Privacy Policy

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Last Revised: Nov 6, 2023

This Privacy Policy explains the categories of personal information that Censo (“Censo” or “we”) collects, whether through our website or through links we make available on third-party sites or platforms (collectively, our “Services”), how we process that information, and for what purposes. This Privacy Policy also explains how we can use and disclose, and how we protect, such information, as well as your choices regarding your information. Throughout this Privacy Policy, "information" includes personal information about you. We follow this Privacy Policy in accordance with applicable law.

Please note that when you provide information to us through a third-party site or platform, that same information may be separately collected by that third-party site or platform. This Privacy Policy covers the information we collect. The information the third-party site or platform collects is subject to that site or platform’s privacy policy and practices. Privacy choices you make on that third-party site or platform will not apply to our use of the personal information we collect from you.

PLEASE READ THIS PRIVACY POLICY AND OUR TERMS OF USE (THE “TERMS”) https://censo.co/legal/terms CAREFULLY. IF YOU DO NOT AGREE WITH THE PROVISIONS OF THIS PRIVACY POLICY OR THE TERMS, DO NOT USE OR ACCESS THE SERVICES. BY USING OR ACCESSING THE SERVICES, OR BY CLICKING A BUTTON OR CHECKING A BOX MARKED “I AGREE” (OR SOMETHING SIMILAR), YOU SIGNIFY THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO THE PROVISIONS OF THIS PRIVACY POLICY AND THE TERMS (COLLECTIVELY THE “TERMS”).

Information We Collect

We may collect personal information (information that directly or indirectly identifies a specific individual, such as name, address, email, or telephone number) and anonymized information (information that doesn’t, and can’t reasonably be used to identify, a specific individual). When anonymous information is directly or indirectly associated with personal information, we treat it as personal information. We may use personal information and anonymized information to create aggregate information (information about groups of people that can’t be used to identify individuals):

• Information You Provide. Personal Information you provide when you sign up to be on our email list or to otherwise receive information from us, participate in a survey, answer a questionnaire, or enter a promotion, such as your name, country of residence, gender, date of birth, email address, username, and password
• Information Provided by Third Parties. Information we receive about you through our service providers or from other parties

We may also automatically collect other information from or about you, including:

• usage, viewing, technical, and device data when you use our website, including your browser, platform, or device type, unique device identifier, operating system, mobile network information, IP address, software and hardware attributes, and your internet service provider’s domain name
• your geographic location, where we are permitted by law to process this information, including precise or approximate location information provided by a mobile or other device interacting with one of our Services or associated with your IP address or other online or device identifier
• information regarding your access to and use of the Services, such as content viewed or downloaded, landing pages, how often you use the Services, browsing activity, dates and times of access, pages viewed, forms you complete or partially complete, and your preferences
• whether you open an email and your interaction with that email’s content, search terms, error logs, and similar information
• anonymized information
• aggregated information

How We Collect Information

We collect information from or about you when you use or access the Services, request information from us, participate in surveys, questionnaires, or promotions, or participate in other activities on our Services.

We, along with our service providers and other third parties from whom we acquire information, may automatically collect information, including whether or not you are logged in or registered on any of our Services, through cookies, web beacons, tags, pixels, application analytics software, software development kits, application program interfaces, Web beacons and other technologies. Please see "Cookies and Other Online Tracking Technologies; Do Not Track" below for more information, including how to disable cookies and make choices with respect to data collection by online tracking technologies.

We may obtain information about you from other sources to update or supplement the information you provide or we collect automatically, including from social networking services, publicly accessible sources, our service providers, and other third parties. Applicable law may require that you authorize the third party to share your information with us before we can acquire it. To the extent we receive any personal information about you from any such source, this Privacy Policy will apply to that information.

How We Use Your Information

Subject to applicable law and the choices and controls on the use of your information that may be available to you, we may use the information that we collect from and about you or the devices associated with you, for any of the following purposes:

