Privacy Policy

AssHero takes privacy seriously. This privacy policy describes the personal data that AssHero collects when you use a AssHero Service, the purposes for which your personal data is used, and your choices regarding its use.

When we say “‘AssHero”, “we”, and “us,” we mean AssHero.com on behalf of itself and its affiliates.

Any capitalized terms not defined herein shall have the meaning assigned to them in each applicable set of Services terms.

How to Read this Privacy Policy

This privacy policy consists of two parts:

• Part One sets out the privacy practices that apply across the Services.
• Part Two sets out the privacy practices specific to a AssHero business and one or more of its Services indicated in that section, including:
• Personal data collected and processed
• Additional data security measures
• Data retention practices
• Account and personal data deletion; and
• The Cookie policy applicable to each Service.

This policy does not cover the practices of other services AssHero may own but are not discussed in this privacy policy and listed above, other companies we don’t own or control, or people we don’t manage.

If you have a disability, you may access this policy in an alternative format by contacting us at [email protected].

PART ONE: AssHero PRIVACY PRACTICES

Data Controller

When you sign up and use a AssHero Service, AssHero.com is the data controller of your personal data for the purposes of delivering those Services to you (as that term is defined in each applicable set of terms) and as otherwise permitted in this privacy policy.

Contact Information

For all privacy inquiries you may contact us at: [email protected]

We do not knowingly collect or solicit personal data about children under 13 years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any personal data. If we learn we have collected personal data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided personal data to us, please contact us to provide that information (see the contact information above).

If you are under the age of 16 and a resident of the EEA or United Kingdom, or under 18 and are a resident of Israel, please have your parent or guardian contact us to provide consent for processing your personal data before you attempt to register for or otherwise use the Services or send us any personal data (see the contact information above).

Personal Data We Collect

When you use our Services

Our Services collect different personal data when you sign up and use them. For details on the personal data that we collect and the categories of third parties with whom your personal data is shared when you use each Service, please read the relevant Part Two section for that Service.

When you submit a DMCA takedown request

When you submit a takedown request utilizing a Digital Millennium Copyright Act (DMCA)-compliant takedown request form for one of the Services, we will collect your contact information (including your first and last name, address, phone number, and email address) so that we can remain in contact with you during the process and ensure that your claim is sufficiently addressed. This information will be used to process your request and keep a record of your complaint. If we receive a valid counter-notice, your complaint (which includes your contact information) will be forwarded to the uploader.

We will not collect additional categories of personal data or use the personal data we collected for materially different, unrelated or incompatible purposes without providing you notice.

Information That is Not Personal Data

We may create aggregated, de-identified or anonymized data from the personal data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it within AssHero and with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

How We Use Your Personal Data

When you use any of our Services, we use the personal data we collect for the following purposes:

• Providing and customizing the Services you use and request
  • Providing users with the products, Services or information they request, including when you use any one of our Services or any of our combined or integrated Services that you choose to use.
  • Operating and securing the AssHero businesses and our Services, including utilizing shared IT and Security systems, technology and infrastructure.
  • Creating and managing user accounts or user profiles for the Services, including enabling us to allow users to sign up for, and sign in and receive one or more AssHero Services at one time.
  • Providing support and assistance for the Services, including responding to customer support inquiries and responding to data subject rights requests under applicable law.
  • Customizing or personalizing the Services, website content and communications based on users’ preferences.
  • To distribute and display your content, which may include your username, across one or more of our Services. “Your content”, for purposes of this paragraph, refers only to user generated content you post on our Services. For example, if you post a question or answer on asshero.com, it may be distributed and displayed on another AssHero Service, and may include your asshero.com username.
  • Conducting fraud protection activities, implementing security and debugging.
  • Carrying out other business purposes stated when collecting users’ personal data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act and General Data Protection Regulation.
  • Processing orders or other transactions; billing.
• Measuring performance and improving the Services
  • Measuring our progress towards corporate goals and key performance indicators, including gathering commercial data related to our subscription Services.
  • Improving the Services, including by:
    • When you use our Services powered by AI, using user inputs to help improve our models.
    • Learning how you use and interact with our Services, by testing, research and development, and gathering commercial data and internal analytics on your use of a Service, or those unique users that subscribe to all or more than one of our Services, and gathering internal analytics on how you engage with one Service when integrated on another Service (for example, your use of a Symbolab feature integrated within asshero.com).
• Marketing the Services
  • Marketing and selling the Services, including to co-market, co-promote or cross-sell the AssHero Services (with your consent or otherwise in accordance with applicable law).
  • Showing you advertisements, including interest-based or online behavioral advertising.
• Communicating with you
  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about the Services.
  • Sending emails and other communications according to your preferences or that display content that we think will interest you, as permitted by applicable law.
• Meeting legal requirements and enforcing legal terms
  • Fulfilling our legal obligations under applicable law, regulation, court order or other legal process (e.g., subpoenas or warrants), such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
  • Protecting the rights, property or safety of you, AssHero, or another party, including conducting fraud protection, security and debugging.
  • Enforcing any agreements with you, including the applicable Terms of Use or Terms of Service for the relevant Service.

