Updated August 30th, 2024

INTRODUCTION

21CS (“Company” or “We”) respects your privacy and is committed to protecting the integrity, confidentiality and availability of data used by internal employees and external customers. This Privacy Policy (“Policy”) describes our policies and practices regarding the collection, use and disclosure of information you submit, or we obtain:

• When you visit or use our website.
• Through email, text, and other electronic messages between you and this website.
• Through mobile and desktop applications you download from this website, which provides dedicated non-browser-based interaction between you and this website.

Solely for purposes of this Policy, we refer to the above collectively as the “Site.”

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our Site. Unless otherwise noted, by accessing or using the Site, you consent to our collection, use, storage, and disclosure of your personal information you agree to this Policy.

This policy may change from time to time. Your continued use of the Site or submission of information after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

21CS

6 Liberty Square

PMB 537

Boston, MA 02109

You may also contact us directly by:

• Telephone: +1 800-555-6845
• E-mail: privacy@21cs.com and at compliance@21cs.com

Children Under the Age of 16

Our Site is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Site. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on the Site or through any of its features, register on the Site, make any purchases through the Site, use any of the interactive or public comment features of the Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact our compliance department at  compliance@21cs.com.

INFORMATION WE COLLECT

We may collect personal information that you provide directly to us, such as information you submit when you visit or use the Site. We may also collect information that is passively or automatically collected from you, such as information collected from your browser or device. We use this information to operate the Site, carry out our business, comply with laws and for other purposes described herein.

When you contact us, or take a survey, we collect the following information from you:

• First and last name
• Email address
• Company name and role
• Information you voluntarily provide when you contact us or respond to a survey

If you apply for a position with us, you will first need to create an account. To do so, we collect your name, email address and password. When you submit an application, we collect the information you submit including your CV/resume.

You do not have to provide the above information to access or use other sections of the Site; however, if you do not provide certain requested information, we may not be able to provide you with some of the information, products, or services we offer.

Sources of Personal Information

You. We may collect your personal information when you contact us; create an account; participate in a survey; or submit an application for employment. We may also collect information through web technologies such as browser cookies, flash cookies, and web beacons set when you visit the Site.

Third Parties. We may collect information about you from third parties that are lawfully entitled to share your data with us including service providers that collect information on our behalf, you, or your references. Where required by applicable law, we will take reasonable steps to notify you that we have collected your information from a third party.

Cookies and Other Web Technologies. We use web technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons for various purposes including recognizing you when you return to the Site and helping us improve the quality of our service when you visit our Site.

A cookie is a small file consisting of letters and numbers that automatically collects certain information from you. This file uniquely identifies and recognizes your browser or device and transmits information back to the server. Depending on the cookie type, it may perform different functions such as remembering your preferences, improving the quality of your visit, recording the website pages you view, and remembering the name or address you entered during a visit. We use cookies to tailor our products and services, estimate our audience size, track visits to our Site and process your requests.

Our Site uses essential, functional, and performance cookies to function and perform as designed and analytics cookies to understand how you use the Site, improve its functionality, and other related purposes.

Controlling cookies. You may control cookies, including preventing or stopping the installation and storage of cookies, through your browser settings and other tools. Most browsers will allow you to block or refuse cookies. However, you may need to manually adjust your preferences each time you visit a website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site. Please note that if you block certain cookies, some of the services and functionalities of our Site may not work. For more information, see the Help section of your browser.

Do Not Track. “Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website indicating that you do not want the website operator to track certain browsing information about you. We do not track Site users over time and across third party websites; our Site is not configured to detect Do Not Track signals from a user’s computer so we are unable to respond to Do Not Track requests.

HOW WE USE YOUR INFORMATION

We use the information we collect about you or that you provide to us, including any personal information, for the following purposes:

• To manage and present our Site and its contents to you including enabling your access.
• To provide customer service.
• To communicate with you including providing notices and information about the Site and related services.
• For other everyday business purposes such as IT and website administration and improvement, security, fraud prevention including investigations, corporate governance, reporting and legal compliance.

• For marketing, advertising, and promotional purposes.

• To respond to law enforcement requests; as required by applicable law, court order, or governmental regulations; and for other lawful processes or public safety purposes.
• To investigate, establish or defend allegations or legal claims.
• For the recruiting and application process or managing the employment relationship.
• To fulfill any other purpose for which you provide it.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
• To comply with legal obligations.
• As permitted or required by law.

