Our Commercial or Business Purposes for Collecting Personal Data

• Providing, Customizing and Improving the Services

  • o Creating and managing your account or other user profiles.

    o Processing orders or other transactions; billing.

    o Providing you with the products, services or information you request.

    o Meeting or fulfilling the reason you provided the information to us.

    o Providing support and assistance for the Services.

    o Improving the Services, including testing, research, internal analytics and product

    development.

    o Personalizing the Services, website content and communications based on your

    preferences.

    o Doing fraud protection, security and debugging.

    o Carrying out other business purposes stated when collecting your Personal Data or as

    otherwise set forth in applicable data privacy laws.

• Corresponding with You

  • o Responding to correspondence that we receive from you, contacting you when

    necessary or requested, and sending you information about Symbolic or the Services.

    o Sending emails and other communications according to your preferences or that

    display content that we think will interest you.

Other Permitted Purposes for Processing Personal Data

In addition, each of the above referenced categories of Personal Data may be collected, used, and

disclosed with the government, including law enforcement, or other parties to meet certain legal

requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law,

regulation, court order or other legal process, such as preventing, detecting and investigating security

incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you,

Symbolic or another party; enforcing any agreements with you; responding to claims that any posting or

other content violates third-party rights; and resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for

materially different, unrelated or incompatible purposes without providing you notice or obtaining your

consent.

Categories of Sources of Personal Data

• You

  • When you provide such information directly to us.

    • When you create an account or use our interactive tools and Services.

    • When you voluntarily provide information in free-form text boxes through the

      Services or through responses to surveys or questionnaires.

    • When you send us an email or otherwise contact us.

  • When you use the Services and such information is collected automatically.

    • Through Cookies (defined in the “Tracking Tools and Opt-Out” section below).

    • If you download and install certain applications and software we make

      available, we may receive and collect information transmitted from your

      computing device for the purpose of providing you the relevant Services, such

      as information regarding when you are logged on and available to receive

      updates or alert notices.

  • Third Parties

    • Vendors

      • We may use analytics providers to analyze how you interact and engage with

        the Services, or third parties may help us provide you with customer support.

    • Third-Party Credentials

      • If you provide your third-party account credentials to us or otherwise sign in to

        the Services through a third-party site or service, some content and/or

        information in those accounts may be transmitted into your account with us.

How We Disclose Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this

section. Depending on state laws that may be applicable to you, some of these disclosures may

constitute a “sale” of your Personal Data. For more information, please refer to the state-specific

sections below.

• Service Providers. These parties help us provide the Services or perform business functions on

our behalf. They include:

o Hosting, technology and communication providers.

o Analytics providers for web traffic or usage of the site.

o Security and fraud prevention consultants.

o Support and customer service vendors.

o Payment processors.

• Our payment processing partner Stripe, Inc. (“Stripe”) collects your voluntarily-

  provided payment card information necessary to process your payment.

• Please see Stripe’s terms of service and privacy policy for information on its use

  and storage of your Personal Data.

• Business Partners. These parties partner with us in offering various services. They include:

  o Businesses that you have a relationship with.

  o Companies that we partner with to offer joint promotional offers or opportunities.

  o Publishers that offer Publisher Materials (each as defined in the Terms of Use) through

  the Services.

• Parties You Authorize, Access or Authenticate

  o Third parties you access through the services.

  o Social media services.

  o Other users.

Legal Obligations

We may disclose any Personal Data that we collect with third parties in conjunction with any of the

activities set forth under “Other Permitted Purposes for Processing Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger,

acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in

whole or in part).

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect,

including by removing information that makes the data personally identifiable to a particular user. We

may use such aggregated, de-identified or anonymized data and disclose it with third parties for our

lawful business purposes, including to analyze, build and improve the Services and promote our

business, provided that we will not disclose such data in a manner that could identify you.

Tracking Tools and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and

JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and

when you visit and use our Services, analyze trends, learn about our user base and operate and improve

our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet,

phone or similar device when you use that device to access our Services. We may also supplement the

information we collect from you with information received from third parties, including third parties

that have placed their own Cookies on your device(s).

Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests

sent from a browser at this time.

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you

have requested. For example, certain Cookies enable you to log into secure areas of our Services.

Disabling these Cookies may make certain features and services unavailable.

• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our

Services, maintain your preferences over time and recognize you when you return to our Services.

These Cookies help us to personalize our content for you, greet you by name and remember your

preferences (for example, your choice of language or region).

• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how

visitors use our Services. They do this by collecting information about the number of visitors to the

Services, what pages visitors view on our Services and how long visitors are viewing pages on the

Services. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics

services. Google’s ability to use and disclose information collected by Google Analytics about your

visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy.

You have the option to opt-out of Google’s use of Cookies by visiting the Google Analytics Opt-out

Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most

browsers have an option for turning off the Cookie feature, which will prevent your browser from

accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you

to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are

already on your device. If you do this, however, you may have to manually adjust some preferences

every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you or to modify your preferences with respect to

Cookies, you can access your Cookie management settings. To find out more information about Cookies

generally, including information about how to manage and delete Cookies, please visit

http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located

in the European Union.

