We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal data for any purpose.

Here are some examples of non-personal data Jawger may collect and how we may use it:

• We may collect information such as language, unique device identifier, referrer URL, location, and the time zone to better understand customer behavior and improve and optimize our products, services, and advertising.
• We may collect information regarding customer activities on the Jawger services in aggregate form to help us understand which parts of our products and services are of most interest. For the purposes of this Privacy Policy, aggregated data is considered non-personal data.
• We may use non-personal data collected to detect, investigate and prevent activities that may violate our policies or be illegal.

An important aspect to privacy is protecting your personal data and who has access to it. Your personal data is yours and yours alone to share, not ours because you registered to use Jawger's products and services. That is why we do not share your personal data with third parties, except in limited circumstances, including:

• When you opt-in to a Jawger service that is performed by a third party on our behalf, like customer service, merchant services, image publishing services and package delivery services; we will only share the minimum personal data, if any, to perform the transaction you have requested; however, third parties are prohibited from using your personal data for purposes other than those requested by us or required by law.
• When you opt-in to share your personal data with third party sites or platforms, such as social networking sites. Please note that once we share your personal data with a third party, the information received by the third party becomes subject to the third party's privacy practices.
• When you opt-in to share your personal data with carefully selected third parties through our services so that they can send you offers and promotions about their products and services.
• When we share personal data with third parties in connection with the sale of a business, to enforce our Terms of Service or rules, to ensure the safety and security of our customers and third parties, to protect our rights and property and the rights and property of our customers and third parties, to comply with legal process or in other cases if we believe in good faith that disclosure is required by law.

We may also share anonymous, aggregated data with third parties performing services on our behalf to help us provide you the best products and services.

We DO NOT track you across third party websites to provide targeted advertising.

We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your personal data. In accordance with local law, your controls and choices may include:

• You may correct, update and delete your account.
• You may change your choices for subscriptions and notifications.
• You may choose to opt-in and opt-out from products and services we offer through Jawger from third parties at any time.
• You may request access to the personal data we hold about you and that we amend or delete it.
• You may exercise your controls and choices, or request access to your personal data, by following instructions provided in communications sent to you.

Please be aware that, if you do not allow us to collect personal data from you, we may not be able to deliver certain products and services to you, and some of our services may not be able to take account of your interests and preferences. If you have questions regarding the specific personal data about you that we process or retain, please contact us at the address below or by sending an inquiry to info@jawger.com.

We recognize the need to provide further privacy protections with respect to personal data we may collect from children on our site and applications. Some of the features on our sites and applications are age-gated so that they are not available for use by children, and we do not knowingly collect personal data from children in connection with those features. In addition, children cannot register for an Account, their parent or guardian must create a Custodial Account for them and grant them permission to use functionality that might involve sharing information. In addition, if we intend to collect personal data from children, we take additional steps to protect children's privacy, including:

• In accordance with applicable law, obtaining consent from parents for the collection of personal data from their children, or for sending information about our products and services directly to their children.
• Limiting our collection of personal data from children to no more than is reasonably necessary to participate in the use of our Services.
• Notifying parents or guardians about our information practices with regard to children, including the types of personal data we may collect from children, the uses to which we may put that information, and whether and with whom we may share that information.
• Giving parents or guardians access or the ability to request access to personal data we have collected from their children and the ability to request that the personal data be changed or deleted.
• When your child turns 18 years of age their Account can be converted from a Custodial Account to a regular account.

You may read Jawger's Children's Online Privacy Protection Act (COPPA) privacy and legal disclosure at: https://www.jawger.com/company/coppa-stmt.

Jawger takes the security and confidentiality of your personal data very seriously. We have implemented technical, administrative and physical security measures that are designed to protect personal data from unauthorized access, disclosure, use and modification. Our services protect your personal data during transit using encryption such as Transport Layer Security (TLS) and your personal data is stored in encrypted form in our databases and on our servers.

From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable and by using our service and website you acknowledge this risk.

We will retain your personal data for the length of time needed to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law. We currently operate in the US and all data is stored and processed in the US. We take reasonable steps to safeguard the privacy of your personal data.

A cookie is a piece of data stored on the hard drive of your computer. Usage of a cookie is in no way linked to any personally identifiable information while on our website. We use cookies to: (a) collect and analyze non-authenticated visitor traffic to public website pages, and (b) authenticate users for access to non-public content and services. We receive IP addresses in the normal course of the operation of our website. An IP address is a number assigned to you by your internet service provider so you can access the internet. Although we receive IP addresses, we do not use them to identify you personally or disclose them to others.

You may update or remove the information you provide to us by updating your profile or contacting us at support@jawger.com. To protect your privacy and security, we will take reasonable steps to verify your identity before updating or removing your information. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business. Information stored as part of this backup process will be deleted in due course.

