BZEEN Privacy Policy

Effective Date: 10/28/2021

This BZEEN Privacy Policy (“Privacy Policy”) provides the privacy terms under which

we, X Marks the Spot Software, Inc., are providing you the services and content made

available through the BZEEN website (the “Website”) and mobile application (the

“App”). This Privacy Policy is included with and supplements the BZEEN Terms of

Service. The Website and the App, and the services and content made available

through the Website and the App, including downloadable software applications,

text/SMS message services, email message services, and any and all other associated

services, data, information, tools, software, updates and materials, are referred to

altogether in this Privacy Policy and in the BZEEN Terms of Service as the “Services.”

This Privacy Policy explains our online information collection and use practices, and the

choices you can make about the way we use such information. It is important that you

take the time to read and understand this Privacy Policy so that you can appreciate how

we use your personal information. REMEMBER IF YOU USE OR ACCESS THE

SERVICES, YOU AGREE TO THIS PRIVACY POLICY. AS WE UPDATE OR EXPAND

OUR SERVICES, WE MAY CHANGE THIS PRIVACY POLICY UPON NOTICE TO

YOU, HOWEVER, PLEASE REVIEW IT FROM TIME TO TIME.

For users that are citizens of the European Union ("EU"), this Privacy Policy is

subject to the provisions of the General Data Protection Regulation ("GDPR") and

other applicable privacy laws. In such case, we are a data “Controller” and you

are a “Data Subject” with certain protected privacy rights concerning your

“Personal Data.” Your Personal Data may identify you as a person, and thus is

often referred to as Personally Identifiable Information ("PII"). PII is included in

the term “Personal Data” that is used in this Privacy Policy

1. Who Collects Your Information With Our Services?

We do. We collect information from you when you use the Services, and we are

responsible for protection of your information.

2. What Information Do We Collect?

A. Requested Information. When you use the Services, we may request specific

Personal Data about you in order to register you for an account, give you access to the

social media and other functionality of the Services, add you to our email list, or fulfill

your requests for information. You may choose not to provide your Personal Data, but

then you might not be able to take advantage of some or even any of the features of our

Services. We only collect basic Personal Data about you that does not include any

special types of information (e.g., health-related) as defined in the GDPR. The types of

Personal Data we collect and save include:

● your account registration and profile information, such as your user name, photo

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or avatar, location, country, email address, physical address, phone number;

● information that you provide in using our Services, such as information and

avatars about people to whom you wish to send comments or with whom you

want to make contact, messages or communications to friends and contacts, and

other content that you process through the Services;

● information you provide such as feedback, comments or other messages; and

● technical information collected in our logs (e.g., your Internet Protocol (“IP”)

address, page URLs and timestamp, etc.); and

● device information such as mobile phone provider associated with the device you

are using to access the Services, your device’s unique identifier, the type of

device and its operating system, the pages or features accessed most frequently,

calls and messages placed through the Services, how pages or features of the

Services are used, search terms entered, and similar analytics about use of the

Services.

Note also that in a case of an error arising during use of the Services, we collect data

and information (through third party products) on your mobile device or computer called

Log Data. This Log Data may include information such as your device IP address,

device name, operating system version, the configuration of the Services, the time and

date of your use of the Services, and other statistics.

B. Aggregate Information. We may also collect anonymous, non-identifying and

aggregate information such as the type of browser you are using, device type, the

operating system you are using, and the domain name of your Internet service provider.

C. Location Information. The Services do require location-based information, and

as a result the Services may need to use GPS or other location-based services to

identify your physical location. With your consent, the Services may also access your

device’s calendar, contacts, call history, camera roll, or other device-stored information,

in order to facilitate and provide the Services.

3. Why Is My Information Being Collected?

We need to collect your Personal Data so that we can provide the Services, give you

access to the social media functionality of the Services, respond to your requests for

information and demonstrations, add you to our emailing lists, and process your

requests to access our Services. We also collect aggregate information to help us

better design the Services. We collect Log Data for monitoring purposes to help us to

diagnose problems with the hosting servers, administer the Services, calculate usage

levels, and otherwise provide the Services to you.

4. How Do We Use the Information We Collect?

A. With our third-party partner companies (we explain this more in point 5 below),

we use the Personal Data you provide for the purposes for which you have submitted it,

including:

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● Responding To Your Inquiries and Fulfilling Your Requests. We may use

your Personal Data to respond to your inquiries and to fulfill your requests for

information.

● Creating and Maintaining Your User Account. We use your Personal Data to

create and maintain an account for you so that you can use the Services we

make available.

● Communicating With You About Our Services. We may use your Personal

Data to send you information about new Services and other items that may be of

interest to you.

● Improving Our Services. We may use your information to make our Services

more stable and user-friendly, to analyze how our Service is used and to address

service issues, and to develop new marketing programs relating to the Services.

