We understand that privacy is tremendously important to our users and we are committed to protecting it through our compliance with this privacy policy (“Policy”). This Policy describes the limited information we (“operator”, “we”, “us”, “our”) may collect from you or that you may provide (“Personal Information”) in the “Equity Maps” mobile application (“Mobile Application” or “Service”) and any of its related products and services (collectively, “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that Personal Information. It also describes the choices available to you regarding your Personal Information and how you can access and update it.

This Policy is a legally binding agreement between you (“User”, “you” or “your”) and this Mobile Application developer (“operator”, “we”, “us” or “our”). If you are entering into this agreement on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this agreement, in which case the terms “User”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this agreement, you must not accept this agreement and may not access and use the Mobile Application and Services. By accessing and using Equity Maps app, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy.

Collection and storage of information

Equity Maps is a native app designed to give you the user control over the data, which is collected and stored independently on your device. Beginning with version 5.3 (Premium) you are able to export data via email to recipient/s via your own email on your device, or to the emails that you have entered for the participants.

Our top priority is customer data security and, as such, we exercise the no logs policy. We may process only minimal user data, only as much as it is absolutely necessary to maintain the Mobile Application and Services.

Information collected automatically is used only as statistical information regarding the general usage of the Mobile Application and Services. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.

We may collect these categories of Personal Data from you and temporarily store them in order to fulfill the request:

• When you contact us for support or other requests.
  • Profile or Contact Data, such as email address
  • Other Identifying Information that you voluntarily choose to provide, such as identifying information in emails or letters you send us
• When you export Participant Analytics within Equity Maps Mobile Application to external emails (beginning with Premium version 5.3).
  • Contact Data such as email address
  • PNG files of the participant analytics, which are temporarily stored to process your data request to send the Personal Data to the email you indicated within Equity Maps Mobile Application

Data analytics

Equity Maps uses the following third party service/s to collect information that is aggregated and anonymized to protect individual users:  Google Analytics for Firebase and Firebase Crashlytics.

The data is only used in aggregate form as a statistical measure to help improve our product and not in a manner that identifies you or any of your students or participants personally. Data on device type, operating system, and the general user experience is automatically collected when using Equity Maps and solely used to optimize and improve the usability of the app. We use the information obtained from these analytics tools to monitor the performance and improve our Mobile Application and Services. We do not use third-party analytics tools to track or to collect any personally identifiable information of our Users and we will not associate any information gathered from the statistical reports with any individual User.

Privacy of children

We recognize the need to provide further privacy protections with respect to Personal Information we may collect from children under the age of 13 and take many special precautions to protect their privacy. We do not require any Personal Information from users, including from children at any time and you have the choice to use partial names or alias for all participants, which are stored only locally on your device.

You also have the choice to record audio, which is stored only locally on your device, with the choice to export at your discretion the audio or CSV files of your data via the email accounts on your own device. We do not have access via the Mobile Application to collect the data.

Use and processing of collected information

We act as a data controller and a data processor in terms of the GDPR when handling Personal Information, unless we have entered into a data processing agreement with you in which case you would be the data controller and we would be the data processor.

Our role may also differ depending on the specific situation involving Personal Information. We act in the capacity of a data controller when we ask you to submit your Personal Information that is necessary to ensure your access and use of the Mobile Application and Services. In such instances, we are a data controller because we determine the purposes and means of the processing of Personal Information and we comply with data controllers’ obligations set forth in the GDPR.

We act in the capacity of a data processor in situations when you submit Personal Information through the Mobile Application and Services. We do not own, control, or make decisions about the submitted Personal Information, and such Personal Information is processed only in accordance with your instructions. In such instances, the User providing Personal Information acts as a data controller in terms of the GDPR.

