EFFECTIVE DATE: 4/19/23

Verb, Inc. (“Verb”) values your privacy. In this Data Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our website, www.verb.net, www.goverb.com, and any related applications owned by Verb, Inc. or any affiliated websites we host on behalf of our customers (together, our “Sites”), and the services available through our Sites (“Services”).

By visiting the Sites, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Sites or Services, and any dispute over privacy, is subject to this Policy and our Terms of Use(www.goverb.com/terms-of-use), including its applicable limitations on damages and the resolution of disputes. The Terms of Use are incorporated by reference into this Policy.

Verb’s privacy policy for learner-inputted responses in Verb activities:

Does Verb share the responses that I put into activities?

Verb offers a safe place to explore authentic and honest thoughts, emotions, and ideas related to yourself and work. That’s why Verb does not share individual learner responses in activities with managers, administrators, or others at your organization — or anyone else — without your expressed, written consent.

Additionally, the only personal identifiable information Verb gathers is name and email address, and we never share those with third parties.

What information is available to people who manage Verb at my company (admins) or my manager?

• Activity completion data
• Anonymous responses to Verb’s content relevancy question

Does anyone at Verb see my responses in activities?

Periodically, Verb’s Product team reviews learner responses to aggregate qualitative data and/or to improve the quality of the learning experience and design.

We’ve found that learners sometimes want to be recognized for their efforts on Verb to grow as leaders. To do this, we work with individual learners on a case-by-case basis to secure permission to review responses in activities and share any quotes.

THE INFORMATION WE COLLECT ABOUT YOU

INFORMATION WE COLLECT DIRECTLY FROM YOU THROUGH SITES. 

The type of information that we collect from you depends on your use of our Sites and our Services. When you visit our websites or use our applications, we may collect your name, contact information and any other information that you choose to provide to us. We will provide user data upon request and all data will be destroyed upon termination of the agreement by either side.

INFORMATION WE COLLECT AUTOMATICALLY. 

We may automatically collect the following information about your use of our Site or Services through cookies, web beacons, and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Sites and or use our services; and the referring URL, or the webpage that led you to our Site. Please see our Cookies Policy for more information on our use of cookies.

INFORMATION THAT WE COLLECT ABOUT YOU FROM SOCIAL NETWORKING SITES. 

You also may log into our Sites through Facebook or other social networking sites. If you do so, we will request your permission to your public profile and email. If you allow us to have access to this information, then we will have access to this information even if you have chosen not to make that information public. We store the information that we receive from these sites with other information that we collect from you or receive about you. For
information about how these sites may use and disclose your information, including any information you make public, please consult their privacy policies.

HOW WE USE YOUR INFORMATION 

We use your information, including your personal information, for the following purposes: 

• To provide our services to you, including to enable your entry in a competition, to communicate with you about your use of our services, to respond to your inquiries, and for other customer service purposes.
• To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Sites or our services.
• For marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters, information about competitions, or to otherwise contact you about information that may be of interest to you.
• To better understand how users access and use our Sites and services, both on an aggregated and individualized basis, and to improve our Sites and services and respond to user desires and preferences.
• For other research and analytical purposes, such as to examine trends in participation, success in campaigns and/or competition, as well as overall web usage.
• If you are an authorized user under an enterprise license, to track your progress through professional development, mentoring, and engagement activities and share such information with your employer and/or enterprise sponsor.

HOW WE SHARE YOUR INFORMATION 

We may share the information that we collect about you, including your personal information, as follows: 

• Enterprise Clients. If you are an authorized user under an enterprise license, we may share your information with your sponsor, which, in most cases, is your employer.
• Groups and Colleagues. If you are participating in activities on the Sites which provide for working in groups, we may share your information with colleagues in those groups.
• We may share your personal information with investors and other third parties to enable potential investors to search for new ventures and/or individuals.
• We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personally identifiable information will be subject to this Policy.
• Competition Sponsors. Our contest websites are hosted on behalf of competition sponsors. In most circumstances, we evaluate your submission on behalf of or in conjunction with the competition sponsor. We will provide your contact information and, depending on the contest, information about your submission with the contest sponsor. The competition sponsor will use your information in accordance with the competition rules and its own privacy policy, which might differ from this Policy.
• Social Media Users. Your social media username and profile picture may be visible to other users of our Services, regardless of whether they are connected to you via social media. In addition, there may be a reference to our Sites on social media pages.
• Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents that perform functions on our behalf.
• Upon Your Direction. If we have applications which allow you to share your content and work product with designees, we may share such information with your designees at your direction to do so.
• Business Transfers. If we are acquired by or merged with another entity, if substantially all our assets are transferred to another entity, or as part of a bankruptcy proceeding, or other business transfer, we may transfer the information we have collected from you to the other entity.
• In Response to Legal Process. We also may disclose the information we collect from you to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.. 
• To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which we are involved.
• Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.

