Effective Date:  June 28, 2021

This Privacy Policy describes the privacy practices that Trusper Inc., doing business as Musely (“Musely” or “us” or “we”) follows when collecting and using information about you from our website (located at https://www.musely.com), the Musely application, and any other channel, platform, application, or mobile feature that we operate (collectively, the “Platform”). We ask that you please read this Privacy Policy before using the Platform. It describes what information we gather from you and others who visit or use the Platform, how we use that information, and what we do to protect it. When you access or use the Platform, certain information, including your Personal Information may be collected, transferred, processed, stored, and in certain circumstances, disclosed as described in this Privacy Policy.

This Privacy Policy complies with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Privacy Policy. Capitalized terms used but not defined in this Privacy Policy have the definitions provided in our Participant Agreement (located at https://www.musely.com/terms). Provisions within the Participation Agreement may affect this Privacy Policy with respect to your use of the Platform so please review the Participation Agreement prior to using the Platform.

BY CREATING AN ACCOUNT ON OUR PLATFORM OR OTHERWISE PROVIDING US WITH YOURS OR OTHERS’ PERSONAL INFORMATION, YOU EXPRESSLY CONSENT TO THESE INFORMATION HANDLING PRACTICES AND YOU ACKNOWLEDGE AND CONFIRM THAT YOU HAVE PERMISSION TO PROVIDE US WITH ALL PERSONAL INFORMATION PROVIDED. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY OR OUR PARTICIPANT AGREEMENT, PLEASE DO NOT USE OR REGISTER FOR AN ACCOUNT ON THE PLATFORM.

Table of Contents

1.......... THE INFORMATION WE COLLECT.

2.......... Third Party Analytics Providers.

3.......... EXTERNAL LINKS.

4.......... HOW WE USE YOUR INFORMATION.

5.......... OUR INFORMATION SHARING PRACTICES.

6.......... YOUR CHOICE AND OPTIONS RELATING TO OUR COLLECTION.

7.......... ACCESSING AND UPDATING YOUR PERSONAL INFORMATION.

8.......... SAFETY AND INFORMATION SECURITY MEASURES.

9.......... NOTICE TO USERS OUTSIDE THE UNITED STATES.

10........ THE GENERAL DATA PROTECTION REGULATION (“GDPR”).

11........ CALIFORNIA SHINE THE LIGHT LAW.

12........ CALIFORNIA MINORS.

13........ CHANGES TO THIS PRIVACY POLICY.

14........ CONTACT INFORMATION.

1 THE INFORMATION WE COLLECT.

We collect data to provide the products and services you request on the Platform, ease your navigation on the Platform, communicate with you, and improve your experience using the Platform. You provide some of this information directly to us, such as when you create an account. Some of the information is collected through your interactions with the Platform. We collect such data using technologies like Cookies and other tracking technologies, error reports, and usage data collected when you interact with our Platform. Some of the information is collected from your use of, and interactions with, us and others on social media, including but not limited to Facebook®, Instagram® Twitter®, Pinterest®, Snapchat®, and YouTube® (collectively “Social Media”).

The data we collect depends on the products, services, and features of the Platform that you use, and includes the following:

1.1 Personal Information.

When you visit our website at www.musely.com without creating an account, you can browse without submitting Personal Information about yourself. In general, we collect Personal Information that you submit to us in the process of creating or editing your account and user profile on the Platform or that you submit to us voluntarily through your use of the Platform. Information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device, or household is “Personal Information.”

In particular, the Platform has collected the following categories of Personal Information from users in the last twelve months. We obtain these categories of Personal Information with the methods described in more detail below.

We may also collect Personal Information from third parties, such as Social Media, product vendors, Payment Processors, and other partners. Our collection of this information allows us to provide you with our products and services, establish, maintain and support your user account on the Platform, and communicate with you in accordance with our Participation Agreement.

Personal Information does not include:

· Publicly available information from government records.