For UK and EEA residents, please see Additional Terms For European Economic Area And UK Residents for our lawful basis for processing your personal data for the purposes described above.

Tracking Tools, Advertising and Your Choices

AssHero and our third-party providers collect information in the Services through tracking technologies, including but not limited to, cookies (small pieces of information or text files that a website sends to your computer for record-keeping purposes and is stored in a file on your computer’s hard drive), web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, in-app tracking methods and other tracking technologies now and hereafter developed (“Tracking Technologies”). Further details about the Tracking Technologies we use (including the purpose for using them), interest-based advertising, your choices and how to manage cookies and do-not-track signals are below, and can also be found in each Service’s respective Cookie Policy, linked in each Service’s Part Two section of this Privacy Policy

Advertising

We may serve ads on our Services or on external services and engage and work with Service Providers and other third parties to serve advertisements on the Services and/or on Third-Party Services. Some of these ads may be tailored to your interests based on your browsing, across time, of the Services and elsewhere on the Internet, which may include use of data from cross-device usage, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on a third-party service after you have left the Services (i.e., “retargeting”). Our advertisers’ and ad networks’ use of Tracking Technologies are governed by their own privacy policies

Your Cookies and Tracking Technologies Choices

We may use Tracking Technologies to collect information about interactions with the Services, including information about your browsing and purchasing behavior. Tracking Technologies make Web-surfing and browsing easier for you by saving your preferences so that we can use the saved information to facilitate and improve your use of the Services.

• Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to some Tracking Technologies, such as HTML5 cookies. Please be aware that if you disable or remove these technologies, some parts of the Services may not work and that when you revisit the Services your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
• Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer. Apple and Google mobile device settings have settings to limit ad tracking, and other tracking, but these may not be completely effective.
• Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but we are not responsible for the completeness or accuracy of this third-party information. You have the right to request information from us about the Services that currently do not respond to “do not track” mechanisms featured in any Internet browser by contacting us according to the “How to Contact Us” section below.
• Many advertisers and service providers that perform advertising-related services for us and third parties participate in voluntary programs that provide tools to opt-out of such interest-based advertising such as the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding interest-based advertising for DAA members, visit https://youradchoices.com/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies also are members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/ . You can also go to https://help.adroll.com/hc/en-us/requests/new to adjust your advertising preferences with our service provider, NextRoll, Inc. (which used to be called AdRoll), or here to opt out of the use of your data by one of our other service providers, LiveRamp.
• Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected, participating members should no longer deliver certain interest-based advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your browser-based opt-out may not, or may no longer, be effective.
• We support the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising ( https://www.iab.com/wp-content/uploads/2015/05/ven-principles-07-01-09.pdf ) and expect that ad networks that we directly engage to serve you interest-based advertising will do so as well, though we cannot guarantee their compliance. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
• In addition, we may serve ads on third-party services that are targeted to reach people on those services that are also identified on one or more of our databases (“Matched List Ads”). This is done by using Tracking Technologies, or by matching common factors between our databases and the databases of the third-party services. We are not responsible for these third-party services, including without limitation their security of the data. We are not responsible for such third parties’ failure to comply with your or our opt-out instructions as they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you. For more information, please see the selling and sharing sections of the applicable State-Specific Rights section.
• If you are located in the EEA, UK or Canada, you can manage your Cookies consent choices using our consent management platform provided by our service provider OneTrust. If you do not wish to accept non-Essential Cookies in connection with your use of the Services or wish to withdraw your consent, you can opt out by selecting “Customize” and changing you by clicking on Cookies Preferences

