PRIVACY POLICY

Nucla takes the security of your data and our infrastructure very seriously. We are committed to providing an environment that is safe, secure, and available to all of our customers all the time.

Last updated: January 2024

The Nucla Platform is a product provided by Nucla Inc. ("Nucla").

 Your privacy is important to us. This Privacy Policy ("Policy") applies to NuclaInc.'s ("we," "us," or "Nucla") products and services (including, without limitation our Platform and our ProfessionalServices, as each term is defined under our Nucla License and ServicesAgreement and our Nucla Platform Agreement (collectively, the "Agreement")and any medium through which we make them available, including, without limitation our website, mobile app, and other platforms (collectively, the"Services"). This Policy explains what information we collect from users of our Services (a "user," "you,"or "your"), including information that may be used to personally identify you ("Personal Information") and how we use it. We encourage you to read the details below. This Policy applies to any user of, or visitor to, our Services.

We reserve the right to change this Policy at any time. We will notify you of any changes to this Policy by sending notice to the primary email address specified in your account or by a prominent notice on our website. Significant changes will go into effect thirty (30) days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check our website, including this privacy page, for updates. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Policy means that the collection, use and sharing of yourPersonal Information is subject to the updated Policy.

What Information Do We Collect?

We will only collect and process Personal Information about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g.to deliver the Services you have requested), and our legitimate interests.

We collect information that you give us when you create an account, contact us, or otherwise access or use the Services, any information you voluntarily submit to us, and information regarding how you use the Services. Specifically, the foregoing includes:

- Your internet protocol address (i.e., IP address) and, if you access the Services from a mobile application, your unique mobile device ID number and non-email authentication.

- Your name, email address, postal address, telephone number, profession and employer, profile picture, your responses to surveys that we may ask you to complete for research purposes or to help direct Nucla activities, and your social media information.

- Information about your intended use of the Services, including brands and agencies with which you are looking to connect, advisors and/or board members with whom you are looking to connect, and other personal and/or business interests you may communicate to us.

- Details of any financial transactions you participate in on the Services, including the amount, currency, and method of payment.

- Browser and device information and information collected through technologies such as cookies, pixel tags, and other technologies.

- If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

How Do We Use The Information We Collect?

We use the information we collect to:

- Deliver and improve the Services and your overall user experience, including, without limitation, creating a profile for you based on information you have provided to us, information imported from other sites or applications, or information provided to us by third parties; allow you to contact or invite other users to access the Services; and enabling you to network with other users, post information on bulletin boards, and view and compare profiles.

- Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.

 - Link or combine user information with other PersonalInformation.

- Compare and verify information for accuracy and update our records.

- Email, text, message, or otherwise contact you with information and updates about us and the Services.

- Respond to your comments and questions and provide customer service.

- To send you information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.

- Analyze how you use the Services with tools such as GoogleAnalytics and other tools to help us understand traffic patterns and know if there are problems with the Services, and generate other internal reports about the use of the Services.

- Create targeted content and advertising to promote the Services, engage our users, and to suggest products or services that might be of interest to you.

Do We Share Your Personal Information?

We do not rent, sell, or share your Personal Information with other people or non-affiliated third parties except with your consent or as necessary to complete any transaction or provide any service you have requested or authorized. We may share your Personal Information as set forth below.

Sharing with Third Parties

To help us provide the Services, we may provide limited access to some of your Personal Information to the following third parties:

- Other Users: if you make your profile searchable, then all users with access to our searchable database will have access to your Personal Information you make available on your profile.

Business Partners: Sometimes we collaborate with other organizations to deliver the Services. In these cases, we may share your name, contact information and other details you provided when making an account with our partners.

- Service Providers: We work with a wide range of third-party providers, notably our database administrators, cloud computing services, advertising services, data analysts, application service providers, bulk SMS services, and other non-governmental organizations.

- Payment Processors: We work with payment processors such as Stripe to help process credit card transactions and other payment methods made through the Services. These payment processors will store certain information about you.Please refer to their privacy policies to learn more about how they use yourPersonal Information.

- Other Third Parties: if you opt in to receive information about opportunities, products, or services of other third parties, we provide some of your Personal Information (such as contact information) to those third parties.

- Acquirers: We may also transfer your Personal Information to a third party as a result of a merger, acquisition, reorganization or similar transaction.

Sharing for theProtection of Company and Others

We will also share Personal Information with companies, organizations or individuals outside of Nucla if we have a good-faith belief that access, use, preservation, or disclosure of your Personal Information is reasonably necessary to detect or protect against fraud or security issues, enforce our terms of use, meet any enforceable government request, defend against legal claims, protect against harm our legal rights or safety, maintain the security of the Services, and/or to protect the rights or property of Nucla.

In such event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your Personal Information, give you an opportunity to consent to such changes.

How Do We Use Tracking Technologies?

A "cookie" is a small file placed on your hard drive by some of our web pages.   We, or third parties we do business with, may use cookies to help us analyze our web page flow, customize our services, content and advertising, measure promotional effectiveness and promote trust and safety. Cookies are commonly used at most major transactional websites in much the same way we use them in our Services.

You may delete and block all cookies from our Services, but parts of the Services may not work. We want to be open about our cookie use.

Even if you are only browsing the Services, certain information(including computer and connection information, browser type and version, operating system and platform details, and the time of accessing the Services)is automatically collected about you. This information will be collected every time you access the Services and it will be used for the purposes outlined in this Privacy Policy.