· De-identified or aggregated consumer information.

· Information excluded from the CCPA’s scope, including, without limitation:

o Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and

o Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

1.2 Medical Information

If you purchase products that require an online consultation with a medical professional, you will be asked to submit during the online questionnaire process personal medical and health information, photographs of different angles of your face or other parts of your body, as well as demographic and other information relevant to diagnosis and treatment, such as skincare routines, lifestyle and general medical history (e.g., conditions, allergies, etc.) (collectively, “Medical Information”). With your consent, Musely will share your Medical Information via confidential channels to a doctor or other medical professional regarding your diagnosis and treatment.

Any Medical Information that you submit may be covered by HIPAA, which offers different protections for Medical Information than privacy laws such as the CCPA. To the extent that any Medical Information that you submit to us is subject to HIPAA protection, such Medical Information will be handled in accordance with HIPAA requirements.

1.3 Automatically Collected Usage and Device Information.

Similar to other websites, we use tracking technologies to automatically collect certain technical information from your web browser, mobile, or other device when you visit our Platform. This data may include, without limitation, your IP address, browser type and language, referring/exit pages and URLs, other browser history, platform type, number of clicks, landing pages, the pages you requested and viewed, the amount of time spent on particular pages, and the date and time of your visits. Our collection of this data, described in more detail below, allows us to provide more personalized services to you and to track usage of the Platform.

A. Cookies.

We automatically derive and collect certain data based on your interactions with the Platform using cookies and similar technologies (collectively, “Cookies”). Our collection of data through Cookies includes information about your browser and usage patterns, which may include your IP address, browser type, browser language, referring/exit pages and URLs, pages viewed, links clicked, whether you opened an email, and information about the device you use to access the Platform. Our collection of this information allows us to improve your user experience in various ways, such as to personalize our display of the Platform to you, to “remember” whether or not you are signed in, and to provide better technical support to you.

Please note: If you restrict, disable or block any or all Cookies from your web browser, mobile, or other device, the Platform may not operate properly, and you may not have access to services on the Platform. We shall not be liable for any impossibility to use the Platform or degraded functioning thereof, where such are caused by your settings and choices regarding Cookies.

B. Pixels (aka web beacons/web bugs/java script).

We may use Pixels to automatically record certain technical information about your interactions when you visit the Platform or otherwise engage with us, to help deliver Cookies on our Platform, or count users who have visited the Platform. We may also include web beacons in our promotional e-mail messages or newsletters to determine whether you open or act on them for statistical purposes. “Pixels” are tiny graphics (about the size of a period at the end of a sentence) with unique identifiers used to track certain online actions, movements and related information of Platform users. Unlike Cookies, which are stored on a user's computer hard drive, Pixels are embedded invisibly on web pages or in HTML-based emails. The data we receive through Pixels allows us to effectively promote the Platform to various populations of users, and to optimize external ads about the Platform that appear on third-party websites.

1.4 Information from Other Sources.

We may obtain both personal and non-personal information about you from business partners, contractors, suppliers, and other third parties and add it to your account information or other information we have collected. We, and the third parties we engage, may combine information we collect from you over time, and across the Platform, with information obtained from other sources. This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.

1.5 Location Information.

We collect precise geolocation data from you or your device, as well as your address information, e.g., shipping and billing address, when you set up your account and order our products and services. We also collect and use information about your general location (e.g., your state of residence) and can infer your approximate location based on your IP address in order to track our general Platform usage or to tailor any pertinent aspects of your user experience to the region where you are located.

1.6 User Contributions.

You also may provide information, product reviews, opinions or tips, as well as participate in public discussions, all of which may be published or displayed (hereinafter, “posted”) on public areas of the Platform or transmitted to other users of the Platform or third parties, including, for example, third party websites and services like Social Media that are integrated into or linked to the Platform (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Platform or third parties with whom you may choose to share your User Contributions. Such third parties may have their own policies and terms that apply to your User Contributions, and we are not responsible for any third party’s policies or terms. We cannot and do not guarantee that unauthorized persons will not view your User Contributions.