● Sending Administrative Emails. We may use your Personal Data to send you

emails to: (a) confirm your account and your other Personal Data, (b) process

your requests for our Services, (c) provide you with information regarding the

Services, or (d) inform you of changes to this Privacy Policy, our Terms of

Service, or our other policies.

B. We may use anonymous information that we collect to improve the design and

content of our Services, and to enable us to personalize your Internet experience. We

also may use this information in the aggregate to analyze how our Services are used,

analyze industry trends, as well as to offer you programs or services.

5. Do We Share Your Personal Data?

A. In general, we will not share your Personal Data except: (a) for the purposes for

which you provided it; (b) with your consent; (c) as may be required by law (e.g., in

response to a court order or subpoena, or in response to a law enforcement agency

request); (d) as we think necessary to protect our organization or others from injury

(e.g., when we believe that someone is causing, or is about to cause, injury to or

interference with the rights or property of another); or (e) on a confidential basis with

persons or organizations with whom we contract to carry out site operations or as

necessary to render the Services.

B. We do use third parties (companies and individuals), who will have access to or

collect your Personal Data, and you acknowledge and consent to this use. We may do

this to facilitate the availability of the Services, including by having the third parties

assist us in providing the Services to you. The privacy policies of those third parties

apply to their use of your Personal Data (and not this Privacy Policy). The URL’s to the

● Apple Account https://apple.com/legal/privacy

● Google Account https://policies.google.com/privacy

● Google Cloud https://cloud.google.com/terms/cloud-privacy-notice

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● Google Play Services https://policies.google.com/privacy

● Google Analytics for Firebase https://firebase.google.com/support/privacy

● Cleanspeak https://cleanspeak.com/privacy-policy

● AppsFlyer https://www.appsflyer.com/legal/services-privacy-policy

● SendInBlue https://www.sendinblue.com/legal/privacypolicy

● Facebook Platform https://www.facebook.com/about/privacy

We may also share aggregate information with others, including affiliated and

non-affiliated organizations. Finally, we may transfer your Personal Data to our

successor-in-interest in the event of an acquisition, sale, merger or bankruptcy.

6. Are There Other Ways My Personal Data Could Be Shared?

You may elect to share certain Personal Data with individuals or with the public via your

use of the Services. In this case, you will control such sharing via settings that we

provide. By using the Services, you are publicly sharing Personal Data and other

information via social media. Be aware that when you choose to share Personal Data

and other information with friends, public officials, or with the public at large, you may be

disclosing sensitive information, or information from which sensitive information can be

inferred. Always use caution when sharing information through the Services. You

understand and agree that we are not responsible for any consequences of your

posting, sharing, distributing, uploading, making available to anyone, or otherwise

publishing of information through and beyond the Services.

7. How Can You Access and Control Your Information?

After registering for an account via the Services, you may log-in to the account and edit

your Personal Data in your profile. For instructions on how you can further access your

Personal Data that we have collected, or how to correct errors in such information,

please send an e-mail to support@xmarksthespotsoftware.com, or call us at

302-401-6680. We will also promptly stop using your information and remove it from our

servers and database at any time upon your request. To protect your privacy and

security, we will take reasonable steps to help verify your identity before granting

access, making corrections or removing your information.

If you are an EU citizen and believe that we have misused your Personal Data, you

have the right to contact the European Data Protection Supervisor (“EDPS”) to ask the

EDPS for advice on how to exercise your rights or to ask the EDPS to investigate a

complaint. For more information, see EDPS Complaints.

8. How Do We Store and Protect Your Information?

A. After receiving your Personal Data, it will be stored for future use. We use a third

party host to store your Personal Data, currently Google Cloud. We will take care to use

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a hosting service that provides physical, electronic, and managerial procedures in place

to safeguard and help prevent unauthorized access, maintain data security, and

correctly use the information we collect. Unfortunately, no data transmission or data

storage solution can ever be completely secure. As a result, although we take

industry-standard steps to protect your information (e.g., strong encryption), we cannot

ensure or warrant the security of any information you transmit to or receive from us or

that we store on our or our service providers' systems.

B. If you are using the Services from outside of the USA, you understand that your

connection may be sent through and to servers located in the USA, and the information

you provide may be stored in web servers and internal systems located within the USA.

By accessing or using the Services or otherwise providing information to us, you

consent to the processing, transfer, and storage of information in and to the USA, where

you may not have the same rights and protections as you do under local law.

C. Your Personal Data is stored for as long as reasonably required for its purpose or

for any additional period required by law (if any). Account information is deleted when

you or when we delete your account. We may store information longer for legitimate

business reasons (for example, Personal Data may remain in backups for a reasonable

period of time), or as legally required. Otherwise, we store your Personal Data until you

request us to remove it from our servers. We store our logs and other technical records

indefinitely.

