo;

• Language;

• Country;

• Time zone;

• Birthday;

• Your rating of our support;

• Telephone number;

• Testimonials, with your authorization; and

• Anonymized social media comments.

2.3 How We Use Your Personal Information: The above personal information may be used for the following purposes:

• To operate, improve, or promote our services; 

• To contact you;

• When you have opted in to receive email messaging;

• To respond to your email inquiries. Specifically, when Visitors or Members send email inquiries to us, the return email address is used to answer the email inquiry we receive. We do not use the return email address for any other purpose or share it with third parties;

• To monitor and analyze trends such as:

1. 1. 1. Purchase history
      2. Sales reports
      3. Behavior on the Platform
      4. Email clicks and opens;

• To market our products and services through:

1. 1. 1. Email marketing 
      2. Advertising, including retargeting via Google and Facebook 
      3. Notifications; and

• Perform accounting, administrative, and legal tasks.

2.4 Who Has Access to Your Data Within Our Organization: Within our organization, access to your data is limited to those persons who require access in order to provide you with the products and services you purchase from us, to contact you, and to respond to your inquiries, including requests for refund. Those staff members may be on teams such as: marketing, events, development, executive, customer support (PrimeGuides). Employees only have access to data that is relevant to their team, on a “need to know” basis.2.5 Who We Share Your Data With Outside of Our Organization and Why:

• Processors: We may use service providers in connection with operating and improving the Platform, to assist with certain functions, such as payment processing, email transmission, conducting surveys or contests, data hosting, managing our ads, and some aspects of our technical and customer support. We take measures to ensure that these service providers access, process, and store information about you only for the purposes we authorize, subject to confidentiality obligations.  We use 3rd-party solutions for marketing and analytics. This processing occurs on third party platforms on accounts owned by Company. This processing is subject to our Data Privacy Agreements or Addenda with these third parties, and their respective privacy policies.

• Authorities We may access, preserve, and disclose information about you to third parties, including the content of messages, if we believe disclosure is in accordance with, or required by, applicable law, regulation, legal process, or audits. We may also disclose information about you if we believe that your actions are inconsistent with our Terms of Use or related guidelines and policies, or if necessary to protect the rights, property, or safety of, or prevent fraud or abuse of, Company or others.

2.6. Why We Store Information We Collect From You: We retain certain information that we collect from you while you are a Member on the Platform, and in certain cases where you have deleted your account, for the following reasons:

• So you can use our Platform;

• To ensure that we do not communicate with you if you have asked us not to;

• To provide you with a refund, if entitled;

• To better understand the traffic to our Platform so that we can provide all members with the best possible experience;

• To detect and prevent abuse of our Platform, illegal activities and breaches of our Terms of Use; and

• To comply with applicable legal, tax or accounting requirements.

When we have no ongoing legitimate business need to process your information, we will either delete or anonymize it.

3. Third-Party Data:

3.1 Third-Party Links: The Platform contains links to third party websites such as social media sites, and also contain third-party plug-ins (such as the Facebook “like” button and Twitter “follow” button). If you choose to use the websites, platforms, features or services of any third party (“Third Party Services”), you may disclose your information not just to those third parties, but also to their users and the public more generally depending on how their services function. We are not responsible for the content or practices of those websites or services, or any other Third Party Service. The collection, use, and disclosure of your information will be subject to the privacy policies of the third party providing the Third Party Services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third parties.

3.2 Affiliate & Non-Affiliate Links: Occasionally you may have clicked on one of Company’s affiliate and non-affiliate links and signed up or bought something via that link. In this case, the person or organization in charge of the affiliate link will have the information that you have submitted. This may be your email address, name, address, or whatever else they asked you. If you have signed up for bought something from Company via an affiliate link, please check the privacy policy on their Platform.

3.3 Analytics and Online Advertising: If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.In addition, we may use Google Analytics and other third parties for analytics services on our Platform to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. These third parties may use technologies to collect your location information (“Tracking Technologies”), to track the actions of users of the Platform, to measure statistics of user activity on the Platform, and provide other services relating to Platform activity and internet usage.  We may also engage and work with third parties to serve advertisements on the Platform and/or on Third Party Services. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.  Third parties may also place cookies or other Tracking technologies on your computer, mobile phone, or other device to collect information about you as discussed above. These third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick and others) may also serve tailored ads to you as you use the Internet and Internet-connected applications, and access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Platform to assist in this activity.  As above, the information collected and stored by any such Third Party Services remains subject to their own policies and practices.  We neither have access to, nor does this Privacy Policy govern, the use of cookies or other Tracking Technologies that may be placed on your device you use to access the Platform by such non-affiliated third parties. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.  Please note that if you exercise the choices above, you will still see advertising when you use the Platform, but it will not be tailored to you based on your online behavior over time.