Disclosing Your Information

To carry out the purposes outlined above, we may disclose your personal information to our affiliates, service providers and contractors (e.g., background check vendors, third-party staffing vendors, payroll processors, and information technology vendors), professional services providers and government entities.

We may also disclose your personal information to third parties, as necessary, to: (1) comply with federal, state, or local laws; (2) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; or (4) exercise or defend legal claims.

Lastly, we may transfer personal information to a third party as part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control or acquires of all or part of the assets of our business.

In general, we will not disclose your personal information except with your consent and as described in this Policy. The categories of parties to whom we may disclose your information include:

• Your agent or representative.
• Our subsidiaries and affiliates.
• Our business partners.
• Contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them (e.g., platform host, payment processor, IT and technical support, fulfillment services, marketing and advertising vendors, cloud storage).
• Professional services providers such as accountants and attorneys.
• Government or regulatory agencies as required or authorized by applicable law.
• A buyer or other successor in connection with certain business transactions, such as a sale, acquisitions, merger, or change in control, or in preparation for any of these events.

We may also disclose your personal information to third parties:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To investigate, establish or defend against third party allegations or claims including enforcing or applying any agreements such as for billing and collection purposes.
• To demonstrate our relationship with you, investigate, prevent, or take action regarding suspected or actual illegal activities or to assist law enforcement agencies, protect the security or integrity of the Site, protect against or investigate fraud, or protect the rights and safety of others.
• As appropriate to protect the rights, property, or safety of 21CS, our customers, or others if we reasonably believe disclosure is necessary or appropriate. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

• As permitted or required by law.

We may disclose aggregated information about our users and information that does not identify any individual without restriction.

Your Choices

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. EU and UK users, see our Cookie Policy for additional information.
• Disclosure of Your Information for Third- Party Advertising. We do not share personal information with unaffiliated or non-agent third parties for their promotional purposes.
• Promotional Offers and Direct Marketing. If you do not wish to have your email address and/or contact information used by the Company to promote our own services, you can opt- out by following the opt out instructions in the communication or sending us an email with your request to privacy@21cs.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

YOUR RIGHTS

Accessing or Correcting Your Information and Submitting a Complaint

You may send us an email at privacy@21cs.com or contact Compliance at +1-800-555-6845 to request access to, correct, or delete personal information that you have provided to us, subject to verification of your identity and certain limitations.

Links to Third Parties’ Sites and Third-Party Integrations 

We may provide links to websites or resources outside of the Site for your informational purposes only. We may also provide links to third party integrations. Third party integrations are websites or platforms that synchronize with our Site to provide you with additional functionality, tools, or services such as maps, applying for a position, sending requested information, etc. You acknowledge and agree we are not responsible for the availability of third-party sites, resources, or integrations and do not endorse and are not responsible or liable for any content, advertising, goods, services, or other materials on, available through, or provided by such sites, resources, or integrations.

We are not responsible for the privacy or other practices of such sites and cannot guarantee the security of personal information that you provide, or is collected by, such sites. We encourage you to review the privacy policies and terms and conditions on those linked sites.

Retention of Your Information

We retain your personal information for as long as necessary to satisfy the purpose for collecting it, including to provide products and services and while you have an open account with us. We may retain your personal information for longer if it is necessary to comply with our legal or reporting obligations, resolve disputes, collect fees, etc. or as permitted or required by applicable law. We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we process your personal information; or applicable legal requirements.

We may maintain the information we collect automatically from you and associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service.

Data Security and Storage

We have taken steps to implement reasonable measures to secure your personal information from accidental loss and unauthorized access, use, alteration, and disclosure. As part of these efforts, we train our workforce on data security practices and, where applicable, subject them to confidentiality obligations.

All information you provide to us is stored on our secure servers behind firewalls. Personal information collected during the course of business, or through other means where you may provide it to us, is housed on third-party servers owned by Digital Ocean, Oracle, and Vultr.

Any payment transactions will be encrypted and are handled through our third-party payment processors (Stripe, First Data). We do not have access to, store or retain your credit card numbers or related financial information.

We take reasonable steps to ensure that service providers who access or process personal information on our behalf are obligated to implement appropriate safeguards to protect that information.

No system for safeguarding personal or other information is 100% secure and although we have taken steps to protect your information from being intercepted, accessed, used, or disclosed by unauthorized persons, we cannot fully eliminate security risks associated with personal information. The transmission of information via the internet is not completely secure and while we do our best to protect your personal information, we cannot guarantee the security of information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Site.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

If you believe that your data has been misused or is insecure, please contact us at privacy@21cs.com.