• Services Provision. To provide the Services to you, troubleshoot, and provide support. We may also share information with third parties when it is required to do any of the foregoing
• Communication. To communicate with you, including to respond to your inquiries, provide information, content, and notifications of changes to our Services, and to request feedback or completion of a survey or questionnaire
• Personalization. To personalize your experiences with us, including to remember your interests and preferences, customize the content we provide to you or the content, product, and service recommendations we make to you, facilitate your interactions with us, track and categorize your activity and interests on the Services, and enrich your experience on the Services
• Marketing and Advertising. To advertise and market to you, including sending you promotional communications, customizing the marketing and advertising that we show you, and presenting you with relevant offers. We may also run advertising on other websites and applications through our advertising display partners
• Analytics. To provide, operate, develop, analyze and improve the Services, including through surveys and other user research and analytics tools
• Our Business Purposes. For our business purposes, such as to meet our contractual and legal obligations, operate and improve on our lawful business activities, and detect and prevent misuse of our products and services and activities that may violate our policies, pose safety issues, or be fraudulent or illegal
• Legal and Safety Purposes. For legal and safety purposes, including to defend or protect us, you, or others from harm or in legal proceedings, protect our rights, protect our security and the security of our systems and customers, respond to court orders, lawsuits, subpoenas, and government requests, address legal and regulatory compliance, comply with our license obligations, enforce the Terms, or notify you of product recalls or safety issues
• Anonymized Information. To collect, process, and create anonymized information, whether ourselves or through a service provider or other third party, and to use and allow any party to use for any purpose that anonymized information
• Aggregated Information. To collect, process, and create aggregated information, whether ourselves or through a service provider or other third party, and to use and allow any party to use for any purpose that aggregated information
• Other Reasons With Your Consent. For any other purpose for which you provide your consent to us or request that we process your information

Sharing Your Information with Other Parties

We will not share your information with third parties other than in limited circumstances and subject to applicable law, including:

• Our Service Providers. When companies perform services on our behalf, such as fulfilling transactions, monitoring compliance with and enforcing our Terms, auditing interactions and transactions with users, detecting and preventing fraud, addressing security issues, fixing errors, helping us with advertising and marketing, maintaining accounts, providing customer service, helping with our internal research and development, verifying product and service quality or safety, and performing any of the other actions or activities allowed under this Privacy Policy. These companies may not use your personal information for purposes other than those we request or as required by law
• At Your Direction. When you direct us to share your personal information with another party, such as by signing up to receive offers and promotions about their products or by directing us to link the information you have provided to us with a social networking platform. Please note that once we share your personal information with another party in the foregoing circumstances, the information received by the other party is controlled by that party and becomes subject to its privacy practices, not this Privacy Policy. Please see "Your Choices Regarding Your Personal Information" below.
• Change of Control. As part of a corporate transaction, such as a merger or sale of assets, divestiture, joint venture, securities offering, financing, bankruptcy, reorganization, liquidation, or dissolution. In such event, your information can be used subsequently by the other party or parties involved in that business transaction
• Analytics. For analytics, including to understand how you use the Services, determine how you access the Services, and improve the Services
• Compliance With Law. To comply with legal processes or applicable law, to enforce or apply the Terms, to ensure the safety and security of us, our users, and third parties, to protect our rights and property and those of our users and third parties, and in other cases where we have a good faith belief that disclosure is required by law
• Anonymized and Aggregated Information. We can disclose anonymized information and aggregated information to any party for any purpose
• Other Reasons With Your Consent. For any other purpose for which you provide your consent to us or request that we process your information

You can choose not to disclose certain information. Please see “Your Choices Regarding Your Personal Information”, "Cookies and Other Online Tracking Technologies; Do Not Track," “Children's Privacy,” and “How to Contact Us” below.

Your Choices Regarding Your Personal Information

You have choices about our collection and use of your information which you can exercise by . contacting us or using various tools we may provide.

For example, you can:

• Change Your Information. Make changes to your information, such as re-scanning your Face through the Censo App. We may take reasonable steps to verify your identity before providing access to your information or making changes to it.
• Change Your Communication Preferences. Make changes regarding receiving notices from us by changing your preferences for the Censo App on your mobile device or by emailing us at info@censo.co. You also can opt out of receiving marketing emails from us by following the opt out or unsubscribe instructions in each such email. You may, however, continue to receive service-related and other non-marketing emails.
• Withdraw Consent. Withdraw your consent to our use or disclosure of your information at any time by emailing us at info@censo.co We will respond to requests to control your personal information as required by applicable law.
• Control Online Tracking Technologies. Use certain controls to address cookies and other online tracking technologies. Please see “Cookies and Other Online Tracking Technologies; Do Not Track” below.

In some circumstances, your ability to access or control your personal information will be limited, as required or permitted by applicable law. Please be aware that if you do not provide information that we request, we may not be able to provide certain Services to you, and some of our Services may not fully function as intended.