USER-GENERATED CONTENT 

• You may post content on certain of our Sites to our forums and blogs, including your comments, pictures, and any other information that you would like to be available on our Sites. If you post content to our Sites, all the information that you post will be available to all visitors to our Sites. If you post your own content on our Site or Services, your posting may become public we cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.

CANADA’S ANTI-SPAM LEGISLATION

Verb has taken all reasonable steps to comply with Canada’s Anti-Spam Legislation. We only email contacts with whom we have had a business relationship or who have used the Service within the last 2 years, and people who may have enquired about an event in the last 6 months and people who have opted in to receive our newsletters. Should you receive an unsolicited email from Verb Inc. please email support@goverb.com and we will remove your details.

SPECIAL INFORMATION FOR CALIFORNIA CONSUMER

California residents may request a list of certain third parties to which we have disclosed personally identifiable information about you for their own direct marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting us at: support@goverb.com. Please allow up to thirty (30) days for a response.

THIRD-PARTY LINKS

Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

DO NOT TRACK POLICY

California law requires that operators of websites and online services disclose how they respond to a Do Not Track signal. Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked. Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to Do Not Track signal. We continue to work with the online industry to define a common understanding of how to treat Do Not Track signals.

In the meantime, you may opt out of receiving interest-based advertising from advertising networks that may be delivered on our platform and other websites by visiting the following websites. If you want to opt out of this online behavioral advertising, visit the following sites: http://www.aboutads.info/consumers and http://www.networkadvertising.org.

This will opt you out of many – but not all – of the interest-based advertising activities in which we or third parties engage. Choices you make may be browser and device-specific. If you delete your cookies or use a different browser or a different computer or device, you may need to update your opt-out choices. Other third-party Labs provide visitors with the ability to opt-out of receiving interest-based ads on their Labs that you need to control through your settings on that Lab. For example, to opt out of Google’s use of your online behavior for advertising purposes, visit Google’s Ad Settings page.

ACCESS TO MY PERSONAL INFORMATION 

You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time. At any time, you may request a list of the data we have collected on you and we will provide it within a reasonable amount of time. We also will comply with any request to delete all data we have collected on you. 

WHAT CHOICES DO I HAVE REGARDING USE OF MY PERSONAL INFORMATION? 

We may send periodic promotional emails to you (e.g., emails notifying you about competitions that may be of interest to you). You may opt-out of such communications by following the opt- out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails from us, we may still send you e-mails about your account or any Services you have requested or received from us.

CHILDREN UNDER 13 

Protecting the privacy of young children is especially important. Our Service is not directed to children under the age of 13, and we do not knowingly collect Personal Data from children under the age of 13 without obtaining parental consent. If you are under 13 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Data has been collected on the Service from persons under 13 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 13 years of age has obtained an Account on the Service, then you may alert us at support@goverb.com and request that we delete that child’s Personal Data from our systems.

SECURITY OF MY PERSONAL INFORMATION 

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. Additionally, all our data is stored in the cloud and hosted by only the most reputable, secure cloud storage companies. We do not store hard copies of our data at any time. Please be aware that despite our best efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

DATA RETENTION 

We only retain the Personal Data collected from a User for as long as the User’s account is active or otherwise for a limited period if we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:

• The contents of closed accounts are deleted within 3 months of the date of closure 
• Billing information is retained for a period of 7 years as of their provision to Verb in accordance with accounting and taxation laws 
• Information on legal transactions between Client and Verb is retained for a period of 7 years as of their provision to Verb in accordance with the general liability purposes. 

DATA TRANSFER 

We may transfer, process and store Personal Data we collect through the Services in centralized databases and with service providers located in the U.S. The U.S. may not have the same data protection framework as the country from which you may be using the Services. When we transfer Personal Data to the U.S., we will protect it as described in this Privacy Policy.

CHANGES AND UPDATES TO THIS POLICY 

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices regarding the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.

CONTACT US 

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at support@goverb.com.