Privacy Policy

INTRIGUE - PRIVACY POLICY
Last Updated: February 23, 2021

1.     PURPOSE
Your privacy is important to Intrigue Corp.  This Privacy Policy is incorporated by reference into the Intrigue License and Terms of Service (the “Terms”). The terms “Intrigue,” “we,” and “us” include Intrigue Corp. and our affiliates and subsidiaries. This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt-out of a use or correct or change such information. All other terms not defined in Section 12 or otherwise herein will have the meanings set forth in the Terms.

2.     SCOPE; APPLICABILITY
This Privacy Policy describes how Intrigue may collect, use, store, disclose, and Process Personal Information through your access and use of Intrigue products and services, including those at https://intrigue.io, related Intrigue websites (each a “Site”), mobile software applications, forums, blogs, and other online or offline offerings (collectively, the “Services”). All individuals whose responsibilities include the Processing of Personal Information on behalf of Intrigue are expected to protect that data by adherence to this Privacy Policy. This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.

This Privacy Policy applies when you access the Services or share information with Intrigue, as indicated below. By using the Services, you consent to this Privacy Policy, which may be updated by us at any time. If you do not consent to this Privacy Policy for any reason, please do not use the Services or share your information with us. Please note that this Privacy Policy applies only to the Services, and not to any other third party website linked to or from it, or any third party website in which Intrigue content or functionality is embedded. We do not control the privacy policies or practices of others.

3.     TRANSPARENCY/NOTICE—TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Intrigue and the requirements of applicable law. Some of the ways that Intrigue may collect Personal Information include:

You may provide Personal Information directly to Intrigue through interacting with the Services, participating in surveys, during events such as sweepstakes, and requesting Services, or information.  You have the choice on what information to share and the services you want to engage. You can choose not to provide information to us, but in general some information about you is required in order for you to access certain functionality of the Services, such as those mentioned below or for tracking your preferences, subscribing to a newsletter, or initiating other such actions.

As you navigate the Services, certain passive information may also be collected about your visit, including through cookies, log files, web beacons, device identifiers, advertising identifiers and similar tracking technologies as described below.

We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.

3.1    TYPES OF PERSONAL INFORMATION WE COLLECT
Intrigue collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively “Individuals”).

Information You Provide Directly to Us. 
When you use the Services or engage in certain activities, such as registering for an account with Intrigue, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:

User Profiles. 
When you create a profile, Intrigue may collect certain Personal Information including your name, contact details, photographs, examples of your work, information on work previously performed via the Service and outside the Service, skills and other information, including your username (“Profile”).

Communications with Us. 
We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, register for Intrigue’s newsletter, request to receive customer or technical support, or otherwise communicate with us.

Surveys. 
From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/or Services and in any manner consistent with the policies provided herein.

Posting on the Services. 
Intrigue may offer publicly accessible pages, blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself in on Intrigue’s pages, blogs, private messages, and community forums, the Services will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Services, such content will be considered “public” and will not be subject to the privacy protections set forth herein.

Automatic Data Collection. 
We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through access or use of the Services such as preferences.


Information from Other Sources. 
We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access or use our Services through a Third-Party application, we may collect information about you from that Third-Party application that is public via your privacy settings or is otherwise available. This supplemental information allows us to verify information that you have provided to Intrigue and to enhance our ability to provide you with information about our business, products, and Services.

3.2     HOW INTRIGUE USES YOUR INFORMATION
The EU General Data Protection Regulation (GDPR) and other relevant laws (such as the UK Data Protection Act), require that we inform you of the legal bases for our Processing of your personal information.  We acquire, collect, store, use, disclose and Process Personal Information about Individuals for a variety of business purposes, including:

To Provide Products, Services, or Information Requested. Intrigue may use information about you to provide the Services and fulfill requests for products or information, including to:
 - Generally manage Individual information and accounts;
 - Respond to questions, comments, and other requests;
 - To assess vulnerabilities and other bugs you discover in the course of your use of the Services;
 - Provide access to certain areas, functionalities, and features of Intrigue’s Services;
 - Contact you to answer requests for customer support or technical support; and
 - Allow you to register for events.
Administrative Purposes. Intrigue may use Personal Information about you for its administrative purposes, including to:
 - Measure interest in Intrigue’s Services;
 - Develop new products and Services;
 - Ensure internal quality control;
 - Verify Individual identity;
 - Communicate about Individual accounts and activities on Intrigue’s Services and systems, and, in Intrigue’s discretion, changes to any Intrigue policy;
 - Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as Account management, customer service, or system maintenance;
 - Process payment for products or services purchased;
 - Process applications and transactions;
 - Prevent potentially prohibited or illegal activities; and
 - Enforce our Terms.
 Marketing Intrigue Products and Services. Intrigue may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Intrigue may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
 - To tailor content, advertisements, and offers;
 - To notify you about offers, products, and services that may be of interest to you;
 - To provide Services to you and our sponsors; and
 - For other purposes disclosed at the time that Individuals provide Personal Information; or
 - Otherwise with your consent.  When we obtain your consent, the GDPR (where it applies) and other similar laws give you the right to withdraw your consent without penalty.  You can do this at any time by following the instructions in Section 5 below.  
Compliance with laws: to comply with our legal obligations (for example, maintaining information in accordance with tax, audit, or company law requirements and responding to legal process).

You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 5 below.

Research and Development.
Intrigue may use Personal Information alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services.

Direct Mail, Email and Outbound Telemarketing. 
Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Intrigue’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 5 below.

Services via Mobile Devices. 
From time to time, Intrigue may provide Services that are specifically designed to be compatible and used on mobile devices. Intrigue will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of Intrigue’s Services may require that users log in with an account. In such cases, information about use of mobile versions of the Services may be associated with accounts. In addition, Intrigue may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Intrigue to enable Individuals to access accounts and to enable Intrigue to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. Intrigue may use personal or non-identifiable information transmitted to Intrigue to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices Intrigue provides.

Anonymous and Aggregated Information Use. 
Intrigue may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Intrigue’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Intrigue may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Intrigue and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.  This information is not generally subject to the restrictions in this Privacy Policy, provided it does not identify and could not be used to identify a particular Individual.

Sharing Content with Friends or Colleagues. 
Intrigue’s Services may offer various tools and functionalities to share content. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Intrigue or any other Third Parties for any other purpose.

Other Uses. 
Intrigue may use Personal Information for which we have a legitimate interest, such as network and information security, direct marketing, disclosure to affiliated organizations, research (including marketing research), fraud prevention, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

3.3     COOKIES, PIXEL TAGS/WEB BEACONS, ANALYTICS INFORMATION, AND INTEREST-BASED ADVERTISING
We, as well as Third Parties that provide content, advertising, or other functionality on our Services, may use cookies, log files, device identifies, advertising identifies,  pixel tags (web beacons), local storage, and other tracking technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.

Cookies. 
Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.

Pixel Tags/Web Beacons. 
A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

Embedded Scripts. 
We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as an embedded script. An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your computer or other device and is deactivated or deleted when you disconnect from the Service.

Social Media Widgets. 
Our Site includes social media features such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.

Analytics. 
We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to .optout.aboutads.infowww.networkadvertising.org/choices.  


Our uses of such Technologies fall into the following general categories:

Operationally Necessary. We may use Technologies that are necessary to the operation of our Sites, Services, applications, and tools. This includes technologies that allow you access to our Sites, Services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;

Performance Related. We may use Technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools;

Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites;

Advertising or Targeting Related. We may use first-party or third-party Technologies to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using Technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

If you would like to opt-out of the Technologies we employ on our Sites, Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.  

3.4     THIRD-PARTY WEBSITES AND SOCIAL MEDIA PLATFORMS
The Services may contain links to other websites and other websites may reference or link to our Services. These other domains and websites are not controlled by us, and Intrigue does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Intrigue’s Services may include publicly accessible blogs, community forums, or private messaging features. The Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.

3.5     THIRD-PARTY PAYMENT PROCESSING
If you use the Services to make, receive or facilitate payments, we and Third-Party applications may collect certain financial information from you to process transactions, including your name, email address, address, financial account information and other billing information. Intrigue uses Quickbooks to process payments.

4.       ONWARD TRANSFER—INTRIGUE MAY DISCLOSE YOUR INFORMATION
4.1     INFORMATION WE SHARE
We may share your information as described in this Privacy Policy (e.g., with our Third-Party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission.

We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; (vi) analytics; and (vi) in connection with the provision of the Services. Intrigue has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

Business Partners. Intrigue may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. Intrigue may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Intrigue. Intrigue requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Intrigue provided them.