Applicable Law

This Policy is governed by the internal substantive laws of Pennsylvania, United States without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Privacy Policy shall lie exclusively with the state and federal courts within Pennsylvania. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect.

Transfer of Your Personal Information.

We may transfer your information to our company or third parties located in third countries including the United States, the European Union, the United Kingdom, Australia for processing and storage. These countries may not have similar data protection laws to the country in which you reside.

CALIFORNIA RESIDENTS

“Shine the Light Law”: If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your PI by Crunch to third parties for the third parties’ direct marketing purposes. Requests may be made one time per calendar year. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2018 will receive information regarding 2017 sharing activities). You may submit your request using the contact information at the end of this Policy.

California Consumer Privacy Act (“CCPA”): The following CCPA Section supplements and amends the Policy to disclose information about our data processing practices as required by the California Consumer Privacy Act of 2018 (“CCPA”).

This CCPA Section applies solely to individuals who are residents of the State of California (“consumers” or “you”). This CCPA Section describes our policies and practices regarding the collection, use, and disclosure of personal information we collect about you, including personal information we obtain when you access or use the Site, or through offline channels including but not limited to phone and email conversations, emails, attendance at events, through our authorized services providers, or other interactions.

Any terms defined within the CCPA have the same meaning when utilized within this CCPA Section. The other provisions of the Policy continue to apply except as modified in this CCPA Section.

Please read this CCPA Section carefully before using the Site or otherwise submitting information to us. By visiting the Site or otherwise submitting information, you indicate your understanding that the collection, use, and disclosure of your information is subject to the terms of this CCPA Section. Except as otherwise noted, any capitalized terms not defined in the CCPA Section have the meaning set forth in the Policy.

IF YOU DO NOT CONSENT TO THE COLLECTION, USE, AND SHARING OF YOUR INFORMATION AS DESCRIBED IN THIS CCPA SECTION, PLEASE DO NOT PROVIDE US WITH SUCH INFORMATION.

1. Personal Information We Collect

As described below, we may collect or have collected in the preceding 12 months the following categories of personal information (“PI”). We may add to the categories of PI we collect and the purpose we use PI. In that case, we will inform you by posting an updated version of this CCPA Section on the Site.

Identifiers. Examples include real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

Personal information described in subdivision (e) of Section 1798.80. Examples include name, characteristics or description, address, telephone number, account number, credit card number.

Characteristics of protected classifications under California or federal law.

Professional or employment-related information. This includes without limitation,

• Data submitted with employment applications including employment history, employment recommendations, etc.
• Background check and criminal history
• Work authorization
• Professional licenses
• Educational degrees
• Fitness for duty data and reports
• Benefit plan enrollment, participation, and claims information
• Leave of absence information, including religious and family obligations, and physical and mental health data, concerning employees and their family members

Internet or other electronic network activity. Examples include browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement.

Audio, electronic, visual, thermal, olfactory, or similar information. This category includes, without limitation, information collected from voicemail messages, while speaking with one of our service representatives, and/or by video camera.

Sensitive Personal Information. This category includes:

• Social Security, driver’s license, state identification card, or passport number
• Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
• Precise geolocation
• Racial or ethnic origin
• Religious or philosophical beliefs
• Union membership
• Contents of your mail, email, and text messages (unless Punch Bowl is the intended recipient of the communication)
• Genetic information
• Biometric information for the purpose of uniquely identifying a consumer
• Health information
• Information related to sex life or sexual orientation

PI does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, such as certain health or medical information and other categories of information protected by different laws

The Company may add to the categories of Personal Information it collects and the purposes it uses Personal Information. In that case, the Company will inform you.

1. Business or Commercial Purposes for Which We Collect Your Personal Information

See section 7, above.

1. Disclosures of Personal Information

The following chart describes the categories of collected personal information we may or have disclosed about you in the preceding twelve months and the categories of third parties to whom we may or have disclosed that personal information. Please also see section 8, above.

 D. Selling or Sharing Personal Information

Under the CCPA, “sell” means disclosing PI for monetary or other valuable consideration. “Share” means disclosing your information for purposes of cross contractual behavioral advertising regardless of consideration.

• We do not sell or share your PI as those terms are defined in the CCPA.
• We do not have actual knowledge that we have sold or shared personal information of minors under age 16.

E. Sensitive Personal Information

We do not use or disclose your sensitive personal information for purposes that, with limited exceptions, are not necessary to provide our products and services as are reasonably expected by an average consumer requesting those goods and services.