You can reduce the information cookies collected from your device.  An easy way of doing this is often to change the settings in your browser. If you do that you should know that (a) your use of the Services maybe adversely affected (and possibly entirely prevented), (b) your experience of this and other sites that use cookies to enhance or personalize your experience may be adversely affected, and (c) you may not be presented with advertising that reflects the way that you use our and other sites. You find out how to make these changes to your browser at this site: www.allaboutcookies.org/manage-cookies/.  Unless you have adjusted your browser settings so that it will refuse cookies, our system will send cookies as soon as access our Services.  By using the Services you consent to this, unless you change your browser settings.

Web beacons may be used to track the traffic patterns of users from one page to another in order to maximize web traffic flow. Our third-party advertising service providers may also use web beacons to recognize you when you visit the Site or access the Services and to help determine how you found the Services. If you would like more information about this and to know your choices about not having this information used by these companies, please visit: the Digital Advertising Alliance’s website, http://www.aboutads.info/,or the Network Advertising Initiative’s website, http://networkadvertising.org/consumer/opt_out.asp.

Session replay technologies, such as, may be used to collect information regarding visitor behavior on the Service. For more information about FullStory, please see the FullStory privacy policy available athttps://www.fullstory.com/legal/privacy/. You can opt out of FullStory’s collection and Processing of data generated by your use of the Services by going to https://www.fullstory.com/optout/.

How Do We Secure YourPersonal Information?

Information you post to public areas of the Services may be accessed, used, and stored by others around the world, including those in countries that might not have legislation that requires adequate protection ofPersonal Information. We take reasonable steps to protect your PersonalInformation against unauthorized access, alteration, disclosure, misuse, or destruction. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  The safety and security of your PersonalInformation also depends on you. If you have an account with us, you are responsible for keeping your membership details confidential. Your account is protected by your account password and we urge you to take steps to keep yourPersonal Information safe by not disclosing your password and by logging out of your account after each use. We further protect your Personal Information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology.However, these measures do not guarantee that your Personal Information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using the Services, you acknowledge that you understand and agree to assume these risks.

We retain your Personal Information while your account is in existence or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of theServices.

Your Choices Regarding Information

You have several choices regarding the use of Personal Information on the Services:

Changing or Deleting Your Personal Data. All users may review, update, correct or delete thePersonal Information furnished by a user in their user account (including any imported contacts) by contacting us at legal@nucla.com or by accessing your user account. For your protection, we may only share and update the PersonalInformation associated with the specific email address that you use to send us your request, and we may need to verify your identity before doing so. We will try to comply with such requests in a reasonably timely manner. If you completely and permanently delete all of your Personal Information, then your user account may become deactivated. If you wish to cancel your account, you may do so through your account page, and any personally identifiable information associated with your account will be deleted as soon as is reasonably practical or as required by applicable law. Please note that we may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required by law. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Download or Access Personal Information. You can ask us for a copy of your PersonalInformation and can ask for a copy of Personal Information you provided in machine readable form by emailing us at legal@nucla.com.

Opting Out of Email Communications. We may use some of the information we collect for marketing purposes, including to send you promotional communications about newCompany features, products, events, or other opportunities. If you wish to stop receiving these communications or to opt out of use of your information for these purposes, please follow the opt-out instructions, such as clicking"Unsubscribe" (or similar opt-out language) in those communications.You can also contact us at legal@nucla.com to opt out. Despite your indicated e-mail preferences, we may send you Service-related communications, including notices of any updates to this Policy. 

Links to Third Party Websites

We may provide links to other websites and/or social media platforms. We have no control over these websites and they are subject to their own terms of use and privacy policies. As such, we do not endorse and are not responsible for the availability of, or for any content, advertising, products, or other materials on or available from, these third party websites.

How We Respond to Do Not Track Signals

Your browser settings may allow you to automatically transmit aDo Not Track signal to websites and other online services you visit. We do not alter our practices when we receive a Do Not Track signal from a visitor’s browser because we do not track our visitors to provide targeted advertising.To find out more about Do Not Track, please visit http://www.allaboutdnt.com.

Children Under 16

The Services are not directed to individuals who are under age of sixteen (16) and we do not solicit nor knowingly collect PersonalInformation from children under the age of sixteen (16). If you believe that we have unknowingly collected any Personal Information from someone under the age of sixteen (16), please contact us immediately at legal@nucla.com and the information will be deleted.

Third Party DirectMarketing

Your California Privacy Rights: if you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of your Personal Information with third parties for the third parties’ direct marketing purposes. California law provides that you have the right to submit a request to us at our designated address and receive the following information: (a) the categories of information we disclosed to third parties for the third parties’ direct marketing purposes during the preceding calendar year; and (b) the names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed. You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually.  To make such a request, please use the contact information below.

A Note to Users Outside the United States

Our Company is based in the United States. The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information will be stored and processed in the United States (or any country where we have facilities or in which we engage service providers), and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

We will use reasonable efforts to ensure that transfers ofPersonal Information are provided an adequate level of protection as required by law, such as by entering into appropriate contractual arrangements (such as, where applicable, the standard contractual clauses for the transfer of data as approved by the European Commission), by complying with or relying on EU-U.S.Privacy Shield Framework certifications, or by asking for your prior consent.

Contact Us

If you have any questions about this Policy, your Personal Information, or the Services, you can contact legal@nucla.com.