2Bfluent

2bfluent collects some Personal Data from its Users.

Personal Data collected for the following purposes and using the following services: Access to third-party accounts Facebook account access Permissions: Contact email; Email; Photos

Google Drive account access Personal Data: various types of Data as specified in the privacy policy of the service

Advertising Google AdSense, Facebook Lookalike Audience, Google Ads Similar audiences and Google Ad Manager Personal Data: Cookies; Usage Data

Direct Email Marketing (DEM) Personal Data: email address; first name; last name

Facebook Audience Network Personal Data: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data

Analytics Facebook Ads conversion tracking (Facebook pixel), Google Ads conversion tracking and Google Analytics Personal Data: Cookies; Usage Data

Google Analytics Advertising Reporting Features Personal Data: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service

Google Analytics Demographics and Interests reports Personal Data: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)

Backup saving and management Amazon Glacier Personal Data: various types of Data as specified in the privacy policy of the service

Contacting the User Contact form and Mailing list or newsletter Personal Data: email address; first name; last name

Phone contact Personal Data: phone number

Displaying content from external platforms Adobe Fonts and Google Fonts Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

Handling payments Stripe Personal Data: various types of Data as specified in the privacy policy of the service

Payment by bank transfer Personal Data: first name; last name; payment data

Hosting and backend infrastructure Amazon Web Services (AWS) Personal Data: various types of Data as specified in the privacy policy of the service

Interaction with data collection platforms and other third parties Mailchimp widget Personal Data: email address; first name; last name

Interaction with external social networks and platforms Facebook Like button and social widgets, LinkedIn button and social widgets and Twitter Tweet button and social widgets Personal Data: Cookies; Usage Data

Location-based interactions Non-continuous geolocation Personal Data: geographic position

Managing contacts and sending messages Mailchimp Personal Data: email address; first name; last name

SendinBlue Email Personal Data: Cookies; email address; Usage Data

Managing landing and invitation pages Mailchimp Landing Page Personal Data: email address; first name; last name

Managing support and contact requests ZOHO CRM Email Personal Data: various types of Data as specified in the privacy policy of the service

Registration and authentication Facebook Authentication and Google OAuth Personal Data: various types of Data as specified in the privacy policy of the service

Registration and authentication provided directly by 2bfluent Direct registration Personal Data: address; billing address; city; country; date of birth; email address; first name; last name; password; phone number; picture; profile picture; state; ZIP/Postal code

Remarketing and behavioral targeting Facebook Custom Audience and Twitter Tailored Audiences Personal Data: Cookies; email address

Facebook Remarketing, Google Ad Manager Audience Extension, Google Ads Remarketing, Google Signals, Remarketing with Google Analytics and Twitter Remarketing Personal Data: Cookies; Usage Data

Tag Management Google Tag Manager Personal Data: Usage Data

Segment Personal Data: Cookies; Usage Data

User database management SendinBlue Marketing Automation Personal Data: Cookies; email address; Usage Data

Further information about Personal Data The Service is not directed to children under the age of 13 Users declare themselves to be adult according to their applicable legislation. Minors may use 2bfluent only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use 2bfluent.

Personal Data collected through sources other than the User The Owner of 2bfluent may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing. Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

Automated decision-making Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. 2bfluent may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. 2bfluent adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law. Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties. The rationale behind the automated decision making is:

to enable or otherwise improve the decision-making process; to grant Users fair and unbiased treatment based on consistent and uniform criteria; to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.; to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within 2bfluent, Users can check the relevant sections in this document. Consequences of automated decision-making processes for Users and rights of Users subjected to it As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken. In particular, Users have the right to:

obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision; challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis; request and obtain from the Owner human intervention on such processing. To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

Privacy Shield participation: data transfers from the EU and Switzerland to the United States The Owner participates in and complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States. The policies and rights outlined below are therefore equally and explicitly applicable to Users from Switzerland, except if stated otherwise. The Owner has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.

If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view the Owner’s certification, please visit https://www.privacyshield.gov/welcome (or find the direct link to the certification list of Privacy Shield participants maintained by the Department of Commerce https://www.privacyshield.gov/list).

What does this mean for the European User?

The Owner is responsible for all processing of Personal Data it receives under the Privacy Shield Framework from European Union individuals and commits to subject the processed Personal Data to the Privacy Shield Principles.

This, most importantly, includes the right of individuals to access their personal data processed by the Owner.

The Owner also complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, which means that it remains liable in cases of onward transfers to third parties.

With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, the Owner is subject to the investigatory and regulatory enforcement powers of the FTC, if not stated otherwise in this privacy policy.

The Owner is further required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Dispute resolution under the Privacy Shield

In compliance with the Privacy Shield Principles, the Owner commits to resolve complaints about its collection or use of the User’s Personal Data. European Union individuals with inquiries or complaints regarding this Privacy Shield policy should first contact the Owner at the contact details supplied at the beginning of this document referring to “Privacy Shield” and expect the complaint to be dealt with within 45 days.

In case of failure by the Owner to provide a satisfactory or timely response, the User has the option of involving an independent dispute resolution body, free of charge.

In this regard, the Owner has agreed to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to data transferred from the EU. The User may therefore contact the Owner at the email address provided at the beginning of this document in order to be directed to the relevant DPA contacts.

Under certain conditions – available for the User in full on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint) – the User may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Contact information Owner and Data Controller 2bfluent ltd - 1 Samuel Ogden Street, Manchester, M17AX (UK)

Owner contact email: admin@2bfluent.com