3.4 Social Networking and Other Third Party Features: The Platform may contain third party technologies that allow you interact with or connect the Platform to certain Third Party Services (“Third Party Features”).  For example, you may use a Third Party Feature to obtain certain services, “like” or “share” our content over social media, register or log-in to the Platform through your social media or email account, or chat with a bot.  If you use a Third Party Feature, both the Company and the applicable Third Party Service may have access to certain information about you and your use of the Platform and the Third Party Service. Similarly, if you publicly reference the Platform on a Third Party Service, we may use your reference on or in connection with the Platform.  When you use Third Party Features, including to connect the Platform to any social network or other Third Party Service, please remember that you are bound by the privacy policy of the social network or Third Party Service, and we do not control and are not responsible for the privacy practices of such social network or Third Party Service. You should consult the privacy policy of such Third Party Services to determine the information practices of those Third Party Services.

3.5 Notice Concerning Do Not Track: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals. To learn more about Do Not Track, you can do so here.

4. Cookies and Tracking Tools:

4.1 We use cookies to help you make using our Platform easier, such as:

• To remember your country and language preferences; To deliver information that matches your interests;

• To help us understand our audience and traffic patterns;

• To let you automatically log into programs and parts of our Platform that require membership; and 

• To manage and present Platform info displayed on our Platform that will be specific to you.

4.2 We also use web beacons to collect personal and non-personal data on how you use our Platform, such as how long did you visit our page, what web browser you’re using, what’s your operating system, and who’s your internet service provider. We use these beacons, in connection with cookies, to collect non-personal data on the usage of our Platform including but not limited to the date and time of the visit, the pages visited, the referring web page, the type of browser (e.g., Internet Explorer, NetScape), the type of operating system (e.g., Windows, Linux, or Mac), and the domain name of the visitor’s Internet service provider (e.g., AOL). This information is collected about thousands of Platform visits and analyzed as a whole. This information is useful in, for example, tracking the performance of our online advertising such as online banner ads and to determine where to place future advertising on other Platforms.

4.3 If you are uncomfortable with the collection of such information through the use of cookies and beacons, we recommend disabling these features through your browser preferences, though please understand this will limit the performance and functionality of our Company’s Platform. Your browser documentation should provide specific procedures for disabling cookie and beacon support.

5. Data Security and Data Privacy Regulation:

5.1 We implement a variety of administrative, managerial, and technical security measures to help protect your personal information. Our Company has various internal control standards which relate specifically to the handling of personal information. These include certain controls to help safeguard the information we collect online. Our employees are trained to understand and comply with these controls and we communicate our Privacy Policy, practices and guidelines to our employees. However, while we strive to protect your personal information, you must also take steps to protect your information. We urge you to take every precaution to protect your personal information while you are on the Internet.

5.2 Platforms we sponsor have security measures in place to protect the loss, misuse, and alteration of the information under our control. While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining this information. If we do discover a security breach affecting your data, every effort will be made to provide a notification within 72 hours of our team learning of the occurrence.

6. California Consumer Privacy Act:

6.1 If you are a resident of California, the California Consumer Privacy Act (“CCPA”) provides specific protections and rules with respect to California’s own definition of “Personal Information,” which includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.  The CCPA also grants certain rights to California residents to access or delete the Personal Information that we have collected about them, to opt-out of the sale of their personal information by us to a third party, and not to be discriminated against for exercising these rights.  We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable California data protection laws. You can contact us by sending an email to: hello@getprimeminds.com.

6.2 Right to Access: California residents have the right to request certain information relating to our data practices in the preceding 12 months including:

• The categories of personal information we have collected about you;

• The categories of sources from which the personal information was collected;

• The categories of personal information about you we disclosed for a business purpose or sold;

• The categories of third parties to whom the personal information was disclosed for a business purpose or sold; and

• The business or commercial purpose for collecting or selling the personal information.

See above for more detail about the categories, sources, purpose of collection and recipients of personal information.  

6.3 You also have the right to request the specific pieces of personal information we have collected about you.  Once we receive your request and confirm your identity and California resident status, we will disclose to you the information that we have collected about you, as required by the CCPA.

