Effective Date: August 14, 2023

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This policy describes how Almanac Labs, Inc. and Almanac Labs, Inc. dba Blaze.ai (“Almanac,” “we,” “us,” or the “Company”) collects, aggregates, stores, safeguards and uses the data and information (including non-public personal information, or “NPI”) provided by users through our website, blaze.ai (the “Site”); our online Software-as-a-Service platform including any related APIs (the “Platform”); content submitted by users, including you; as well as information collected by us through other means, including by email, over the phone, or in offline communications. This Platform and Site are operated by the Company and are referred to collectively herein as the “Services”. This policy is incorporated into and a material term of your registration and/or use of Almanac’s Services. By using any of the Services, you consent to the practices set forth in this Privacy Policy and the Almanac Terms of Use.

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We take your privacy and the security of your information seriously.

This policy explains:

• What information we collect, and how we use it
• Choices you can make about the way your information is collected and used
• How we protect personal information electronically and physically

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Information we collect

Information You Provide to Us

Almanac collects information from you when you choose to provide it to us through the Site, the Platform or through any other means. This may include when you create an account on the Site, request or register to use the Platform or other Almanac products or services, request information from us, sign up for newsletters or our email lists, use our Site, request customer or technical support, responses to surveys, entries into sweepstakes or contests, or otherwise contact us.  We may also collect the contents of messages or attachments that you may send to us, as well as other information you provide, and that may be associated with your communications

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We may offer interactive features such as forums, blogs, chat and messaging services, and social media pages. We and others who use our Services may collect the information you submit or make available through these interactive features. Any content you provide via the public sections of these features will be considered “public” and is not subject to the privacy protections referenced herein. By using these interactive features, you understand that the information provided by you may be viewed and used by third parties for their own purposes.

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We may post job openings and opportunities on the Site or other locations. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.

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The information we collect may include your name, address, email address, telephone or mobile phone number, photo, current company and position, work history, and other information relating to your employment or professional activities. You may be required to provide certain personal and/or business information to apply for and receive Almanac products services.

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Information We Automatically Collect

We may use cookies or other technologies (including pixel tags and web beacons), to automatically collect certain information when you visit our Site, utilize the Platform, or interact with our emails. For example, if you are responding to an offer, promotional email or other email from us, we may automatically populate your personal information into our system once you enter your offer code or similar identifying device or otherwise accept your offer or promotion. Additionally, we may automatically collect certain non-personal information from you such as your browser type, operating system, software version, user settings, Media Access Control (“MAC”) address, cookie identifiers, mobile carrier, mobile advertising, internet service provider, and Internet Protocol ("IP") address. We also may collect information about your use of the Platform, including the date and time of access, the areas or pages that you visit, the amount of time you spend using the Services, the number of times you return, whether you open, forward, or click-through emails, and other Services usage data.  Information we collect may be associated with accounts and other devices.  Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.

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We may also use third-party service providers to collect and process analytics and other information on our Services. These third-party service providers may use cookies and other technologies to collect and store analytics and other information. They have their own privacy policies addressing how they use the analytics and other information and we do not have access to, nor control over, third parties’ use of cookies or other tracking technologies.

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You may adjust your browser or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Site or take full advantage of all of our offerings. Check the "Help" menu of your browser or operating system to learn how to adjust your tracking settings or cookie preferences. Please note that our system may not respond to Do Not Track requests or headers from some or all browsers.

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How we use information we collect

Almanac uses the data and information you provide in a manner that is consistent with this Privacy Policy and applicable law. If you provide personal data for a certain reason, we may use the personal data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the personal data you provide to answer your question or resolve your problem. Also, if you provide personal data in order to obtain access to the Site or Services, we will use your personal data to provide you with access to such services and to monitor your use of such services.

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Almanac may also use your personal data and other personally non-identifiable information collected through the Site or the provision of the Services to help us improve the content and functionality of the Site or the Services, to better understand our users and to improve the Site and the Services. Almanac and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. If at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

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For example, we may use your data:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

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De-identified and Aggregated Information Use.