Consumer Rights

The CCPA provides California consumers with the following rights, subject to certain exceptions:

1. Right to Request Deletion

You have the right to request that we delete your PI from our records in certain circumstances.

Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will delete and direct any service providers, contractors, and third parties to whom we have disclosed your PI to delete it from their records.

2. Right to Know

You have the right to request that we disclose the following information to you as it relates to the 12-month period preceding the Company’s receipt of your verifiable consumer request (see below):

• The categories of PI we have collected about you.
• The categories of sources from which the PI was collected.
• The business or commercial purpose for collecting, selling, or sharing PI.
• The categories of PI we disclosed or sold for a business purpose.
• The categories of third parties we disclosed PI to, by the category of PI.
• The specific pieces of PI we collected about you.

3. Right to Request Correction.

You have the right, subject to certain limitations, to request that we correct any inaccurate personal information we maintain about you. Upon receipt of a verifiable consumer request, and as required by the CCPA, we will take appropriate steps to respond to your request.

4. Nondiscrimination.

We will not discriminate against you for exercising any of your rights under the CCPA. For example, we generally will not provide you with a different level or quality of goods or services if you exercise any of your rights.

G. Submitting Consumer Rights Requests

To submit a California Consumer rights request to Know, Delete, or Correct as outlined in this CCPA Section, please contact us at privacy@21cs.com or +1-800-555-6845.

Verifiable Requests

We reserve the right to only respond to verifiable consumer requests. A verifiable consumer request is one made by any individual who is:

• The consumer who is the subject of the request,
• A consumer on behalf of the consumer’s minor child, or
• By a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer.

If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of a Consumer. In general, we may ask you to provide identifying information that we already maintain about you, or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive PI to verify your identity. We may not be able to respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. However, making a verifiable consumer request does not require you to create an account with us.

Additionally, you will need to describe your request in sufficient detail to allow us to review, understand, assess, and respond. We will not use the PI we collect from an individual to determine a verifiable request for any other purpose, except as required by law.

We reserve the right to charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will attempt to notify you as to why we made that decision and provide a cost estimate before completing your request. We will attempt to respond to a verifiable consumer request within forty-five (45) days of receipt, but we may require up to ninety (90) days to respond, under which circumstances we will notify you of the need for an extension.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. With respect to Personal Information collected on and after January 1, 2022, and to the extent expressly permitted by applicable regulation, you may request that such disclosures cover a period beyond the 12 months referenced above, provided doing so would not be impossible or require a disproportionate effort by us. The response we provide will also explain the reasons we cannot comply with a request, if applicable. To the extent permitted by the CCPA, we will respond to no more than two requests during any 12-month period.

Authorized Agents

You may authorize a natural person, or a business registered with the California Secretary of State to act on your behalf with respect to the right under this CA Addendum. When you submit a request to Know or a request to Delete, unless you have provided the authorized agent with a qualifying power of attorney, you must provide your authorized agent written permission (signed by you) to act on your behalf and verify the authorized agent’s identity with us. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.

EUROPEAN ECONOMIC AREA and UNITED KINGDOM

The following “GDPR Section” applies solely to individuals located in the European Economic Area (“EEA”) or United Kingdom (“UK”) when they access or use our Site. This GDPR Section describes our policies and practices regarding the collection, use, and disclosure of personal data we collect about you when you access or use the Site, or through other channels including but not limited to phone and email conversations, emails, attendance at events, and other interactions.

This GDPR Section supplements and amends the information contained in the Policy with respect to individuals located in the EEA and UK. The other provisions of the Policy continue to apply except as modified in this GDPR Section. Any terms defined within the EU and UK General Data Protection Regulations have the same meaning when utilized within this GDPR Section.

For purposes of applicable data protection laws, Company is the data controller of the personal data we collect through the Site. As data controller, we process your personal data in accordance with this Policy and the GDPR Section. If you have any questions, you may contact us at:

21CS

6 Liberty Square

PMB 537

Boston, MA 02109

+1-800-555-6845

A. Categories of Personal Data

We process the personal data set forth in sections 3 and 19.A of this Policy. You do not need to provide any of the personal data requested; however, if you do not provide certain information requested at the time, we may be unable to provide you with the requested products or services or process your application for a position.

The Company may add to the categories of personal data it collects and the purposes it uses it. In that case, the Company will inform you.

B. Collection, Use and Legal Basis for Processing

We may process your personal data for a variety of purposes as outlined in this Policy and GDPR Addendum.

In general, we may process your personal data based on one or multiple legal bases such as your consent, our legitimate interests, for performance of a contract with you, for public interest or to meet legal obligations. The following chart identifies the purposes and legal bases we rely on for processing your personal data.