6.4 Right to Deletion: California residents have the right to request the deletion of their personal information that we collect or maintain. Once we receive your request and confirm your identity and California resident status, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. Such exceptions include, but are not limited to, when the personal information is necessary to complete a transaction or provide goods or services to you, detect security incidents, comply with the law, and for internal uses reasonably aligned with your expectations.

6.5 Right to Opt-Out: California residents have the right to opt out of the sale by the Company of their personal information.  We do not sell any personal information of minors under the age of 16 without receiving affirmative authorization to do so.  To exercise this right, you can contact us by sending an email to: hello@getprimeminds.com. Also, generally speaking, please be assured that the Company does not sell or rent your information to third parties purely for our profit, to data brokers, or in any way other than those intended to improve your online experiences and the relevance of offers made to you through the Platform and elsewhere.  There are instances where the Company has shared personal information in order to provide our customers with personalized services or customized offers to improve your online experiences, and to improve our products and services.  We do this in ways that are intended to extend the experience to our customers in a variety of environments. Depending on the circumstances and the contractual obligations in place, this sharing may be a “sale” under applicable law and you may have the right to request that we stop such sharing.

6.5 Right to Non-Discrimination:  California Residents have the right to not receive discriminatory treatment if and when they exercise their rights to access, delete, or opt-out under the CCPA.This means we cannot, for example:

• Deny goods or services to you;

• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or by imposing penalties;

• Provide a different level or quality of goods or services to you; or

• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
  

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

6.6 Exercising Your Rights:  In order to exercise your “access”, “deletion”, and/or “opt-out” rights, you may submit a request by contacting us via:

• by Mail: PrimeMinds, ATTN: PrimeMinds Inc., 8200 S. Quebec Street, Suite A3-418, Centennial, CO 80112 

• by Email: legal@getprimeminds.com

6.7 You may also authorize another person (your “agent”) to submit a request on your behalf, and in the same manner.  Once we receive your request, we will contact you to verify your identity and California resident status and review your request. We aim to respond to your requests within 90 days of receiving the request. If we need more time to respond to your request, we will let you know the reason and how much additional time we will need.

6.8 There are some exceptions to these requests.  For example, we can keep your personal information for certain business purposes, such as processing payments for merchandise you order or undertaking internal research for our technological developments.

6.9 Additionally, the CCPA provides for certain exemptions, such that requests under the CCPA cannot prevent our ability to:comply with federal, state, or local laws;

• comply with certain requests by legal authorities;

• cooperate with enforcement agencies;

• exercise or defend legal claims;

• collect, use, retain, sell, or disclose consumer information that is deidentified or aggregate consumer information;

• collect or sell personal information if all aspects of such transactions occur wholly outside California; or

• preserve evidentiary privileges.

In some instances, we may refuse to respond to such a request based on an exemption, a legal requirement, or other business or legal policy.  We will inform you as to the basis for refusing any such request.

6.10 Notice to California Residents under 18 Years of Age: If you are a registered user of online services under the age of 18, and we have actual knowledge of your age, then under California law you may request and obtain removal of certain content or information you have posted on our online services. To do so, please contact us at the address, phone number or email address below. Please note that removal does not ensure complete or comprehensive removal of the content. For example, removal may not be possible or permitted if another provision of law requires the content to be maintained, if it was posted or reposted by others, or if we paid compensation to you in exchange for the posting.

6.10 California- Direct Marketing Information: Under California Civil Code Section 1798.83 (the “Shine The Light” law), customers who are California residents and have a relationship with the Company primarily for personal, family, or household purposes are entitled to receive, upon request and free of charge, information about the personal information (if any) we disclosed to third parties for their direct marketing purposes in the prior calendar year. This information may be requested once a year. If applicable, this information will include a list of the categories of personal information that was shared and the names and addresses of the third parties that received the information. If you are a California resident and want to request this information, please submit your request in writing to by sending an email to: legal@getprimeminds.com. 

7. European Economic Area (EEA):

7.1 If you are a resident of the European Economic Area (EEA), or are accessing the Platform from within the EEA, you have certain rights with respect to your data. We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable EEA data protection laws. You can contact us by sending an email to: legal@getprimeminds.com. 