Session Replay Tools

On certain pages of certain Services websites operated by AssHero, we use session replay tools provided by third party service providers, including Fullstory, Inc., Amplitude Inc., and Microsoft. Session replay tools are a necessary tool for AssHero to provide our Services. These tools allow AssHero to understand user activity and content performance to help deliver and optimize our Services, find and fix performance issues, and continuously improve our user’s experience. Depending on how you use our Services, our session replay tools may automatically collect the following information:

• Device-dependent data collected by your computer and web browser:
• IP address
• E-mail address including your first and last name, insofar as you have provided it to us via our Services
• Screen size of your terminal
• Device type and browser information
• Geographical data (country only)
• Language for displaying our website
• User interactions
• Mouse commands (movement, position and clicks)
• Date and time of access
• Keystrokes (not for sensitive fields like your texts to be checked or credit card information)

Our session replay tools service providers use this information to evaluate your use of our Services, to compile reports on usage and to provide other services in connection with the evaluation of our website. They also use third-party services (e.g. Google) to provide these services, who may store or otherwise process information that your browser transmits when you visit our Website (including, under certain circumstances, your IP address).

For more information about the session replay tools we use, see:

• Fullstory Privacy Policy
• Microsoft Clarity Privacy Policy
• Amplitude Privacy Policy

How We Share Your Personal Data

Sharing with Third-Parties

We share your personal data with the following categories of third-parties and for the following purposes:

• With Service Providers that help us operate our Services. These third parties help us provide the Services or perform business functions on our behalf. They include:
  • Hosting, technology and communication providers
  • Security and fraud prevention consultants
  • Analytics providers that provide analytics on web traffic or usage of our Services (e.g. tools that track user clicks or how visitors found our Services)
  • Support and customer service vendors
  • Payment processors, including those listed in the applicable Part Two section for each Service. They collect your payment information necessary to process your payment and share limited payment information with us necessary to operate our Services
  • Marketing services providers
  • Identification verification service providers
• With Advertising Service Providers and Partners to Show You Ads. These third parties help us market our services and provide you with other offers that may be of interest to you. They include:
  • Ad networks (including social media ad networks)
• With Parties You Authorize, Access or Authenticate When Using Our Services
  • Third-party log-in services
  • Third-party services you choose to integrate with through the Services.
• To Fulfill our Legal Obligations. Third parties that carry out the activities set forth under Meeting Legal Requirements and Enforcing Legal Terms in the How We Use Your Personal Data section above.
• Business Transfers. If we undergo a merger, acquisition, bankruptcy or other transaction in which a third party assumes control of our business (in whole or in part), your personal data may be transferred to that third party. Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Details of the categories of personal data and the third parties with whom we share your personal data that we have collected over the past 12 months may be found in the relevant Part Two section for each Service below.

Sharing With Government Authorities and Law Enforcement

When you use our Services, we may access and share the personal information described in the applicable Part Two section with regulators, law enforcement, or other government agencies as required by applicable law or if we have a good-faith belief that we must do so to comply with court orders or government requests supported with legal process. We may also do so for the purposes of detecting, investigating and preventing fraud or illegal activity on our Services, and to protect the rights and safety of our users. For information on the categories of information that may be shared for the purposes and the legal bases for doing so, see the Additional Terms For European Economic Area And UK Residents section in this Policy.

Marketing Communications

When you register an account or subscribe to a Service, you will receive marketing communications related to that AssHero’s services as well as transactional and account-related communications, as permitted by applicable law. We will collect your email address as well as other information you provide on a voluntary basis to help tailor communications to you. In any marketing communication from AssHero, you can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. You may also opt-out of receiving marketing communications at any time either through your account settings or by contacting us (see Contact Us section above). Please note that you will continue to receive transactional or account-related communications.

Data Security

We take commercially reasonable steps to protect your personal data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of personal data and how we are processing that data.

Examples of data security measures we implement include regular security vulnerability scanning of our Services in order to make your visit to or use of our Services as safe as possible; maintaining personal data behind secured networks that are only accessible by a limited number of persons with special access rights to such systems and who are under obligation to keep the information confidential; and implementing a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal data.

You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Data Retention

We will retain your personal data as described in the applicable Part Two section for the relevant Service you are using.

Changes To This Privacy Policy

We are constantly working to grow our business and improve our Services, offer new Services and features to you, and keep up with applicable laws. For these reasons we may need to change this privacy policy from time to time. When we make material changes, we will provide you with a reasonable form of online notice of the updated policy.

Additional Terms For Canadian Residents

If you reside in Canada, the following additional terms apply. If there are any conflicts between this section and any other provision of this policy, the provision that is more protective of personal data will apply.