Our website may contain links to other websites. You should carefully review the privacy policies and practices of other websites as we cannot control or be responsible for their privacy practices.

If you are a California resident, California Civil § 1798.83 permits you to request information regarding the disclosure of your personal data by Jawger for direct marketing purposes. Jawger values your trust and does not share your personal identifiable information unless you give us explicit permission.

If you are a California resident under the age of 18, and a registered user of Jawger where this policy is posted, California Business and Professions § 22581 permits you to request and obtain removal of content or information you have publicly posted. Note that Jawger allows you to delete or remove content you have posted using the deletion options within our services. If you have questions about how to remove content in a specific service or if you would like additional assistance with deletion you can contact us at the address below or at support@jawger.com. Although we offer deletion capability for our services, you should be aware that the removal of content may not ensure complete or comprehensive removal of that content or information posted through the services.

In May 2018, a new data privacy law, the EU General Data Protection Regulation (GDPR) becomes effective. The GDPR requires Jawger to provide users with more information about the processing of their personal data.

Legal Ground for Processing Personal Data

The legal grounds for Jawger processing your personal data for the purposes set out in Section 1 will typically be through obtaining your affirmative consent. An example of giving affirmative consent is when an EU resident actively clicks a box allowing Jawger to use and collect personal data after being informed of the collection of personal data and for what purpose.

Your Rights

(i) Access, update, delete your personal data

You may request a copy of personal data being processed, where and for what purpose. Jawger will provide a copy of the information requested, free of charge, in an electronic format.

You may request that Jawger rectify, restrict or delete your personal data. For the most part, you can exercise this right by logging into your account and visiting your various profiles.

In certain circumstances we may need to retain your personal data, such as:

• Where required by law.
• Where necessary to continue providing services.
• Where the burden or expense of deleting such personal data would be disproportionate to the risks to your privacy in the case in question.
• For archiving purposes in the public interest, scientific, or historical research.
• Defense of legal claims.

(ii) To object

You may object at any time to Jawger's processing of your personal data for direct marketing purposes. If you choose to object, we will no longer process your personal data, unless there is a compelling legitimate reason for future processing. As a result of an objection Jawger might not be able to deliver certain products or services to you.

(iii) Restrict processing of your information

You may restrict the processing of personal data when: (a) you contest the accuracy of personal data, (b) the processing is unlawful, and you request restriction of use instead of erasure, (c) Jawger no longer needs the personal data for the purposes of the processing, but you would like to keep your data available for the establishment, exercise, or defense of legal claims, or (d) you object to processing as of the date. Upon restriction, Jawger will continue to store your data and will not further process your personal data without your consent. However, Jawger may process your personal data for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of public interest of the EU or EU Member State.

(iv) To be notified of data breach

You will receive a data breach notification in accordance to applicable laws if we or our data processors become aware of a data breach which is likely to result in a risk of your rights and freedoms.

(v) Data portability

You may require us to provide a copy of your personal data concerning you which you provided Jawger, in a commonly used and machine-readable format and you have the right to transmit that data to another controller without hindrance from Jawger.

(vi) Lodge a Complaint

A European resident who believes their rights have been violated under the GDPR may lodge a complaint with the Information Commissioner's Office or other supervisory authority.

Jawger's contact information can be found in Section 13. We may ask for proof of identification to verify your access requests.

Use of Cookies

As described in Section 8 of this Privacy Policy, Jawger will provide notice and receive affirmative consent prior to deploying the use of cookies. User's may opt-out of cookies from Jawger by referring to help pages regarding cookie management for your specific browser.

Privacy by Design and by Default

Jawger is committed to implement appropriate technical and organizational measures to safeguard your personal privacy at all design stages. Our design features address the amount of personal data collected, the extent of personal data processing, the period of personal data storage and personal data accessibility.

Jawger as a Data Controller

The GDPR makes a distinction between organizations that process personal data for their own purposes ("data controllers") and organization the process personal data on behalf of other organizations ("data processors"). Jawger acts a data controller in respect of your personal data. For example, if you create an account with Jawger, we will be a data controller of the personal data that you provide as part of your account.

Jawger's Use of Data Processors

To support the delivery of Jawger's services, we may engage and use data processors who will have access to certain personal data. Prior to Jawger engaging with data processors, there is an agreement between Jawger and the data processor that they have in place the proper privacy, security, and confidentiality practices in accordance with applicable laws.

Jawger may use the following processors to help deliver our services:

Jawger's contact information can be located in Section 13 if you have any questions relating to your Personal data and your rights under the GDPR.

From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice on our website if these changes are material and, where required by applicable law, we will obtain your consent.

Our site and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal data.

Please direct any comments or questions to: info@jawger.com

Last updated: January 5, 2019
©2019 Jawger, Inc.