7.2 Rights that you may have, depending on the country in which you live, include, but are not limited to:

• Accessing, correcting, updating, or requesting deletion of your information;

• If you request that your account be deleted, you will lose access to all of our programs in which you are actively registered;

• Objecting to processing of your information, asking us to restrict processing of your information, or requesting the portability of your information;

• Opting out from receiving marketing communications that we send you at any time. You can exercise this right by selecting the “unsubscribe” or “opt-out” link in the marketing emails we send you. Additionally, you may update your email preferences by changing the settings in your account;

• Withdrawing your consent at any time if we have collected and processed your information with your consent. Withdrawing your consent will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent; and 
• Complaining to a data protection authority about our collection and use of your information. For more information, please contact your local data protection authority. 

8. Children’s Privacy Statement:

8.1 This children’s privacy statement explains our practices with respect to the online collection and use of personal information from children under the age of thirteen, and provides important information regarding their rights under federal law with respect to such information.

• This Platform is not directed to children under the age of thirteen and we do NOT knowingly collect personally identifiable information from children under the age of thirteen as part of the Platform. We screen users who wish to provide personal information in order to prevent users under the age of thirteen from providing such information. If we become aware that we have inadvertently received personally identifiable information from a user under the age of thirteen as part of the Platform, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children under the age of thirteen as part of the Platform.

• Because we do not collect any personally identifiable information from children under the age of thirteen as part of the Platform, we also do NOT knowingly distribute such information to third parties. We do NOT knowingly allow children under the age of thirteen to publicly post or otherwise distribute personally identifiable contact information through the Platform.
• Because we do not collect any personally identifiable information from children under the age of thirteen as part of the Platform, we do NOT condition the participation of a child under thirteen in the Platform’s online activities on providing personally identifiable information.

9. Revisions to Privacy Policy:

9.1 Our Company reserves the right to revise, amend, or modify this policy, our Terms of Use, and our other policies and agreements at any time and in any manner, by updating this posting.  To the extent and provision of this Privacy Policy is not compliant with law, such Privacy Policy shall be automatically revised to the extent necessary to be compliant.  If any clause within this Privacy Policy is found to be illegal or unenforceable, that clause will be severed from the Privacy Policy and automatically revised to the extent necessary to be compliant with law and enforceable, and the remainder of this Privacy Policy will be given full force and effect.

10. Legal Basis for Processing Data:

10.1 In this subsection, we identify the legal grounds on which we rely to process your personal data.In accordance with GDPR, we identify the following legal bases on which we rely to process Your personal data: the performance of the contract between You and PrimeMinds for the data processing related to Your use of PrimeMinds’s Services (including Your purchases and payments). (See Our “Terms of Use.”)

10.2  PrimeMind’s legitimate interests, more specifically, include:

• Our business interest in processing the personal data we collect, such as to develop, administer and support our Services; to operate, evaluate and improve our business; to facilitate and manage our Services; promote research; support our recruitment activities; or facilitate a corporate transaction (e.g., sale of assets, merger or acquisition).

• Our business interest in processing personal data to fulfill our contracts with business partners, such as third parties that distribute or support our Services or business operations.

• Our business interest in processing personal data to establish, exercise or defend against fraud, illegal activity, and claims and other liabilities, including by enforcing the terms and conditions that govern the Services We provide.

• Our business interest in providing you with emails and push notifications for timely introductory materials and information about your PrimeMind’s account, and features and updates to our Services.

• Our financial interest in providing you with promotional offers and/or discounts with respect to paid subscriptions and special offerings.

• Our business interest in offering you particularized or adapted content based on Your use of the Services.

• Our business interest in collecting data regarding your general usage activities for the purpose of improving Our PrimeMinds user experience.

• Our business interest in requesting that You participate in PrimeMinds surveys in order to better understand Your needs and expectations.

• Our financial interest in providing You the opportunity to purchase PrimeMinds subscriptions for the benefit of a third party through the PrimeMinds “gifting” program when we have launched this program.

• Our business interest in providing you with customer service communications regarding your account, questions about our Services, or any other matters directed to customer service staff, in order to have clear and easy communication with you and to respond to your requests.

• Our business interest in collecting data related to unplanned downtime or errors in our Services.

• Our business interest in complying with our legal obligations, such as maintaining accurate financial records, and for reasons of public interest, such as with respect to adverse events and product safety reporting.
• Our business interest in verifying your eligibility in a community and providing limited reporting to partners associated with such a community when we have created and launched this community.

11. Disclosure of Your Data:

11.1 We may disclose your personal data to certain third parties as described in Sections 4 and 11 of Our Privacy Policy.

12. Where to Direct Questions about our Privacy Policy:

12.1 We may disclose your personal data to certain third parties as described in Sections 4 and 11 of Our Privacy Policy.