Transfers of Personal Data Outside Canada

We may share your personal data amongst AssHero, with third party service-providers and other third parties that require such information to assist us in providing Services to you. In the course of providing these Services, your personal data may be accessed, collected, stored and processed in the U.S. or other foreign jurisdictions by AssHero or its third party service providers. AssHero and third-party service providers may disclose your personal data in response to a search warrant or other legally valid inquiry or order or as otherwise required or permitted by Canadian, US, or other law (which may include disclosure to US and foreign courts, law enforcement or governmental authorities). In the case of a transfer of personal data to AssHero or third-party service providers that process or store personal data on behalf of AssHero, AssHero and/or third party recipient will have agreed to safeguard personal data and use the information only for the purpose(s) for which it has been provided.

Canadian Resident Rights

Subject to applicable law, you have the right to access, update and correct inaccuracies in your personal data in our custody or control. You can request this by email or by writing to us at the contact information set out in the Contact Us section below. We may request certain personal data for the purpose of verifying the identity of the individual seeking access to his or her personal data records.

Additional Terms For California Residents

This section provides information in accordance with the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act for California residents about how AssHero handles certain personal data collected over the past 12 months. If you are a California resident, you have the rights set forth in this section. For how to exercise these rights, see the Exercising Your CCPA Rights section. If there are any conflicts between this section and any other provision of this policy, the portion that is more protective of your personal data will apply.

California Resident Rights under the CCPA

• Access/Right to Know. You have the right to request certain information about our collection and use of your personal data over the past 12 months, including:
  • The categories of personal data that we have collected about you.
  • The categories of sources from which that personal data was collected.
  • The business or commercial purpose for collecting or selling your personal data.
  • The categories of third parties with whom we have shared your personal data.
  • The specific pieces of personal data that we have collected about you.
• Right to Correct. You have the right to correct inaccuracies in your personal data, depending on the type of personal data and our purposes for processing it.
• Deletion. You have the right to request that we delete the personal data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your personal data to provide you with the Services or complete a transaction or other action you have requested. Please see the Data Retention section on our purposes for retaining limited personal data.
• Right to Opt-Out of Certain Activities. In some circumstances, you have the right to opt out of the sale of your personal data or the sharing of your personal data specifically for cross-contextual behavioral advertising purposes.

Exercising Your CCPA Rights. To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both criteria will be considered a “Valid Request .” We may deny requests that do not meet these criteria as permitted by applicable data privacy laws. You may appeal any denial by contacting us using the relevant contact information provided in Part One. . We will only use personal data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request. Please see the Contact Us section for where to submit a Valid Request.

Authorized Agent. You may authorize an agent (an “Authorized Agent“) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Non-Discrimination. We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of personal data that we receive from you.

Categories of Third Parties We Have Shared Your Personal Data With

For the categories of third parties with whom a AssHero shares the personal data it collects and has collected about you over the past 12 months, please see the relevant Part Two section for the Service you are using.

Your Rights under California’s Shine-the-Light Law

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of personal data to third parties for such third parties’ direct marketing purposes. To submit such a request, please see the Contact Us section and specify “California Shine the Light Request” in the subject line.

Additional Terms For Residents of other US States

This section provides information in accordance with US States other than California that may now or in the future have enacted state data privacy laws, including but not limited to the Colorado Privacy Act , the Connecticut Data Privacy Act , the Delaware Personal Data Privacy Act, the Montana Consumer Data Privacy Act, the Indiana Consumer Data Protection Act, the Iowa Consumer Data Protection Act, the Oregon Consumer Privacy Act, the Tennessee Information Protection Act, the Texas Data Privacy and Security Act, the Utah Consumer Privacy Act, and the Virginia Consumer Data Privacy Act. For residents of these US States, this section provides information about how AssHero handles certain personal data that we have collected about you. If you are a resident of one of these US States, you have the rights set forth in this section. For how to exercise these rights, see the Exercising Your US State Privacy Rights section. If there are any conflicts between this section and any other provision of this policy, the portion that is more protective of your personal data will apply.