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We may use de-identified and/or aggregated information that can no longer be reasonably linked to you or your device from the information we collect. De-identified and/or aggregated information is not subject to this Privacy Policy, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

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Sharing of information we collect

Almanac is not in the business of selling your information. There are, however, certain circumstances in which we may share your personal data with certain third parties without further notice to you, as set forth below:

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Agents, Consultants and Third-Party Service Providers:

Almanac, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

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Business Partners:

At your request, we may provide information to third-party businesses to provide you with a product or service of interest to you. We may also provide information to third-party businesses with whom we jointly offer products or services.

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Business Transfers:

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, personal data may be part of the transferred assets.

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Related Companies:

We may also share your personal data with our corporate affiliates and subsidiaries, if any, for purposes consistent with this Privacy Policy.

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Legal Requirements:

Almanac may disclose your personal data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Almanac, (iii) act in urgent circumstances to protect the personal safety of users of the Site, the Services or the public, or (iv) protect against legal liability.

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Profile and User Content

If you have elected to share you profile and/or User Content, that information will be available to other users of the Platform. That may include your full name, a website, links to social media accounts, profile picture, your company and job, profiles that you are following, your location, and the length of time that you have been an Almanac user.

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Links to other websites

The Site may have links to third-party websites, which may have privacy policies that differ from our own. We do not control such sites and are not responsible for the practices of such sites, nor does any such link imply that Almanac endorses or has reviewed the third party site subject to such link. We encourage you to read the privacy policies of each third-party website and, if you have any questions or concerns, you must contact those sites directly. We do not endorse, screen or approve the content or practices of other websites or applications and visiting such sites or applications is at your own risk.

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Children and minors

Our Service is not offered to anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

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Data security

We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about our customers and Site visitors. While we make reasonable efforts to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any personal data to the Company via the Internet.

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Access to your personal information

To keep your personal data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct personal information in our possession that you have previously submitted via the Services.

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Information for EEA users

What Rights Do I Have?

Individuals located in the European Economic Area (EEA) have certain rights in respect of your NPI, including the right of access, rectification, restriction, opposition, erasure and data portability. Where possible, we rely on user consent as a lawful basis for processing personal data and obtain such consent in compliance with applicable laws.  In some cases, Almanac may process NPI pursuant to legal obligation or to protect your vital interests or those of another person.

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How May I Exercise My Individual Rights?

Almanac users may access and update their NPI through their account settings in the Almanac platform. Users located within the EEA may contact us with questions or requests regarding their NPI using the contact information below. Please note that Almanac may request additional information from you to verify your identity before we disclose any personal or account information. We only send marketing communications to users we believe to be located in the EEA with your prior consent, and you may opt out of such communications at any time by clicking the “unsubscribe” link found within Almanac email updates and changing your contact preferences. Please note, you will continue to receive essential account-related information, even if you unsubscribe from promotional emails.

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Who Can I Contact at Almanac Regarding Data Protection Issues?

Almanac has designated a Data Protection Officer to assist with data privacy and data protection issues.  You may contact him or her by emailing support@blaze.ai and addressing your questions or concerns to the Data Protection Officer.

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CalOPPA

"Do Not Track" Signals under the California Online Protection Act (CalOPPA)

We do not currently support Do Not Track ("DNT").  Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.  You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

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Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

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We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

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The payment processors we work with are:

Stripe

Their Privacy Policy can be viewed at https://stripe.com/us/privacy

PayPal / Braintree

Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

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California consumer privacy act

Categories of Personal Information We Collect

Along with the information in the Privacy Policy as a whole, the CCPA requires us to describe the information we collect in certain “categories.”  The categories we collect include:

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The Sources From Which the Categories of Personal Information Are Collected

We collect personal data directly from information you provide to us; indirectly from our affiliates, service providers, and other vendors; and indirectly through your interactions with websites or advertisements.

Business Purposes for Our Collection of Personal Information

The following is a list of the business purposes for our collection of information.