Session Replay Technology

We may use session replay technology in order to identify and resolve customer issues, to monitor and

analyze how you use our Services, to better understand user behavior, and to improve our Services. By

continuing to use the Services, you consent to the use of session replay technology. If you would like to

change your settings with respect to session replay technology, you can access your Cookie

management settings.

Data Security

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate

physical, technical, organizational and administrative security measures based on the type of Personal

Data and how we are processing that data. You should also help protect your data by appropriately

selecting and protecting your password and/or other sign-on mechanism; limiting access to your

computer or device and browser; and signing off after you have finished accessing your account.

Although we work to protect the security of your account and other data that we hold in our records,

please be aware that no method of transmitting data over the internet or storing data is completely

secure.

Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Services or to

perform our business or commercial purposes for collecting your Personal Data. When establishing a

retention period for specific categories of data, we consider who we collected the data from, our need

for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In

some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal

obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable

law, rule or regulation. We may further retain information in an anonymous or aggregated form where

that information would not identify you personally.

For Example:

• We retain your profile information and credentials for as long as you have an account with us.

• We retain your payment data for as long as we need to process your purchase or subscription.

• We retain your device/IP data for as long as we need it to ensure that our systems are working

  appropriately, effectively and efficiently.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under

16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise

use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child

under 16 years of age, we will delete that information as quickly as possible. If you believe that a child

under 16 years of age may have provided Personal Data to us, please contact us at support@symbolic.ai.

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to

prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in

order to submit such a request, please contact us at support@symbolic.ai.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of

websites and web applications and services that you do not wish such operators to track certain of your

online activities over time and across different websites. Our Services do not support Do Not Track

requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

Nevada Resident Rights

Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised

Statutes Chapter 603A.

European Union and United Kingdom Data Subject Rights

EU and UK Residents

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or

Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the

“GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but

“Personal Data” generally means information that can be used to individually identify a person, and

“processing” generally covers actions that can be performed in connection with data such as collection,

use, storage and disclosure. Symbolic will be the controller of your Personal Data processed in

connection with the Services.

If there are any conflicts between this this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If dyou have any questions about this section or whether any of the following applies to you, please contact us at support@symbolic.ai. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect

from you.

Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we

use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for

processing include consent, contractual necessity and our “legitimate interests” or the legitimate

interest of others, as further described below.

• Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

o Profile or Contact Data

o Payment Data

o Categories of Data Considered “Sensitive” Under the State Privacy Laws

o Other Identifying Information that You Voluntarily Choose to Provide

• Legitimate Interest: We process the following categories of Personal Data when we believe

it furthers the legitimate interest of us or third parties:

o Identifiers

o Commercial Data

o Device/IP Data

o Web Analytics

o Professional or Employment-Related Data

o Geolocation Data

o Sensory Data

o We may also de-identify or anonymize Personal Data to further our legitimate

interests.

Examples of these legitimate interests include (as described in more detail above):

o Providing, customizing and improving the Services.

o Marketing the Services.

o Corresponding with you.

o Meeting legal requirements and enforcing legal terms.

o Completing corporate transactions.

• Consent: In some cases, we process Personal Data based on the consent you expressly

grant to us at the time we collect such data. When we process Personal Data based on your

consent, it will be expressly indicated to you at the point and time of collection.

• Other Processing Grounds: From time to time we may also need to process Personal Data to

comply with a legal obligation, if it is necessary to protect the vital interests of you or other

data subjects, or if it is necessary for a task carried out in the public interest.

Disclosing Personal Data

The “How We Disclose Your Personal Data” section above details how we disclose your Personal Data

with third parties.

EU, UK and Swiss Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more

information about these rights, or to submit a request, please email us at support@symbolic.ai. Please

note that in some circumstances, we may not be able to fully comply with your request, such as if it is

frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but

in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also

need you to provide us with additional information, which may include Personal Data, if necessary to

verify your identity and the nature of your request.

• Access: You can request more information about the Personal Data we hold about you and

request a copy of such Personal Data. You can also access certain of your Personal Data by

logging on to your account.

• Rectification: If you believe that any Personal Data we are holding about you is incorrect or

incomplete, you can request that we correct or supplement such data. You can also correct

some of this information directly by logging on to your account.

• Erasure: You can request that we erase some or all of your Personal Data from our systems.

• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as

indicated at the time of collection of such data), you have the right to withdraw your consent at

any time. Please note, however, that if you exercise this right, you may have to then provide

express consent on a case-by-case basis for the use or disclosure of certain of your Personal

Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can

also request that we transmit the data to another controller where technically feasible.

• Objection: You can contact us to let us know that you object to the further use or disclosure of

your Personal Data for certain purposes, such as for direct marketing purposes.

• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

• Right to File Complaint: You have the right to lodge a complaint about Symbolic’s practices with

respect to your Personal Data with the supervisory authority of your country or EU Member

State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-

edpb/board/members_en.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Symbolic and its service

providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you

reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether

provided by you or obtained from a third party, is being provided to Symbolic in the U.S. and will be

hosted on U.S. servers, and you authorize Symbolic to transfer, store and process your information to

and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be

transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection

clauses.

Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use

your Personal Data or your choices and rights regarding such collection and use, please do not hesitate

to contact us at:

• https://symbolic.ai

• support@symbolic.ai

• 2261 Market St, San Francisco, California 94114