Cookies and Other Online Tracking Technologies; Do Not Track

We, along with our service providers and other third parties, use cookies, web beacons, tags, flash cookies or local shared objects, persistent device identifiers, application analytics software, and other tracking technologies to collect information about your activities and activities that occur on your devices or on our Services. The data collected by these technologies is used:

• to personalize the Services for you, such as to remember who you are when you return to a Service or to provide content and advertising based on your preferences, location, and use of the Services
• analyze the use of our Services, including user traffic
• improve and optimize the Services

We may collect this tracking data whether or not you are logged in or have an account on our Services and, if you have provided us with your personal information (such as by signing up to review our newsletter), we may associate this tracking data with your personal information, in which case we will also treat the tracking data as your personal information. Our third party service providers who collect tracking data on our behalf may provide you with the option to choose not to be tracked.

Advertisers and other third parties may also collect tracking data about your activity on our Services, on third party sites and applications, and on your devices and applications. This tracking data may be used to decide which ads you see on third-party sites and applications.

Definitions of some of the tracking technologies mentioned, as well as information about your choices with respect to them, are set forth below.

• Cookies. Cookies are small text files that are stored on your computer. Persistent cookies remain on the computer of the person who access the Services after the browser has been closed. Session cookies exist only during an online session and disappear from the computer when the browser software is closed.

You can instruct your browser to stop accepting cookies, but if you do not accept cookies, you may not be able to use all portions or functionality of the Services. Please see www.allaboutcookies.org for additional information about cookies.

• Web beacons. Web beacons or tags (small images embedded into websites or emails that send information about your computer when you access or use the Services or open an email we send you) can be used by either us or a service provider or other third party.

Service providers and other third parties may collect personal information about an individual user’s or device’s online activities over time and across different internet services when a user or device accesses the Services and other online services. Below are resources regarding online tracking technologies:

• Google Analytics. Please see https://policies.google.com/privacy, https://policies.google.com/technologies/partner-sites, https://www.google.com/analytics/terms/, and https://tools.google.com/dlpage/gaoptout.
• Ad Networks. You may exercise choice over how information about your interests is used by ad networks to deliver you relevant advertising. To learn how to opt out of ad network interest-based advertising in the United States, please visit the Digital Advertising Alliance at https://optout.aboutads.info/?c=2&lang=EN and the Network Advertising Initiative at https://optout.networkadvertising.org/?c=1#!%2F.
• Meta Companies. For Facebook, Instagram, Instagram, Messenger, and other products and features offered by Meta Platforms, Inc. please see https://m.facebook.com/privacy/policy/version/20220104/?_se_imp=0XfB68Xc15maLrM4g.
• Do not track. At this time, we do not respond to “Do Not Track” signals sent from web browsers or other mechanisms that provide users the ability to exercise choice regarding the collection of personal information about an individual user's online activities over time and across service provider, third party internet services, and other third-party services.

Children's Privacy

We do not knowingly collect personal information from individuals under age thirteen (13). If you are under age thirteen (13), please do not access, use, or submit any personal information through or in connection with the Services. If you have reason to believe that we may have accidentally received personal information from an individual under age thirteen (13), please immediately email us at info@censo.co.

How We Protect Your Information

We take physical, technological, and administrative measures to protect the information that you provide through or in connection with the Services from accidental or unlawful destruction, loss, or alteration, and from unauthorized access, use, or disclosure. Please be aware, however, that no security measures can guarantee absolute security. No Internet, text message, email, or application transmission or method of electronic storage is ever fully secure or error free. Text message, email, and other communications, including those sent through or in connection with the Services, may not be secure. You should use caution whenever submitting information through or in connection with the Services and take special care in deciding which information you provide to us.

Storage

By using or visiting the Services, your personal information will be transferred to and processed in the United States and any other country or jurisdiction at our sole discretion. The laws that apply to the use and protection of personal information in the United States or other countries or jurisdictions in which we transfer or process personal information may be different from the laws and protections in your country.

Retention

We will retain your personal information for as long as reasonably necessary for the purposes outlined in this Privacy Policy, while we have a legitimate business need to do so in connection with your user account (if you have one), or as required by law (for example, for legal, tax, accounting, or other purposes), whichever is longer.

If you have elected to receive email communications from us, we retain information about your email preferences until you opt out of receiving our email communications and in accordance with our policies.

