PRIVACY NOTICEs

Last updated   August 6, 2024

This privacy notice for Nemo Applications B.V. (doing business as Lasso Moderation), established in Haarlem, the Netherlands at Kazerneplein 5 (2023GL) ("Lasso Moderation", "we", "us" or "our"), describes how and why we might collect, store, use, and/or share ("process") your store, use, and/or share ("process") your personal data, as referred to in the General Data Protection Regulation ("Personal Data") when you use our services ("Services"), such as when you:

• Visit our website at https://www.lassomoderation.com/;

• Make us of our SaaS-services/platform

• Engage with us in other related ways, including any sales, marketing, or events

In this privacy notice we explain to you which of your Personal Data we process and for what purposes we do so.

We believe that careful handling of Personal Data is of great importance. Personal Data is therefore processed carefully and in accordance with this privacy notice and the applicable laws and regulations.

This means, amongst others, that we:

• Clearly define our purposes before we process your Personal Data, via this privacy notice

• Store as little Personal Data as possible and only process the Personal Data that is necessary for our purposes

• Only process Personal Data if there is a valid basis

• The necessary security measures are taken to protect your Personal Data. We also impose these obligations on parties that process Personal Data for us

• Respect your rights, such as the right to access, correction, data portability or deletion of your Personal Data processed by us

Do you have any questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@lassomoderation.com and we will help you further.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. You can also click here to go directly to our table of contents.

When does this privacy notice apply? This privacy notice applies when you visit, use, or navigate our Services, and we process your Personal Data as a controller. Click here to learn more.

What Personal Data do we process? When you visit, use, or navigate our Services, we may process Personal Data depending on how you interact with Lasso Moderation and the Services, the choices you make, and the services and features you use. Click here to learn more.

Do we process any sensitive Personal Data? We do not process sensitive Personal Data.

Do we receive any Personal Data from third parties? We do not receive any information from third parties.

How do we process your Personal Data? We process your Personal Data to provide, improve, and administer our Services, to communicate with you, for security and fraud prevention, and to comply with laws and regulations. We may also process your Personal Data for other purposes with your consent. We process your Personal Data only when we have a valid legal reason to do so. Click here to learn more.

In what situations and with which parties do we share Personal Data? We may share information in specific situations and with specific third parties. Click here to learn more.

How do we keep your Personal Data safe? We have organizational and technical processes and procedures in place to protect your Personal Data. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your Personal Data. Click here to learn more.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your Personal Data. Click here to learn more.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us at info@lassomoderation.com. We will consider and act upon any request in accordance with applicable data protection laws and regulations.

Want to learn more about what Lasso Moderation does with any Personal Data we collect? Click here to review the notice in full.

TABLE OF CONTENTS

1. WHEN DOES THIS PRIVACY NOTICE APPLY?

2. WHAT PERSONAL DATA DO WE COLLECT?

3. HOW DO WE PROCESS YOUR PERSONAL DATA?

4. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL DATA?

5. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

7. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

8. HOW DO WE KEEP YOUR PERSONAL DATA SAFE?

9. DO WE COLLECT PERSONAL DATA FROM MINORS?

10. WHAT ARE YOUR PRIVACY RIGHTS?

11. CONTROLS FOR DO-NOT-TRACK FEATURES

12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

13. DO WE MAKE UPDATES TO THIS NOTICE?

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

1. WHEN DOES THIS PRIVACY NOTICE APPLY?

This privacy notice applies when you visit, use, or navigate our Services. This privacy notice also only applies to processing of Personal Data by us as a data controller. If an organization processes your Personal Data through our Services, then this organization is the controller. We are then the data processor. In that case, this privacy notice does not apply. You should check the privacy notice of the data controller to read more about the handling of your Personal Data.

2. WHAT PERSONAL DATA DO WE COLLECT?

Personal Data you disclose to us

In Short: We collect Personal Data that you provide to us.

We collect Personal Data that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The basis for the processing of this Personal Data is Section 6 (1) a of the GDPR: you have given us permission to process this data, because you have chosen voluntarily to provide the Personal Data.

If the Personal Data is necessary for providing the Services, we may also invoke Section 6 (1) b of the GDPR: the processing is in that case necessary for the performance of the agreement between us and you. After all, without this information, we cannot provide our Services to you.

Personal Data Provided by You. The Personal Data that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The Personal Data we collect may include the following:

● names

● phone numbers

● email addresses

● usernames

● passwords

● ip addresses

Sensitive Information. We do not process sensitive information.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Google, Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the Personal Data described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

All Personal Data that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such Personal Data.

Information automatically collected

In Short: Some information - such as your Internet Protocol (IP) address and/or browser and device characteristics - is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information may qualify as Personal Data. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The legal basis for the processing of this Personal Data is Section 6 (1) f of the GDPR: we have a legitimate interest in this processing. This information is required for the Services to function properly.

The information we automatically collect includes:

● Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

● Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

3. HOW DO WE PROCESS YOUR PERSONAL DATA?

In Short: We process your Personal Data to provide, improve, and administer our Services, to communicate with you, for security and fraud prevention, and to comply with laws and regulations. We may also process your Personal Data for other purposes with your consent.