You acknowledge, represent, and agree that all User Contributions that you post are submitted voluntarily and that if you submit User Contribution to any area of the Platform that is available to others, Musely does not control and is not responsible for the use of your User Contribution by others. If you elect to submit, provide or make available your User Contribution to Musely or the Platform, you: (a) grant to us and all others who have access to your User Contribution through the Platform or otherwise, a worldwide, royalty-free, transferrable, sublicensable, non-exclusive, perpetual, irrevocable license under all of your intellectual property rights to make, use, copy, modify, adapt, create derivative works of, publicly perform or display, import, broadcast, transmit, distribute, license, publish, translate, offer to sell, and sell, rent, lease or lend copies of your User Contribution (and derivative works thereof) in any form or medium (whether now known or later developed), without credit or compensation to you, and in Musely’s sole discretion, to publish your name and other information about you in connection with your User Contribution; and (b) acknowledge that you receive no licenses to the Platform except as expressly provided in the Participation Agreement. Musely is under no obligation to post your User Contribution or any other User Contribution on the Platform and may, in its discretion, edit, block, refuse to post, or remove any User Contribution (including your User Contribution) at any time. You represent and warrant that you have the rights necessary to grant the rights in this Section and that your User Contribution does not infringe the rights of Musely or any third party or violate the Participation Agreement or any applicable law. If we suspect violations of the foregoing, we may institute legal action and cooperate with law enforcement authorities in bringing legal proceedings against violators. You are solely responsible for your User Contribution and any other User Contribution you provide to us or make available through the Platform. You are responsible for backing up your User Contribution and information that you upload to the Platform.

1.7 Information about Others.

You may also provide us with other third party’s Personal Information in connection with inviting a friend to use our services. In that case, we will ask you for that person's email address and automatically send an email invitation. Musely stores this information to send this email, to register your friend if your invitation is accepted, and to track the success of our invitation service. We collect and handle any such Personal Information about others consistent with this Privacy Policy.

You represent and warrant that you have obtained any required consent, provided any required notice, and otherwise fully complied with all applicable laws, including any data protection laws, with regard to any information that you provide to us about others.

1.8 Social Media.

If you interact with us or our other users regarding Musely and its products and services on any Social Media: (a) the Personal Information that you submit by and through such Social Media can be read, collected and/or used by us (depending on your Social Media privacy settings) as described in this Privacy Policy and (b) where Musely responds to any interaction with you on Social Media, your account name/handle may be viewable by any and all members or Users of Musely’s Social Media accounts. We are not responsible for the Personal Information that you choose to submit or link on any Social Media. Social Media operates independently from Musely, and we are not responsible for Social Media interfaces or privacy or security practices. We encourage you to review the privacy policies and settings of any Social Media with which you interact to help you understand their privacy practices. If you have questions about the security and privacy settings of any Social Media that you use, please refer to the applicable privacy notices or policies.

2 Third Party Analytics Providers.

We also collect information about Platform usage and users with third-party analytics providers like Google Analytics, Facebook Analytics, Amplitude, and other third party analytics providers (“Analytics Providers”). These and other Analytics Providers use Cookies in order to collect demographic and interest-level information and usage information from users that visit the Platform, including information about the pages where users enter and exit the Platform and what pages users view on the Platform, time spent, browser, operating system, and IP address. Cookies allow Analytics Providers to recognize a user when a user visits the Platform and when the user visits other websites. Analytics Providers use the information they collect from the Platform and other websites to share with us and other website operators’ information about users including age range, gender, geographic regions, general interests, and details about devices used to visit the Platform and other websites and purchase items. For more information regarding our Analytics Providers’ use of Cookies, collection and use of information, and how to opt-out of tracking, see:

· Google: Google’s Privacy Policy is available at https://policies.google.com/privacy?hl=en). Google Analytics Opt-out Browser Add-on is available at https://tools.google.com/dlpage/gaoptout).