Any of the information we collect from you may be used for the following purposes:

• Respond to inquiries and offer support
• Improve user experience
• Run and operate the Mobile Application and Services
• Implement your request within the Mobile Application to export Participant Analytics via email

Processing your Personal Information depends on how you interact with the Mobile Application and Services, where you are located in the world and if one of the following applies: (i) you have given your consent for one or more specific purposes; this, however, does not apply, whenever the processing of Personal Information is subject to California Consumer Privacy Act or European data protection law; (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which you are subject; (iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

Disclosure of information

We do not have access to personal data via Equity Maps and we do not rent or sell data or information for marketing or any other purposes. We do not allow third party advertising networks to collect information about users of our Mobile Application and we do not have in-app or contextual advertising of any kind.

Depending on the requested Services or as necessary to complete any transaction or provide any Service you have requested, we may share your information with our service providers (collectively, “Service Providers”) we rely upon to assist in the operation of the Mobile Application and Services available to you and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. We will not share any personally identifiable information with third parties and will not share any information with unaffiliated third parties.

Service Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Service Providers are given the information they need only in order to perform their designated functions, and we do not authorize them to use or disclose any of the provided information for their own marketing or other purposes.

Data protection rights under the GDPR

If you are a resident of the European Economic Area (“EEA”), you have certain data protection rights and we aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. Equity Maps is a native app designed to give you the user control over the data, which is collected and stored independently on your device. Beginning with version 5.3 you are able to export data via email to a recipient via your own email on your device, or to the emails that you have entered for the participants. If we receive an email from you or a communication via a social network, we use that information to best serve you and to process your request through the channel with which you contacted us.

In certain circumstances, you have the following data protection rights:

(i) You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Information. To the extent that the legal basis for our processing of your Personal Information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

(ii) You have the right to learn if your Personal Information is being processed by us, obtain disclosure regarding certain aspects of the processing, and obtain a copy of your Personal Information undergoing processing.

(iii) You have the right to verify the accuracy of your information and ask for it to be updated or corrected. You also have the right to request us to complete the Personal Information you believe is incomplete.

(iv) You have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent. Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us, or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection.

(v) You have the right, under certain circumstances, to restrict the processing of your Personal Information. These circumstances include: the accuracy of your Personal Information is contested by you and we must verify its accuracy; the processing is unlawful, but you oppose the erasure of your Personal Information and request the restriction of its use instead; we no longer need your Personal Information for the purposes of processing, but you require it to establish, exercise or defend your legal claims; you have objected to processing pending the verification of whether our legitimate grounds override your legitimate grounds. Where processing has been restricted, such Personal Information will be marked accordingly and, with the exception of storage, will be processed only with your consent or for the establishment, to exercise or defense of legal claims, for the protection of the rights of another natural, or legal person or for reasons of important public interest.

(vi) You have the right, under certain circumstances, to obtain the erasure of your Personal Information from us. These circumstances include: the Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure such as where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, to exercise or defense of legal claims.

(vii) You have the right to receive your Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance from us, provided that such transmission does not adversely affect the rights and freedoms of others.

(viii) You have the right to complain to a data protection authority about our collection and use of your Personal Information. If you are not satisfied with the outcome of your complaint directly with us, you have the right to lodge a complaint with your local data protection authority. For more information, please contact your local data protection authority in the EEA. This provision is applicable provided that your Personal Information is processed by automated means and that the processing is based on your consent, on a contract which you are part of, or on pre-contractual obligations thereof.

California privacy rights

Consumers residing in California are afforded certain additional rights with respect to their Personal Information under the California Consumer Privacy Act (“CCPA”). If you are a California resident, this section applies to you.

In addition to the rights as explained in this Policy, California residents who provide Personal Information as defined in the statute to obtain Services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the categories and specific pieces of Personal Information we have collected and disclosed.

Data breach

In the event we become aware that the security of the Mobile Application and Services has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice in the Mobile Application.

Changes and amendments

We reserve the right to modify this Policy or its terms related to the Mobile Application and Services at any time at our discretion. When we do, we will revise the updated date at the bottom of this page.

An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Mobile Application and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.

Acceptance of this policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Mobile Application and Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Mobile Application and Services.

Contacting us

If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us using the details below:

www.equitymaps.com/your-email/

We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.

This document was last updated on April 29, 2023