Rights under Effective US State Laws

• Right to Know/Access/Portability.You have the right to confirm whether or not we are processing your personal data and to access such personal data. You may request for this information to be provided to you in a readily usable format, to the extent it is technically feasible.
• Right to Correct. Residents in certain states have the right to correct inaccuracies in their personal data, depending on the type of personal data and our purposes for processing it.
• Right to Delete. You have the right to request that we delete the personal data that we have collected about you.
• Right to Opt-Out of Certain Activities. In some circumstances, you have the right to opt out from (i) the sale of your personal data, (ii) the processing of your personal data for purposes of targeted advertising, (iii) the processing of your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. However, please note that we do not sell and have not sold your personal data. Additionally, AssHero does not process and has never processed your personal data for the purposes described in (ii) and (iii) above.

Exercising Your US State Privacy Rights. To exercise the rights described above, you or your Authorized Agent must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both criteria will be considered a “Valid Request .” We may deny requests that do not meet these criteria. You may appeal any denial by contacting the AssHero company relevant to your request; you can find the contact details for the relevant company in Part Two below. We will only use personal data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request. Please see the Contact Us section for where to submit a Valid Request.

Non-Discrimination. We will not discriminate against you for exercising your rights under applicable US State privacy laws. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights. However, we may offer different tiers of our Services as allowed by applicable data privacy laws with varying prices, rates or levels of quality of the goods or services you receive related to the value of personal data that we receive from you.

Additional State Law Privacy Rights

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal data to third parties who intend to license or sell that personal data. Please note that we do not currently sell your personal data as sales are defined in Nevada Revised Statutes Chapter 603A.

Complaints

If you have an unresolved privacy concern that we have not addressed satisfactorily, you may appeal any decision to us by contacting the AssHero company relevant to your request; you can find the contact details for the relevant company in Part Two below. Otherwise, please refer to your state’s process for filing a complaint with the appropriate agency. Truste Website Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means.

If you are a European Economic Area or UK resident, please see the Additional Terms For European Economic Area And UK Residents section for where to lodge a complaint.

Additional Terms For European Economic Area And UK Residents

If you reside in the European Union, Lichtenstein, Norway or Iceland (collectively, the European Economic Area or “EEA“) or the United Kingdom, the following terms apply. If there are any conflicts between this section and any other provision of this policy, the provision that is more protective of personal data will apply.

Legal Basis for Use of Your Personal Data

The personal data processed by AssHero, as described in Parts One and Two, are processed under the following legal basis:

• Contractual Necessity: AssHero processes the following categories of personal data as a matter of contractual necessity, meaning that we need to process the data to perform under our product specific Terms of Use or Terms of Service with you, which enables us to provide you with the Service:
  • Profile or Contact Data
  • Payment Data
  • Commercial Data
  • Online Identifiers
  • Device/IP Data
  • Web Analytics
  • Third-Party Login Service Data
  • Demographic Data
  • Geolocation Data
  • Other Identifying Information that You Voluntarily Choose to Provide

This includes for the purposes of:

• Providing users with the products, services or information they request.
• Providing customer support and assistance for the Services.
• Personalizing the Services, website content and communications based on users preferences.
• Creating and managing user accounts or user profiles.
• Distributing and displaying your content, which may include your username, across one or more of our Services.
• Enabling users to sign up for and sign in to multiple Services at one time.
• Processing orders or other transactions; billing.
• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about AssHero or the Services when requested or as permitted by applicable law.
• Enforcing any agreements with you, including our Terms of Use or Terms of Service.

When we process personal data due to contractual necessity, failure to provide such personal data will result in your inability to use some or all portions of the Services that require such information.

Legitimate Interest: AssHero processes personal data when it furthers its legitimate interests. This includes:

Purposes for Processing	Legitimate Interest Relied On	Personal Data Categories
Learning how you use and interact with one or more of our Services for the purposes of improving the Services, including testing, research, internal analytics and product development (when such processing is not performed with cookies or otherwise in a manner requiring consent).	In our interest to understand how our customers use our Services and to improve and develop our products and Services.	Profile or Contact Data, Commercial Data, Online Identifiers, Device/IP Data, Web Analytics, Demographic Data, Geolocation Data
To measure our progress towards corporate goals and key performance indicators, including gathering commercial data related to our subscription Services (when such processing is not performed with cookies or otherwise in a manner requiring consent).	In our interest to understand how our customers use our Services and to improve and develop our products and Services.	Profile or Contact Data Commercial Data Online Identifiers Device/IP Data Demographic Data Geolocation Data
Marketing and selling the Services, including co-market, co-promote and cross sell AssHero Services (when such processing is not performed with cookies or otherwise in a manner requiring consent).	In our interest to market, advertise and promote our products and Services to users.	Profile or Contact Data, Demographic Data, Geolocation Data
Sending transactional emails and other product communications to you as our customer according to your communications preferences.	In our interest to improve our products and Services for our users, including to personalize the Service for users.	Profile or Contact Data
Preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.	In our interest, and the interests of our users, to ensure the safety and security of our Services.	Profile or Contact Data Payment Data Commercial Data Online Identifiers Device/IP Data Web Analytics Third-Party Login Service Data Demographic Data Geolocation Data Other Identifying Information that You Voluntarily Choose to Provide
Protecting the rights, property or safety of you, AssHero, or another party.	In our interest to protect our rights and property, and the safety of our staff. It is also in our interest, and the interest of our users, to protect the rights, property and safety of our users.	Profile or Contact Data, Payment Data, Commercial Data, Online Identifiers, Device/IP Data, Web Analytics, Third-Party Login Service Data, Demographic Data, Geolocation Data, Other Identifying Information that You Voluntarily Choose to Provide
Detecting and preventing fraud, security, and debugging	In our interest, and the interests of our users, to ensure the integrity of our services and to detect and prevent fraudulent activity.	Profile or Contact Data, Payment Data, Commercial Data, Online Identifiers, Device/IP Data, Web Analytics, Third-Party Login Service Data, Demographic Data, Geolocation Data, Other Identifying Information that You Voluntarily Choose to Provide
Completion of corporate transactions.	In our interest to operate and manage our business in the event of a proposed or actual business sale.	Profile or Contact Data, Payment Data, Commercial Data, Online Identifiers, Device/IP Data, Web Analytics, Third-Party Login Service Data, Demographic Data, Geolocation Data, Other Identifying Information that You Voluntarily Choose to Provide

• Consent: In some cases, AssHero processes personal data based on the consent you expressly grant to it at the time it collects such data (which you may withdraw at any time after giving it, as described in this policy). This includes:
• Processing your personal data to send you marketing communications where you have consented to such use.
• Collecting your personal data through the use of advertising or tracking cookies based on your prior consent and use your personal data for showing you advertisements, including interest-based or online behavioral advertising.
• Collecting your personal data (including sensitive personal data) for identification verification purposes as described in this privacy policy.
• Learning how you use and interact with one or more of our Services for the purposes of improving the Services, including testing, research, internal analytics and product development (when such processing is performed with cookies or otherwise in a manner requiring consent).
• To measure our progress towards corporate goals and key performance indicators, including gathering commercial data related to our subscription Services (when such processing is performed with cookies or otherwise in a manner requiring consent).

In some cases AssHero processes personal data based on the implied consent you grant to us at the time we collect your personal data, as permitted by applicable law.

This includes:
• Sending you email communications to Market and sell the Services, including to co-market, co-promote and cross sell AssHero Services.

When we process personal data based on your consent, it will be expressly indicated to you at the point and time of collection. You have the right to withdraw your consent at any time. We refer to the EEA and UK Resident Rights section below for further information.

• Legal Obligation: AssHero processes your personal data where necessary to fulfill its legal obligations under applicable law, regulation, court order or other legal processing (e.g. subpoenas or warrants). This includes for the purposes of:
  • Fraud protection, security and debugging.
  • Responding to data subject requests under applicable privacy laws.
  • Preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
  • Data retention and administration obligations.
  • Complying with requests of competent supervisory authorities and legal agencies.
• Other Processing Grounds: From time to time, AssHero may also need to process personal data if it is necessary to protect the vital interests of you or others, or if it is necessary for a task carried out in the public interest.

EEA and UK Resident Rights

• Access: You have the right to confirmation as to whether or not we process personal data concerning you, and request access to and/or a copy of the personal data we hold about you.
• Rectification: If you believe that any personal data we hold about you is incorrect or incomplete, you can request that we correct or supplement such data. You may correct some of this information directly by logging on to your account.
• Erasure: You can request that we erase some or all of your personal data from our systems. Under the GDPR and the UK GDPR, this right is subject to certain exceptions. Please see the Data Retention section on the purposes for which we retain limited personal data.
• Withdrawal of Consent: If we are processing your personal data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time with effect for future processing operations. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your personal data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability: You can ask for your personal data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Restriction of Processing: You can ask us to restrict further processing of your personal data.