· Facebook: Facebook’s Privacy Policy and information regarding opt-out settings is available at https://www.facebook.com/about/privacy/previous.

· Amplitude: Amplitude’s Privacy Policy and information regarding opt-out options and procedures is available at https://amplitude.com/privacy.

3 EXTERNAL LINKS.

The Platform contains links to third party websites and services, including links to Social Media. We are not responsible for any of the content or features or functionality of other linked websites or services. We are also not responsible for the privacy practices and the terms and conditions of use for any external websites or services. The linked websites and services may collect Personal Information from you that is not subject to our control. The data collection practices of linked third party websites and services will be governed by that third party’s privacy policy and terms of use.

4 HOW WE USE YOUR INFORMATION.

4.1 General.

We may use your Personal Information to: provide our products and services to you through the Platform; communicate with you about the Platform; operate, manage, improve, develop, and conduct analyses related to the Platform; prevent fraud or abuse; address technical and security issues; otherwise protect users; and improve the Platform. For example, if you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

We may use or disclose the Personal Information identified above for one or more of the following business purposes (“Business Purpose”):

· To fulfill or meet the reason you provided the information (e.g., to help provide our products and services to you). This includes providing your personal medical information to doctors, medical professionals, and pharmacies in connection with your diagnosis and treatment based on the personal medical information that you provide.

· To personalize and develop our Platform and the services we provide you through the Platform and improve our offerings.

· To provide certain features or functionalities on the Platform.

· For marketing and promotions.

· To create, maintain, customize, and secure your account with us.

· To provide you with support, to communicate with you and respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

· To personalize your experience and to deliver content, products, and services relevant to your interests.

· To help maintain the safety, security, and integrity of our Platform, services, databases, other technology assets, and business.

· For testing, research, analysis, and product development, including to develop and improve our Platform and services.

· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

· To prevent illegal activity, fraud, and abuse.

· As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.

· To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our users is among the assets transferred or liquidated.

4.2 Account-Related Emails and SMS Messages.

When you create an account with us and provide us with your email or telephone number, we may, subject to applicable law, use your email address or telephone number to send you service-related notices (including any notices required by law, in lieu of communication by postal mail), updates, news, and marketing messages. For example, when you register, you will receive a welcome email and may receive SMS messages. If our services are temporarily unavailable, we may also send you an email or SMS notice.

Email and SMS communications you receive from us will generally provide an unsubscribe link or instructions allowing you to opt out of receiving future emails or SMS messages or to change your contact preferences. If you have an account with us, you can also change your contact preferences by updating your contact information within your account settings. Please remember that even if you opt out of receiving marketing e-mails and SMS messages, we may still send you important service information related to your accounts and the Platform. If you correspond with us by email or SMS message, we may retain the content of your email messages, your email address, telephone number, SMS messages and our responses.

4.3 Advertising.

Musely uses third party service providers to serve ads or collect data on our behalf across the internet and on this Platform (“Advertisers”). Some of these Advertisers may collect your Personal Information about your Platform visits and your interactions with our products and services to tailor marketing messages on this Platform and other sites, or to trigger real-time interactions, customize the Platform, or enhance your profile. Advertisers may use Cookies, Pixels and other technologies to collect your Personal Information, measure the effectiveness of their advertisements, and personalize the advertisements on the Platform. Some of these Advertisers may collect your Personal Information that you share on the Platform via a webform automatically and prior to your submission of the Personal Information (i.e., before you click, “Submit”). Advertisers may be able to use information from your Platform visits to send marketing messages to you in a way that could personally identify you. The information collected by Advertisers may include your IP address, user agent, email addresses and other user and device level information. For example, when Advertisers send advertisements and links that appear on the Platform directly to your browser, they automatically receive your IP address. Please keep in mind that your browser settings may not permit you to control Advertisers’ technologies, and this Privacy Policy does not apply to, and we cannot control the activities of Advertisers. If you would like more information about Advertisers’ practices, please see http://optout.aboutads.info/#!/.