Content Visible to Others. When you create a Profile or post content to the Services, this information may be displayed to others. We are not responsible for privacy practices of the other users who will view and use the posted information.

Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, Intrigue may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Intrigue related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Services to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 5 below.

Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Intrigue policies or contracts; (v) to collect amounts owed to Intrigue; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Intrigue will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.

4.2     INTERNATIONAL DATA TRANSFERS
You agree that all Personal Information collected via or by Intrigue may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers in order to provide the Services. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. Where required by law, international transfers of Personal Information will be supported by an adequacy mechanism.

5.       OPT-OUT (RIGHT TO OBJECT TO PROCESSING)
5.1     GENERAL
You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to Intrigue’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting [email protected] Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

5.2     EMAIL AND TELEPHONE COMMUNICATIONS
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Intrigue and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

5.3     “DO NOT TRACK”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

5.4     COOKIES AND INTEREST-BASED ADVERTISING
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.

To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes.

6.        CONTROLLER AND RESPONSIBLE PARTY

When Intrigue receives and Processes Personal Information in order to provide our Services to customers (“Customer Data”), we will only Process such Customer Data on behalf of the particular customer, in order to provide our Services to that customer.  Our collection, use, storage, disclosure and other Processing of Customer Data is subject to our agreements with customers and their written instructions.  For the purposes of the EU General Data Protection Regulation and other relevant data protection laws, Intrigue is a “processor” and “service provider” under applicable privacy laws for Customer Data, and our customers are the “controllers” or “businesses” for their respective Customer Data.   
The controller of your Personal Information collected pursuant to this Privacy Policy (not including Customer Data) is: 
Intrigue Corp., 13359 N Hwy 183 #406-1064, Austin TX 78750 United States or [email protected]

7	ADDITIONAL INFORMATION FOR CERTAIN JURISDICTIONS

In this section, we provide additional information as required by certain privacy and data protection laws. 
6.1	DATA SUBJECT RIGHTS UNDER THE GDPR AND UK DATA PROTECTION ACT

To the extent that the GDPR or the UK Data Protection Act applies to Intrigue’s Processing of your Personal Information, you may have the following rights in relation to that Personal Information: 
•	to obtain from us confirmation as to whether or not Personal Information concerning you is being Processed, and where that is the case, to request access to the Personal Information. The accessed information includes – among others – the purposes of the Processing, the categories of Personal Information concerned, and the recipients or categories of recipient to whom the Personal Information have been or will be disclosed. You have the right to obtain a copy of the Personal Information undergoing Processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs;
•	to correct any Personal Information that we hold about you; 
•	to have your Personal Information removed under certain circumstances unless continued Processing is necessary by law; 
•	to have the Processing of your Personal Information restricted where you dispute its accuracy, if you think its Processing is unlawful, or if you otherwise object to its Processing, or when we no longer need your Personal Information and you need it in relation to a legal claim; 
•	to receive copies of your Personal Information under certain circumstances; 
•	to object at any time to any Processing of your Personal Information which has our legitimate interests as its legal basis. You may exercise this right without incurring any costs. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. The right to object does not exist, in particular, if the Processing of your Personal Information is necessary to take steps prior to entering into a contract or to perform a contract already concluded; 
•	to request that we change the manner in which we contact you for marketing purposes. You can request that we do not transfer your Personal Information to unaffiliated third parties for the purposes of direct marketing or any other purposes; 
•	to obtain a copy of, or reference to, the safeguards under which your Personal Information is transferred outside the EU/EEA/UK. We may redact data transfer agreements to protect commercial terms; and 
•	to complain to your national data protection regulator if you feel that any of your Personal Information is not being processed in accordance with the GDPR. 
•	to withdraw your consent, where the Processing of your Personal Information is based on consent (see the TRANSPARENCY/NOTICE—TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT section above); if you withdraw your consent we will stop Processing your Personal Information, unless we have another legal basis for doing so. 

To exercise any of these rights, make a complaint, or request any additional information, please contact us at 13359 N Hwy 183 #406-1064 Austin, TX 78750 United States or [email protected]  Please note that we may rely on applicable exemptions under EU, Member State or UK law in order to deny part or all of your request.  If we do so, we will inform you when responding to your request.

CUSTOMER DATA. If you would like to submit a request related to Customer Data, you should submit your request directly to the relevant Customer.  If we receive a request from a data subject related to Customer Data, we will attempt to identify and notify the relevant customer of the request and will provide reasonable assistance as required by law to support that customer in responding to a relevant data subject request.

