marlo today, Ltd. ("Marlo," "we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our digital or online properties (including as applicable, our website and social media pages) as well as our marketing and other activities described in this Privacy Policy (collectively, the “Services”).

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This Privacy Policy does not apply to information that we process on behalf of our business customers. Our use of information that we process on behalf of our business customers is governed by our contractual agreements with such customers. If you have concerns regarding your personal information that we process on behalf of a business, please direct your concerns directly to that business.

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1. Information We Collect

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We may collect the following categories of personal information when you access or interact with our Services:

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Personal information that you provide to us. Personal information you may provide to use through the Service or otherwise includes:  

• Contact data, such as your first and last name, salutation, email address, mailing address, professional title and company name, and phone number. ‍
• Demographic data, such as your city, state, country of residence, and postal code
• Communications data based on our exchanges with you, including when you contact us through the Service, social media or otherwise.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party Sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

• Public sources, ​​such as government agencies, public records, and other publicly available sources.
• Private sources, such as data providers, social media platforms and data licensors.
• Marketing partners, such as joint marketing partners and event co-sponsors.
• Service providers that provide services on our behalf or help us operate the Services or our business.
• Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction. For example, we may receive your personal information from an entity we acquire or are acquired by, a successor, or assignee or any party involved in a business transaction such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with our Services, our communications and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, content you viewed or otherwise engaged with, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

For more information concerning our automatic collection of data, please see the “Tracking & Other Technologies” section directly below.

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2. Tracking & Other Technologies

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​​Cookies and other technologies. Some of the automatic data collection described above is facilitated by the following technologies:

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

For information concerning your choices with respect to the use of tracking technologies, see the “Your choices” section below.

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3. How We Use Your Personal Information

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We may use your personal information for the following purposes or as otherwise described as the time of collection:

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Service delivery and operations. We may use your personal information to:

• provide the Services and operate our business;
• enable security features of the Services;
• communicate with you about the Services, including by sending Service-related announcements, updates, security alerts, and support and administrative messages; and
• provide support for the Services, and respond to your requests, questions and feedback.

Service personalization, which may include using your personal information to:

• understand your needs and interests;
• personalize your experience with the Services and our Service-related communications; and
• remember your selections and preferences as you navigate webpages.

Service improvement and analytics. We may use your personal information to analyze your usage of the Services, improve the Services, improve the rest of our business, help us understand user activity on the Services, including which pages are most and least visited and how visitors move around the Services, as well as user interactions with our emails, and to develop new products and services. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

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Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the “Your choices” section below.
• Interest-based advertising. We, our service providers, and third-party advertising partners may use cookies and other technologies to collect information about your interaction (including the data described in the “Automatic data collection” section above) with the Services, our communications and other online services over time, and use that information to serve online ads that we or they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the “Your choices” section below.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Services; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see the “How we share your personal information’ section below.

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To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

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Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

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4. How We Share Your Personal Information

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We may share your personal information with the following parties (or as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection).

• Service providers. Third parties that provide services on our behalf or help us operate the Services or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).
• Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.
• Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.
• Partners. Third parties with whom we partner, including parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
• Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
• Business transferees. We may disclose your personal information in the context of actual or prospective business transactions (e.g., investments in or financings of Decagon, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Marlo as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

We do not sell your personal information for cross-context behavioral advertising.

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5. International Data Transfers

If you are located outside the United States, your information may be transferred to and processed in the U.S. or other jurisdictions that may not provide the same level of data protection. Where required, we implement appropriate safeguards such as Standard Contractual Clauses (SCCs).

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6. Your Choices

You have the following choices with respect to your personal information:

• Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us directly (see the “Contact Us” section below). Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
• Cookies and other technologies.  Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.
• Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
• Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:
• Browser settings. Changing your internet web browser settings to block third-party cookies.
• Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
• Platform settings. Certain platforms offer opt-out features that let you opt-out of use of your information for interest-based advertising. For example, you may be able to exercise that option for Google and Facebook, respectively, at the following websites:
  
  • Google
  • Facebook
• Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
  
  • Network Advertising Initiative
  • Digital Advertising Alliance.  
  • AppChoices mobile app, available here, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
• Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
• Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
• Your Opt-Out Responsibility: You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

7. Cookies and Tracking Technologies

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We use cookies and similar technologies to:

• Authenticate users.
• Analyze usage.
• Store preferences.
• Improve performance.

You may manage cookies through your browser settings or our cookie banner. Where required, we obtain your consent before setting non-essential cookies.

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8. Data Retention

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We retain your personal information only as long as necessary to fulfill the purposes for which it was collected, or as required by law. When no longer needed, we securely delete, return or irreversibly anonymize the data.

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9. Security

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We implement appropriate technical and organizational measures to protect your personal information from unauthorized access, use, disclosure, or destruction. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

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10. Children's Privacy

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Our Services are not intended for children under 18, and we do not knowingly collect personal information from individuals under 18.

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11. Google API Disclosure

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Marlo uses Google API services within the Marlo platform, which is only available to our business customers. Learn more here regarding the use of your data and these API services.

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Importantly, and in accordance with Google policies, Google Workspace APIs are not used to develop, improve, or train generalized AI and/or ML models.

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12. Updates to this Privacy Policy

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We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Services or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Services after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business. Depending on the kind of change we make to this Privacy Policy, we might notify you of the change or request your consent to it.

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13. Contact Us

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If you have questions or concerns about this Privacy Policy, or to exercise any of your rights, please contact us by email at privacy@marlo.today.