4.4 Non-Personally Identifiable Information.

We may use non-personally identifiable information, such as anonymized and/or aggregated website usage data, in any manner that does not identify individual users for the purpose of improving the operation and management of the Platform, including to develop new features, functionality, and services, to conduct internal research, to better understand our Platform usage patterns, to resolve disputes, to troubleshoot problems, to fulfill user requests, or for security and compliance purposes. Any non-personally identifiable information that is combined with Personal Information will be treated by us as Personal Information.

4.5 Payment Processors.

If you purchase or pay for products or the services via the Platform, the transaction may be handled by our service providers or third vendor(s) responsible for processing your payment, such as Paypal, Braintree and Stripe (“ Payment Processors”). These entities have their own privacy policies and those terms will apply to you. Please be sure to review them at the links provided during payment processing.

5 OUR INFORMATION SHARING PRACTICES.

When we disclose Personal Information for a Business Purpose, we enter a contract that describes the purpose and requires the recipient to keep that Personal Information confidential and use only for performance of the contract, and not for any other purpose. We do not sell your information, including any Personal Information.

5.1 Disclosures of Personal Information in the Last Twelve Months.

We disclose your Personal Information for a Business Purpose to the following categories of third parties:

· Social Media.

· Analytics Providers.

· Other third party marketing service providers.

· Affiliated persons or third-party service providers assisting us in the operation, management, improvement, research and analysis of the Platform. Affiliated persons or our third party service providers may augment, extend, and combine non-personally identifiable information with data from additional third party sources in order to assist us with the above. Use of information by affiliated persons and third party service providers will be subject to this Privacy Policy or an agreement that is at least as restrictive as this Privacy Policy.

In the preceding twelve months, we have disclosed the following categories of Personal Information for a Business Purpose, as more fully described in Section 4:

· Category A: Identifiers.

· Category B: California Customer Records personal information categories.

· Category C: Protected classification characteristics under California or federal law.

· Category D: Commercial information.

· Category E: Biometric information.

· Category F: Internet or other similar network activity.

· Category G: Geolocation data.

· Category H: Sensory data.

· Category K: Inferences drawn from other personal information.

5.2 Legal Requirements.

We reserve the right to disclose all information collected via the Platform, internally or to third parties, for any lawful purpose or to prevent harm to us or others. For example, and without limitation, in our discretion, we may disclose information to government regulators, law enforcement authorities or alleged victims of identity theft. We will notify you in the event of a government or legal request for your information.

5.3 Organizational Transitions.

If we should ever transfer or restructure the operational ownership of the Platform, such as through a merger with another entity or a reorganization of all or a part of our operational responsibilities or assets, we may disclose, transfer, assign our rights, and/or delegate our duties to your information without notice and consent, including to prospective or actual recipient or acquiring entities. Should this occur, we will require any third party receiving your Personal Information as described under this subsection to be contractually required to provide the same level of privacy compliance as provided by us under this Privacy Policy.

5.4 Disclaimer.

We cannot ensure that all of your Personal Information will be disclosed only in the ways described in this Privacy Policy. For example, we may be required to disclose Personal Information to third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your Personal Information that they collect from the Platform. Even with the most rigorous information security standards, no transmission of data over the internet can be 100% secure.

6 YOUR CHOICE AND OPTIONS RELATING TO OUR COLLECTION.

You can choose not to provide Personal Information. You can peruse with Platform without setting up an account. If you choose not to provide certain Personal Information to us, some of your experiences may be affected (e.g., we cannot provide you with our products if you do not register for an account on the Platform).