• Complete a purchase or provide the Services you have requested, including invoicing and accounting;
• Respond to your request for information and provide you with more effective and efficient customer service;
• Provide you with updates and information about the Services;
• Contact you by email, postal mail, or phone regarding our Services and third- party products, services, surveys, research studies, promotions, special events and other subjects that we think may be of interest to you;
• Help us better understand your interests and needs, and improve the Services, including through research and reports, and test and create new products, features, and services;
• Secure our websites and applications, and resolve technical issues being reported;
• Comply with any procedures, laws, and regulations that apply to us where it is necessary for our legitimate interests or the legitimate interests of others; and
• Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.

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Sharing of Categories of Personal Information

We may share categories of personal information to accomplish the various business purposes above and as described throughout this Privacy Policy.

CCPA Rights Disclosure

If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

• Inform you about the categories of personal information we collect or disclose about you and the categories of sources of such information;
• Inform you about the business or commercial purpose for collecting personal information and the categories of third parties with whom we share/disclose personal information (which is also disclosed in this Privacy Policy);
• Provide you with the specific pieces of personal information we collect about you; and
• Delete personal information we have about you.

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Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Products to you. You may only make such a request twice within a twelve-month period. Requests are generally free; however, we may charge a reasonable fee or deny your request if it is manifestly unfounded, excessive, or repetitive.

To make a CCPA request, please visit this page or contact us at support@blaze.ai. We will request information, which at a minimum will include your name and email address, to verify your identity. We may request additional information to verify your identity before responding to a request. Under the CCPA, you may have an authorized agent submit a request on your behalf, and we will collect certain authorization and verification information from the agent and you in such circumstances.

The CCPA further provides you with the right to receive information about the financial incentives that we offer to you, if any, and the right not to be discriminated against for exercising your rights under applicable law.

If you would like further information regarding your legal rights under California law, please contact us at support@blaze.ai.

California Do Not Sell Notice and Information Request

If you are a California resident, the CCPA provides you with the right to opt out of the "sale" of your "personal information." We may allow some of our advertising partners to collect certain pieces of information from our site visitors, such as device identifiers, cookies, advertising IDs, IP addresses, and usage activity, so that we and our partners can deliver ads that are more relevant to you. This type of information sharing with our advertising partners may be considered a "sale" under the CCPA. If you want to opt out of these activities, please contact us at support@blaze.ai.  Please note that some or all of the Products may not function if you choose to opt out of such activities.

If you are a California resident, California Civil Code Section 1798.83 you to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for the third parties’ direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding twelve calendar months. If you are a California resident and would like to make such a request, please submit your request in writing to:

Almanac, Inc.

2261 Market Street #4354

San Francisco CA, 94114

Attn:  California Privacy Rights

Shine the Light Disclosure

The California "Shine the Light" law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we disclose certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We currently do not disclose your personal information to third parties for their own direct marketing purposes.

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Information for Residents of the United States, generally.

In states where residents are allowed additional individual rights, we are committed to honoring those rights for such residents, including requests that may limit how we use and share your data, or requests to delete or correct inaccurate data, consistent with applicable law. Note that the applicable law may exempt certain personal information from such requests. To submit a request based on local law, please contact us at support@blaze.ai. We will respond to your request as required by law. If any circumstances cause a material delay in our response, you will be promptly notified.

Under certain state laws, certain residents may opt out of the sale or sharing of their personal information, or the use of their personal information for targeted advertising or profiling purposes. We will not sale your personal information unless we first provide you with a separate notice prior to such sale. To exercise a legal right you have to opt-out of or limit these activities, please contact at support@blaze.ai.

In certain situations, you may have the right to appeal the denial your request to exercise your rights. Please submit an appeal by contacting us at support@blaze.ai.

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If you have questions

If you have any questions about this Privacy Statement or the practices described herein, you may contact us at: support@blaze.ai.

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Changes to this statement

Almanac reserves the right to revise this Privacy Policy at any time. When we do, we will post the change(s) on the Site. This Privacy Policy was last updated on the date indicated above. Your continued use of the Site and the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

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