9. How Do We Use Cookies And Other Tracking Technologies?

A. We or our service providers may use third party code and libraries that do employ

“cookies” to collect information and provide services, as well as to improve services.

“Cookies” are a type of tracking technology that a web server may place on your hard

disk as a text file to store your preferences. Once you choose to provide Personal

Data, this information may be linked to the data stored in a cookie. You can set your

browser to notify you when you receive a cookie, and you can decide to accept or reject

the cookie, or delete it upon leaving the Services. Please note, however, that if your

browser is set not to accept cookies, or you refuse cookies, you may not be able to use

some portions of the Services.

B. We or our service providers may also use "pixel tags," "web beacons," "clear

GIFs," “embedded links” and other commonly-used information-gathering tools in

connection with some parts of the Services and messages. We may use these tools for

such purposes as compiling aggregate statistics about Services usage and response

rates. A pixel tag is an electronic image (often a single pixel), that is ordinarily not

visible to visitors. Pixel tags allow us and our service providers to count users who have

accessed certain parts of the Services, to deliver customized services, and to help

determine the effectiveness of our Services. When used in certain messages, pixel

tags can inform the sender of the whether and when the message has been opened.

C. As you use the Internet, you leave a trail of electronic information at each website

and mobile application that you visit or use. This information, which is sometimes

referred to as "clickstream data”, can be collected and stored by a website's server.

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Clickstream data can reveal the type of computer and browsing software you use and

the address of the website from which you linked to the website. We may use

clickstream data as a form of non-Personal Data to determine how much time users

spend on certain parts of our Services, how users navigate through the Services, and

how we may tailor our Services to better meet the needs of users. We will only use this

information to improve our Services.

D. Many modern web browsers give you the option to send a “Do Not Track” signal

to the websites you visit, indicating that you do not wish to be tracked. At this time, the

Services do not specifically respond to “Do Not Track” signals.

10. Links to Other Sites

We may provide links to certain third party mobile applications and websites on which

you may be able to obtain information or use services. These third party mobile

applications and websites are not operated by us. Please review the privacy policies of

these other mobile applications and websites to learn how they collect, use, store and

share information that you may submit to them, or that they may collect.

11. Children and Young People’s Information

We do not knowingly collect any information from any minors, and we comply with all

applicable privacy laws including the GDPR, CCPA, USA Children's Online Privacy

Protection Act (“COPPA”) and associated Federal Trade Commission (“FTC”) rules for

collecting Personal Data from minors. Please see the FTC's website (www.ftc.gov) for

more information. Our Services will not knowingly accept Personal Data from anyone

under 13 years old in violation of applicable laws, without consent of a parent or

guardian. In the event that we discover that a child under the age of 13 has provided

Personal Data to us without parental consent, we will make efforts to delete the child’s

information in accordance with the COPPA. If you have concerns about our Services,

wish to find out if your child has accessed our Services, or wish to remove your child's

Personal Data from our servers, please contact us at

support@xmarksthespotsoftware.com.

12. California Privacy Rights

The California Consumer Privacy Act (“CCPA”) of 2018 enhances privacy rights

and consumer protection for residents of California. Under the CCPA, California

residents have the rights to: 1) know what Personal Data are being collected about

them; 2) know whether their Personal Data are sold or disclosed, and to whom; 3) say

'no' to the sale of their Personal Data; 4) access their Personal Data; and 5) not be

discriminated against for exercising their privacy rights under the CCPA. California law

allows California residents to request information regarding our disclosures in the prior

calendar year, if any, of their Personal Data to third parties. To make such a request,

please contact us at support@xmarksthespotsoftware.com or telephone us at

302-401-6680. Please include enough detail for us to locate your file; at a minimum,

your name, email and username, if any. We will attempt to provide you with the

requested information within thirty (30) days of receipt. We reserve our right not to

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respond to requests sent more than once in a calendar year, or requests submitted to

an address other than the one posted in this notice. Please note that this law does not

cover all information sharing. Our disclosure only includes information covered by the

law.

13. Changes to this Policy

Because our business needs may change over time, we reserve the right to modify this

that differs from this Privacy Policy, we will revise this Privacy Policy as appropriate. In

the event of a change to our Privacy Policy, we will email the updated policy to the email

address that you provided to us. Your continued use of the Services following our

notice of changes to this Privacy Policy means you accept such changes.

14. Our Contact Information

If you have any questions or concerns about this Privacy Policy, please contact us via

e-mail at support@xmarksthespotsoftware.com.

The Services are protected by United States and international copyright, trademark, and

other applicable laws, and all rights are reserved. This includes the content,

appearance, and design of the Services, as well as the trademarks, product names,

graphics, logos, service names, slogans, colors, and designs.

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