Objection: You can contact us to let us know that you object to the further use or disclosure of your personal data for certain purposes, such as for direct marketing purposes

Please note that these rights can often be exercised only under specific conditions set out in the GDPR and UK GDPR as applicable. Furthermore , we may not be able to fully comply with your request in circumstances where doing so is manifestly unfounded or excessive, or if it is not permitted by law. In those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include personal data, if necessary to verify your identity and the nature of your request.

If you wish to exercise any of your rights, please see the Contact Us section of this policy.

Cross Border Transfers of Personal Data

AssHero businesses are located in the United States, Israel, India, The Netherlands, and Canada and may continue to grow in other countries. We also have service providers both in the United States and throughout the world. As such, AssHero and our service providers may transfer your personal data to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. These transfers are necessary in order for us to provide our Services. When we transfer information about individuals based in the EEA or UK outside of those countries, we will take appropriate measures to safeguard the transfer as required by applicable law, including:

• Adequacy Decisions: European Commission decisions recognizing that certain countries and territories outside of the EEA ensure an adequate level of protection for personal data. Depending on your use of our Services, when we transfer your personal data from the EEA to Israel or the UK, we rely on the European Commission’s adequacy decision for Israel and the UK. Further, where we transfer your personal data from the EEA to an US recipient participating in the DPF (including the UK Extension to the EU-U.S. Data Privacy Framework (DPF), where applicable), we rely on the European Commission’s adequacy decision for the US.
• Standard Contractual Clauses: Transfers to countries that don’t have an adequacy decision typically take place on the basis of the European Commission-approved standard contractual data protection clauses (together with the UK Annex for transfers from the UK), which we use for transfers to countries including but not limited to the US (where the recipient does not participate in the DPF), and Singapore.

In certain circumstances, cross border transfers may take place on the basis of exemptions provided for under applicable data protection law.

You may always contact us to request a copy of the transfer measures that we have taken to safeguard the transfer of your personal data.

Complaints

You have the right to lodge a complaint about our practices with respect to your personal data before a supervisory data protection authority.

• If you are in Europe, an up-to-date list of data protection authorities is available at https://edpb.europa.eu/about-edpb/board/members_en.
• If you are in the Netherlands, the data protection authority is the Autoriteit Persoonsgegevens, available at: https://autoriteitpersoonsgegevens.nl.
• If you are in the UK, the data protection authority is the UK Information Commissioner’s Office available at https://ico.org.uk/.

Additional Terms for Australian Residents

If you reside in Australia, the following additional terms apply in accordance with the Australian Privacy Principles (“APPs”) and the Privacy Act 1988 (“APA”). If there are any conflicts between this section and any other provision of this policy, the following terms shall prevail.

Government ID

To the extent we collect any government ID (such as driver’s license, photo card, etc), we recognise that government ID is a special category of personal information that is subject to a higher standard of privacy protection compared to other types of personal data. Notwithstanding any other part of this policy, to the extent that we collect any such government ID from you, we will only collect, use and disclose such data strictly for the identity verification purpose set out in this privacy policy or for a purpose permitted under APP 9. We will not handle your government ID in any other manner or for any other purpose. Subject to any retention requirements under law or otherwise specified in this privacy policy, we will destroy or de-identify any record of your government ID stored in our systems when we no longer need to use it.

Accessing Your Personal Data

You can request to access, correct, update or delete your personal data by contacting us using the contact details provided under the Contact us section in Part One.

You can request access to any personal data we hold about you at any time. However please be aware that from time to time we may need to reject your request to access personal data we hold about you, if we believe such rejection to be necessary and to the extent allowed by law.

If we do not provide you with access to any of your personal data, or do not correct any of your personal data, we will provide you with our reasons. If you are not satisfied with our reasons, you may make a complaint as set out below under the Complaints section.

Complaints

We take your privacy concerns seriously. If you have a complaint regarding our handling of your personal data or concerning our privacy practices, you may file a complaint with our Privacy Officer using the contact provided under the Contact us section in Part One. Our Compliance team will confirm receipt of your complaint and review it with our legal team. If we believe an investigation is necessary, we will open an investigation into your complaint. We may need to contact you to request further details of your complaint. If an investigation has been opened following a complaint made by you, we will contact you with the result of that complaint as soon as possible.

If you are not satisfied with the outcome of your complaint, you may refer your complaint to the Office of the Australian Information Commissioner by contacting 1300 363 992 or by visiting the website www.oaic.gov.au. Further information about the APA and the APPs is also available from the Office of the Australian Information Commissioner.