6.2	ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

In this section, we provide additional information to California residents about how we handle their Personal Information, as required under California privacy laws including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other Personal Information that is exempt under the CCPA.   
 
A. 	CATEGORIES OF PERSONAL INFORMATION UNDER THE CCPA (Last Updated: February 23, 2021) 
 
While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed Personal Information about consumers in the prior 12 months (from the Last Updated date above).   
 
The table below identifies the categories of personal information (as defined by the CCPA) we have collected about consumers, as well as how we have disclosed such information for a business purpose. For more information about the business and commercial purposes for which we collect, use and disclose personal information, please see the TRANSPARENCY/NOTICE—TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT and the ONWARD TRANSFER—INTRIGUE MAY DISCLOSE YOUR INFORMATION sections above.  


Personal Information Collected 	May We  Disclose this Information?	Categories of Third Parties to Whom We May Disclose this Information
Categories 	Description 	 	 
Identifiers 	Includes direct identifiers, such as name, alias user ID, username and account number; email address, phone number, address and other contact information; IP address and other online or unique identifiers.  	Yes 
	•	service providers   
•	advisors and agents 
•	government entities and law enforcement 
•	affiliates and subsidiaries  
•	data analytics providers 
•	social networks 
•	internet service providers 
•	operating systems and third-
party 	platforms 	and applications 
Customer Records 	Includes personal information, such as name, account name, user ID, contact information, employment information and financial or payment information), that individuals provide us in order to purchase or obtain our products and services. For example, this may include information collected when an individual registers for an account, purchases or orders our products and services, or enters into an agreement with us related to our products and services. 	Yes
	•	service providers   
•	advisors and agents 
•	government entities and law enforcement 
•	affiliates and subsidiaries  
•	internet service providers 
•	operating systems, third-party platforms and applications 
 
Usage Data 	Includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, mobile apps and other Services, and our marketing emails and online ads. 	Yes 	•	service providers   
•	advisors and agents 
•	government entities and law enforcement 
•	affiliates and subsidiaries  
•	data analytics providers 

			• social networks 
Geolocation Data 	Includes precise location information about a particular individual or device. 	Yes 	•	service providers   
•	advisors and agents 
•	government entities and law enforcement 
•	affiliates and subsidiaries  
•	internet service providers 
•	operating systems, third-party platforms and applications 


7.        DATA RETENTION
Intrigue retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

8.       SECURITY OF YOUR INFORMATION
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services or sending an e-mail to you. You may have a legal right to receive this notice in writing.

9.      CHILDREN’S PRIVACY
The Services are not directed to children under 18 years of age, and Intrigue does not knowingly collect Personally Identifiable Information from children under 18  years of age. If you learn that your child has provided us with Personal Information without your consent, you may alert us at [email protected] If we learn that we have collected any Personal Information from children under 18, we will promptly take steps to delete such information.

10.    REDRESS/COMPLIANCE AND ACCOUNTABILITY
If you have any questions about our privacy practices, this Privacy Policy, or how to lodge a complaint with the appropriate authority, please contact Intrigue by email at [email protected] We will address your concerns and attempt to resolve any privacy issues in a timely manner.

11.    OTHER RIGHTS AND IMPORTANT INFORMATION
11.1  CHANGES TO OUR PRIVACY POLICY AND PRACTICES
This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services.

Revision to the Privacy Policy. We may revise this Privacy Policy in our sole discretion, so review it periodically. If you continue to visit this Site and use the services made available to you after such changes have been made, you hereby provide your consent to the changes.

Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, Intrigue will notify you by email or as otherwise required by applicable law. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Intrigue will endeavor to comply with the law or contract.

11.2  CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Except as otherwise provided in this Privacy Policy, Intrigue does not share Personal Information with Third Parties for their own marketing purposes.

12. DEFINITIONS
The following capitalized terms shall have the meanings herein as set forth below.

“Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Intrigue or to which Intrigue discloses Personal Information for use on its behalf.
“Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).

“Personal Information” includes other similar terms under applicable privacy laws – such as “personal data” and personally identifiable information.”  In general personal information includes any information that identifies, relates to, describes or is reasonably capable of being associated, or reasonably linked or linkable with a particular individual.
“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.

“Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Intrigue or Intrigue’s Agents.