To determine the appropriate retention period for the categories of your personal information, we will consider the amount, nature, and type of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we use your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Residents of Europe

This section of our Privacy Policy provides certain required information to persons located in the European Union (“EU”), a European Economic Area (“EEA”) member state, or the United Kingdom (“UK”), and to persons with respect to whom the processing of their personal information may have actual or potential effects in Switzerland. Before we collect any Personal Information, you are entitled under the General Data Protection Regulation (“GDPR”), the United Kingdom General Data Protection Regulation (“UK-GDPR”) and the revised Swiss Federal Act on Data Protection (“revFADP”) to the information in this section of our Privacy Policy.

Legal Basis for Processing
We will only process your personal information when we have a lawful basis for doing so and only for the purposes set forth in this Privacy Policy. We may also seek your prior consent or rely on some other lawful basis to process your personal information.

Additional Rights
If you use our sites and are located in the EU, an EEA member state, or the UK, or the processing of your personal information may have actual or potential effects in Switzerland, you are entitled by law to access, correct, amend, or delete personal information about you that we hold. A list of these rights is below. Please note that these rights are not absolute and certain exemptions may apply to specific requests that you may submit to us.

• The right to access. You have the right to ask us for copies of your personal information. When making a request, please provide an accurate description of the personal information to which you want access. We may charge a reasonable fee based on administrative cost.
• The right to rectification. You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• The right to erasure. You have the right to ask us to erase your personal information in certain circumstances, including your personal information must be erased to comply with a legal obligation under EU, an EEA member state, UK, or Swiss law.
• The right to restrict processing. You have the right to ask us to restrict the processing of your personal information in certain circumstances, including: (i) when the accuracy of the personal information is brought into question, or (ii) when we no longer need the personal information for the purposes of the processing but you require such personal information for the establishment, exercise, or defense of a legal claim.
• The right to data portability. You have the right to ask that we transfer the personal information you gave us from one organization to another, or give it to you.
• The right to lodge a complaint with the supervisory authority. If you believe your rights under the GDPR have been violated, the GDPR gives you the right to file a complaint with your supervisory authority. A list of supervisory authorities is available here: https://edpb.europa.eu/about-edpb/about-edpb/members_en. If you believe your rights under the UK-GDPR have been violated, the UK-GDPR gives you the right to file a complaint with the Information Commissioner’s Office at https://ico.org.uk/make-a-complaint/data-protection-complaints/personal-information-complaint/. If you believe your rights under the revFADP have been violated, you have the right to enforce your claims in court or to file a complaint with the competent data protection authority.
• The right to withdraw consent. If we obtain your written consent to collect and process your personal information, you can subsequently withdraw such consent as to any further processing of information by contacting us at info@censo.co.
• The right to object to processing. You have the right to object to the processing of your personal information that is based on legitimate interests. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests or which override your rights and freedoms, or we can demonstrate the processing is for the establishment, exercise, or defense of legal claims. You can object to the processing of your personal information by contacting us at info@censo.co.
• Automated decision-making. To the extent that we engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you, you have the right not to be subject to such decision-making.

To exercise these rights please contact us at info@censo.co. For your protection, we may need to verify your identity before responding to your request. In the event that we refuse a request, we will provide you a reason as to why.

Cross-Border Transfers of Personal Information

Personal information that you provide while in the EU, an EEA member state, the UK, or Switzerland will be transferred to the United States. The GDPR, the UK-GDPR, and the revFADP permit such transfer when necessary for the performance of a contract between you and us, if we obtain your explicit consent to such transfer, or if it is in our legitimate interest to transfer the personal information. The laws in the United States may not be as protective of your privacy as those in your location. When we transfer personal information from the EU, an EEA member state, the UK, or Switzerland, we will use various legal mechanisms, including contracts such as the standard contractual clauses published by the European Commission under Commission Implementing Decision 2021/914, to help protect your rights.

Retention of Your Personal Information

We will retain your personal information as described in “Retention” above.

How To Contact Us

If you have any questions or comments about this Privacy Policy, please contact us as follows.
Email: info@censo.co
Phone: 646.688.4722

Changes to this Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time and from time to time. If we update or modify this Privacy Policy, you will be required to accept the updated or modified Privacy Policy in order to continue using the Services. If you do not agree to the updated or modified Privacy Policy, you may not continue to access or use the Services. This Privacy Policy was made effective on the date indicated above.

Conflicts

If any of the terms of this Privacy Policy conflict with any of the terms of the Terms, the terms of this Privacy Policy shall control with respect to the subject matter of this Privacy Policy.