Transfers of Personal Data Outside Australia

We may share your personal data amongst AssHero, with third party service-providers and other third parties that require such information to assist us in providing Services to you. Your personal data may be transferred to, and processed in, countries other than Australia, including United States, Israel, India, The Netherlands, and Canada or other countries as might be the case in the future. We will only transfer your personal data overseas for the same purposes set out in this Privacy Policy. Personal data that is stored overseas may not be subject to the APA or the APPs. However, we will not transfer or permit any of your personal data to be transferred outside of Australia unless we have taken reasonable steps to ensure the transfer is in compliance with applicable laws, and in any case to a recipient that has privacy protections in place which are at least substantially similar to which the APPs protect information.

Consequences If We Can’t Collect Your Personal Data

If you do not provide us with the personal data we need, we may not be able to provide appropriate services, targeted content or relevant information to you, and in some cases you may not be able to use our Services.

Additional Terms for Mexican Residents

Purposes and Consent

For residents in Mexico, please consider that the purposes that have originated and are necessary for the existence, continuity and fulfilling of the legal relationship with you are considered primary purposes. Therefore, AssHero does not require your express consent for the processing of your data for these purposes. Any other purpose other than the primary purposes already stated shall be considered as secondary purposes, for which you may refuse processing of data, by not providing your personal data whenever they are requested for these purposes in particular, by notifying your refusal to [email protected], or by configuring your preferences in accordance with our Cookie Policy.

For residents in Mexico, please consider that communication of personal data described in the “Sharing with Third Parties” section (except for the Service Providers and Business Transfers portions), and the “Sharing Personal Data Between the AssHero” section shall be considered “transfers” of data. Nonetheless, said transfers do not require your consent when takes place between companies that are part of the AssHero corporate group and operate under the same privacy policies; under conditions necessary for AssHero to maintain its current legal relationship with you and/or; under a legal requirement for the administration or prosecution of justice., which are considered exceptions under Mexican Law.

Communication of personal data described in the “Service Providers” portion of the Sharing with Third-Parties section of the privacy policy shall be considered a “remission”, where each third party that receives said data shall be considered a processor of the correspondent data. As per Mexican Law, AssHero is not required to inform nor obtain your consent for these communications of data. Please take into consideration that AssHero does not collect, receive and/or transfer financial data, this data is collected and processed at all times by a “Payment Processor”. For more information, please review the privacy policies of the respective payment processors referred to in the “Personal Data Collected” section.

The content referred to in the “Business Transfers” portion of the Sharing with Third-Parties section of this privacy policy does not qualify in Mexico as a communication of personal data, but rather as an assignment of the data controller obligations to a third party, which shall be communicated to you through the availability of a new privacy policy.

Your Rights under Mexican Privacy Law

You are entitled to: (i) access to your personal data kept by AssHero (ii); be informed of the treatment given to your personal data by AssHero; (iii) request rectification of your personal data in case the information is incorrect or incomplete; (iv) request cancellation of your personal data; (v) refuse to the treatment of your personal data; and (vi) revoke your consent for the processing of your personal data (together “ARCO Rights”).

You may exercise your ARCO rights by contacting AssHero compliance at [email protected] with the subject “ARCO Rights”, and providing the following information:

• Your name and address
• The specific AssHero Service you are using
• Supporting documentation of your domicile in Mexico,
• A clear and precise description of the personal data you are seeking to access or the privacy right you are exercising
• Any additional details relevant to your request.

Our compliance team will review and respond to your request within the timeframe permitted by law.

Contact Us

If you subscribed to more than one Service at checkout, or you have a question or request that pertains to more than one Service and would like to exercise any of the rights under applicable privacy law, you can submit your request to AssHero, Inc. and indicate so on the request. AssHero, Inc. will process it accordingly.

Otherwise, please contact the AssHero company relevant to your request; you can find the contact details for the relevant company in Part Two below.

AssHero, Inc.
Attn: Privacy Compliance
2000 Seaport Blvd, Floor 3
Redwood City, CA 94063 USA
866-634-9397
[email protected]
GDPR/US State Privacy Laws Request Form

EEA and UK residents may contact our EU and UK based representative regarding all requests related to data protection and privacy:

Privacy Rep Office Limited
Attn: AssHero, Inc.
2nd Floor, 1-2 Victoria Buildings, Haddington Road
Dublin 4, Dublin, Ireland, D04 XN32
[email protected]
Telephone number: 0035-31-6994225