We process your Personal Data for a variety of reasons, depending on how you interact with our Services, including:

● To facilitate account creation and authentication and otherwise manage your account. We may process your Personal Data so you can create and log in to your account, as well as keep your account in working order.

● To deliver and facilitate delivery of services to you. We may process your Personal Data to provide you with the requested service.

● To send administrative information to you. We may process your Personal Data to send you details about our products and services, changes to our terms and policies, and other similar information.

● To request feedback. We may process your Personal Data when necessary to request feedback and to contact you about your use of our Services.

● To send you marketing and promotional communications. We may process the Personal Data you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below).

● To identify usage trends. We may process Personal Data about how you use our Services to better understand how they are being used so we can improve them.

● To save or protect an individual's vital interest. We may process your Personal Data when necessary to save or protect an individual's vital interest, such as to prevent harm.

4. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL DATA?

We only process your Personal Data when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws and regulations, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests. The specific legal bases are mentioned in the section 2. WHAT PERSONAL DATA DO WE COLLECT?

5. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

In Short: We may share Personal Data in specific situations described in this section and/or with the following third parties.

We do not sell your Personal Data to third parties. We may, however, engage third parties who process certain Personal Data under our responsibility.

Some of these third parties are located in the European Economic Area. Some third parties may be located in countries outside the European Economic Area, such as the United States. In order to protect your Personal Data and to comply with our legal obligations, we will only engage third parties as processors if those third parties offer sufficient safeguards for the protection of your Personal Data. We will conclude a data processing agreement with these third parties, which provides appropriate protection with regard to your Personal Data. These third parties may only process the Personal Data in the context of the assignment we have given them, and not for any other purposes.

We also may need to share your personal information in the following situations:

● Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain Personal Data about you.

Our Services may offer you the ability to register and log in using your third-party social media account details (like your Google, Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your Personal Data by your third-party social media provider. We recommend that you review their privacy notices to understand how they collect, use, and share your Personal Data, and how you can set your privacy preferences on their sites and apps.

7. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

In Short: We keep your Personal Data for as long as necessary to fulfill the purposes for which they were collected or used, unless otherwise required by law.

We will only keep your Personal Data for as long as it is necessary for the purposes for which they were collected or used, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

8. HOW DO WE KEEP YOUR PERSONAL DATA SAFE?

In Short: We aim to protect your Personal Data through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any Personal Data we process. However, despite our safeguards and efforts to secure your Personal Data, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your Personal Data.

9. DO WE COLLECT PERSONAL DATA FROM MINORS?

In Short: We do not knowingly collect Personal Data from children under 18 years of age.

We do not offer our Services to children under 18 years of age and do not knowingly collect Personal Data from children under 18 years of age. By using the Services, you represent that you are at least 18 years of age. If we learn that Personal Data from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such Personal Data from our records. If you become aware of any Personal Data we may have collected from children under age 18, please contact us at info@lassomoderation.com.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, you have rights that allow you greater access to and control over your Personal Data, which we will allow you to exercise. In some regions you have certain rights under applicable data protection laws. These may include:

● The right to inspect the Personal Data that we process of you

● If you have given consent for the processing of your Personal Data, you also have the right to withdraw this consent

● The right to exercise data portability

● The right to have errors corrected

● The right to have outdated Personal Data deleted

● The right to object to a particular use of Personal Data

You can exercise such right by making a request by contacting us via the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

Withdrawing your consent: If we are relying on your consent to process your Personal Dara, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below or by updating your preferences.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you - for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can:

● Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Handling of requests We will consider and act upon any request in accordance with applicable data protection laws and regulations. You can only exercise your rights to the extent that the law grants you these rights. To ensure that a request has been made by you, we may ask you to send a copy of your identity document with this request. We only ask for this if we deem it necessary to identify you. We destroy the copy of your identity document immediately after we have identified you.

Right to complain If you have a complaint about the way we process your Personal Data, you can contact us. We then try to find a solution together. If you are located in the European Economic Area or UK and you believe we are unlawfully processing your Personal Data, you also have the right to complain to the competent data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Questions/comments If you have questions or comments about your privacy rights, you may email us at info@lassomoderation.com.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a "resident" as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

We will use and retain the collected personal information as needed to provide the Services or for:

● Category A - As long as the user has an account with us

● Category B - As long as the user has an account with us

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

● Receiving help through our customer support channels;

● Participation in customer surveys or contests; and

● Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at info@lassomoderation.com, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

Nemo Applications B.V. has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Nemo Applications B.V. will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data - Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed - Request to know

Depending on the circumstances, you have a right to know:

● whether we collect and use your personal information;

● the categories of personal information that we collect;

● the purposes for which the collected personal information is used;

● whether we sell or share personal information to third parties;

● the categories of personal information that we sold, shared, or disclosed for a business purpose;

● the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;

● the business or commercial purpose for collecting, selling, or sharing personal information; and

● the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer's sensitive personal information.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

● You may object to the processing of your personal information.

● You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.

● You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

● You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at info@lassomoderation.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

13. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws and regulations.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at info@lassomoderation.com.