You may obtain information regarding how we assess our legitimate interests or object to our  processing your personal data when we rely on our legitimate interests by contacting us at +1-800-555-6845.

Legal Basis for Processing

• Performance of a contract
• Legal or regulatory requirements
• Legitimate interests (e.g., operating and improving the Site, fulfillment, fraud prevention, customer service, research and development, customer engagement, marketing, job applicant development)
• Consent

 We will only process your personal data for the purpose for which we collected it and for further purposes only if we deem them compatible with that original purpose.

C. Data Subject Rights

Under the EU and UK GDPR, you are entitled to certain rights, subject to limitations. These include the right to:

1. Access or request a copy of your personal data.
2. Correct incomplete or inaccurate personal data we hold about you.
3. Restrict the processing of your personal data.
4. Object to the processing of your personal data carried out in the public interest, based on our legitimate interest of those of a third party, or for purposes of direct marketing.
5. Request the erasure or deletion of your personal data.
6. Receive your personal data in a structured commonly used machine-readable format and have that data transmitted to a data controller of your choosing.
7. Withdraw your consent to the processing of your personal data at any time.
8. Not to be subject to automated decisions where the decision produces a legal effect or similarly significant effect.
9. Lodge a complaint with the appropriate authority in your jurisdiction.

To exercise any of these rights, please contact us +1-800-555-6845.

D. International Transfers

We may transfer your personal data out of the EEA or UK for the purposes set forth in sections 3, 9 and 19.C of the Policy. When we transfer your personal data out of the EEA or UK, we endeavor to ensure it receives a similar degree of protection as provided by the data protection laws of your jurisdiction. To obtain additional information on the mechanisms we use to transfer your personal data, please contact us at +1-800-555-6845.

AUSTRALIA

The following “Australia Section” applies solely to individuals located in Australia when they access or use our Site. This Australia Section describes our policies and practices regarding the collection, use, and disclosure of personal information we collect about you when you access or use the Site, or through other channels including but not limited to phone and email conversations, emails, attendance at events, and other interactions.

This Australia Section supplements and amends the information contained in the Site Policy with respect to individuals located in Australia. The other provisions of the Site Policy continue to apply except as modified in this Australia Section. Any terms defined within Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) have the same meaning when utilized within this Australia Section.

By accessing or using this Site, you consent to our collection, use, storage, and disclosure of your personal information under this Policy.

A. Personal Information We Collect

We collect the personal information set forth in sections 3 and 19.A of this Policy. You do not need to provide any of the personal information requested; however, if you do not provide certain information when requested we may be unable to provide some the services or information requested, process your application, or communicate with you.

Please note that this Australia Section does not apply to employee records.

B. Source of Personal Information

We collect personal information from the sources set forth in section 5 of this Policy

C. How We Use and Disclose Your Personal Information

We use and disclose your personal information as set for the in sections 9, 10, 19.C of the Policy.

D. International Transfers and Disclosures

We may share your personal information within our company, subsidiaries, service providers, courts, regulatory authorities, professional services providers, and other third parties noted in sections 10 and 19.C which may involve transferring your personal information out of Australia to the United States or other countries including Armenia, Denmark, United Kingdom, Germany, Greece, and Sweden.  When we transfer your personal data out of Australia, we endeavor to ensure it receives a similar degree of protection as provided by the data protection laws of your jurisdiction.

E. Accessing Your Personal Information

For information on how to access or correct your personal information, please see section 12, above.

F. Questions or Complaints.

If you have questions or complaints regarding your privacy or how we handle your personal information, you may contact us at:

21CS
6 Liberty Square
PMB 537
Boston, MA 02109
+1-800-555-6845

We will endeavor to promptly respond. If you are not satisfied with our response, you may contact the OAIC to submit a privacy complaint.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to change this Policy at any time. If we make material changes to the Policy, we will post any changes we make to our Policy on this page (with a notice that the Policy has been updated on the home pages of our websites). If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on the home pages of our websites.

The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to- date active and deliverable email address for you, and for periodically visiting our websites and this Policy to check for any changes. Changes will be effective immediately upon posting and will apply to your use of our Site after the “effective date” listed above. Your continued use of the Site after we make changes is deemed to be acceptance of those changes. We will handle your information in accordance with the terms of the Policy in effect at the time of the collection, except to the extent we receive your authorization or as permitted or required by applicable law.

CONTACT US

If you have any questions regarding this Policy, you may contact us at +1-800-555-6845.