6.1 You May Decline Other Requests.

We use your Personal Information as needed for the purposes for which it was collected or where you have consented to our use of such information. If you do not wish to provide information to us or do not wish to consent to the uses described in this Privacy Policy, please do not use the Platform, set up an account, or supply the requested information to us.

6.2 Managing Your Information or Deleting Your Account.

You may access or update your Personal Information at any time by signing in to the Platform and clicking on your account settings page. To delete your account, if the circumstances permit us to do so, please contact us as described below in Section 14.

6.3 Right to Access Specific Information and Data Portability Right.

You may have the right under the CCPA to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

· The categories of Personal Information we collected about you.

· The categories of sources for the Personal Information we collected about you.

· Our business or commercial purpose for collecting or selling that Personal Information.

· The categories of third parties with whom we share that Personal Information.

· The specific pieces of Personal Information we collected about you (also called a data portability request).

· If we disclosed your Personal Information for a Business Purpose, the Business Purpose for which Personal Information was disclosed, and the Personal Information categories that each category of recipient obtained.

· If applicable, (1) the categories of Personal Information we have sold; (2) the categories of Personal Information that we sold about the consumer and the categories of third parties to whom the Personal Information was sold, by category or categories of Personal Information for each category of third parties to whom the Personal Information was sold.  Although we are required to provide this notice to you by the CCPA, we do not sell your Personal Information.  

6.4 Right to Delete.

In some circumstances, you may have the right under the CCPA to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) or vendor(s) to:

· Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

· Debug products to identify and repair errors that impair existing intended functionality.

· Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

· Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.) or the requirements of applicable health care laws, including HIPAA, or other applicable laws.

· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

· Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

· Comply with a legal obligation or legal order.

· Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

6.5 Right to Opt-Out.

If you are 16 years of age or older, you may have the right under the CCPA to direct us not to sell your Personal Information at any time (the “right to opt-out”).

To exercise the right to opt-out or right to opt-in, you (or your authorized representative) may submit a request to us by sending us an e-mail at [email protected]. Once you make an opt-out request, we will wait at least twelve months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back in to Personal Information sales at any time by sending us an e-mail at [email protected]. We will only use Personal Information provided in an opt-out request to review and comply with the request.

Although we are required to provide this notice to you by the CCPA, we do not sell your Personal Information.  

6.6 Exercising Your Rights.

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at 1-866-540-1122

Visiting https://www.musely.com/terms

Sending us an e-mail at [email protected]

Only you, or a person registered with the California Secretary of State that you authorize 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.

You may only make such a request for access or data portability twice within a twelve-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five days of its receipt. If we require more time (up to ninety days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the twelve-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

6.7 Non-Discrimination.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

· Deny you goods or services.

· Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

· Provide you a different level or quality of goods or services.

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

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

6.8 Online Tracking Choices.

Most web browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, some features and services in the Platform (particularly those that require sign-in) may not function properly if your Cookies are disabled. Similarly, if you choose to delete session objects from the Platform, you may not be able to access and use all or part of the Platform or benefit from some or all of the information or features and services offered.

Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have the user’s online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about that browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operations, including the Platform, do not respond to DNT signals.

7 ACCESSING AND UPDATING YOUR PERSONAL INFORMATION.

We do not review for accuracy or update your information regularly, but encourage you to access, review and update your Personal Information at any time. To request a copy of your Personal Information and data or for assistance regarding canceling your account, or deleting your Personal Information, contact us at [email protected] or by calling 1-866-540-1122. We will respond to your request as soon as reasonably possible after verifying your authority to make such requests. Your requests for Personal Information deletion are subject to Section 6 of this Privacy Policy above and we will delete your Personal Information within a reasonable time.

8 SAFETY AND INFORMATION SECURITY MEASURES.

8.1 Security.

We use certain physical, managerial, and technical safeguards designed to preserve the security of your information that we maintain in connection with your use of the Platform. For example, we encrypt all data with secure sockets layer (SSL) or similar technologies when we transmit your data. This, however, does not guarantee that your information may not be accessed, disclosed, altered, or destroyed by any breach of our physical, technical or managerial safeguards. In the event that any of your Personal Information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and will notify you, as appropriate, in accordance with pertinent laws and regulations.

8.2 Storage.

We or our third party hosting providers store Personal Information in operating environments that are safeguarded against public or unauthorized access and protected from internal access with physical and technical security measures. While these measures are helpful to safeguard your Personal Information after we receive it, no transmission of data over the internet is 100% secure.

9 NOTICE TO USERS OUTSIDE THE UNITED STATES.

Please be aware that we are headquartered in the United States. The Platform is governed by United States law. If you are using any of our products or services from outside of the United States, your information may be transferred to, stored, and processed in the United States where our servers may be located. The United States might not offer the same level of privacy protection as the country where you reside or are a citizen. BY USING THE PLATFORM, COMMUNICATING WITH US VIA MAIL, EMAIL OR TELEPHONE, OR OTHERWISE PROVIDING INFORMATION TO US, YOU CONSENT TO THE TRANSFER TO, AND PROCESSING OF, YOUR INFORMATION IN THE UNITED STATES.

10 THE GENERAL DATA PROTECTION REGULATION (“GDPR”).

Residents of the European Economic Area (“EEA”) may be entitled to rights under the GDPR. If you qualify, these rights are summarized below.

If you request to exercise your rights under the GDPR, we may require verification of your identity before we respond to any such request. If you are entitled to these rights, you may exercise your rights with respect to the Personal Information that we collect and store:

· the right to withdraw consent to data processing at any time;

· the right of access to your Personal Information;

· the right to request a copy of your Personal Information;

· the right to correct any inaccuracies in your Personal Information;

· the right to erase your Personal Information;

· the right to data portability, meaning to request a transfer of your Personal Information from us to any other person or entity as chosen by you;

· the right to request restriction of the processing of your Personal Information; and

· the right to object to processing of your Personal Information.

You may exercise these rights free of charge. These rights will be exercisable subject to limitations as provided for by the GDPR. Any requests to exercise the above-listed rights may be made to: [email protected]. If you are an EEA resident, you have the right to lodge a complaint with a Data Protection Authority about how we process your Personal Information at the following website: https://edpb.europa.eu/about-edpb/board/members_en.

11 CALIFORNIA SHINE THE LIGHT LAW.

California Civil Code § 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed Personal Information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to [email protected].

12 CALIFORNIA MINORS.

While the Platform is not intended for anyone under the age of 18, if you are a California resident who is under age 18 and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at: [email protected]. If you receive a request from an end user who is a California resident under the age of 18 to remove the end user’s content that you provided to us, you may request that we also remove such content by contacting us at: [email protected]. When requesting removal, you must specify the information you want removed and provide us with specific information, such as the URL for each page where the information was entered, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you or the end user, if applicable, cannot be identified; (4) you do not follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the content or information. Removal of your information or end user information from the Platform not ensure complete or comprehensive removal of that information from our systems or the systems of our service providers. We are not required to delete information posted by you; our obligations under California law are satisfied so long as we anonymize the information or render it invisible to other users and the public.

13 CHANGES TO THIS PRIVACY POLICY.

Because our privacy practices and privacy law necessarily evolve over time, we reserve the right to revise this Privacy Policy from time to time in our sole discretion, upon notice to you such as by posting updated Privacy Policy on the Platform, sending you an email to your account email, or by any other reasonable means. You should periodically review this Privacy Policy to ensure that you are familiar with the most current version. Your continued use of the Platform after the Effective Date posted above will constitute your acceptance of the updated Privacy Policy.

14 CONTACT INFORMATION.

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your information described in this Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at

Phone: 1-866-540-1122

Website: https://www.musely.com/terms

E-mail: [email protected]

Postal Address: Musely

3300 Central Expressway

Suite C

Santa Clara, CA 95051