Privacy Policy

Overview.

Last Updated: July 15, 2022

Engage Technologies Group, Inc. and its affiliates (“Engage,” “we,” “our,” and/or “us”) values the privacy of individuals who use our websites (such as www.engagetg.com; or www.mobit.com) or services that link to this Privacy Policy (collectively, our “Services”). If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), “personal information” means any information relating to an identified or identifiable individual. This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose personal information from users of our Services. By using our Services, you agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy. Beyond this Privacy Policy, your use of our Services is also subject to our Terms of Service.

Information We Collect

We may collect a variety of information from or about you or your devices from various sources, as described below.

If you do not provide your information when requested, you may not be able to use our Services if that information is necessary to provide you with our Services or if we are legally required to collect it.

A. Information You Provide to Us

Registration and Profile. When you register for an account to use our Services, we ask you for your personal information, which may include your first name, last name, phone number, and email address.

Communications. If you contact us directly, we may receive additional personal information about you. For example, when you contact us via a contact form, email, website chat, phone, or other means, we will receive your first name, last name, email address, as well as the content, data, and time of your message. If you subscribe to our newsletter or authorize yourself as a member of our online community forums, we will receive your email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services. Where enabled, we may ask you for your and your colleagues’ names and email addresses if you utilize the “Share with Co-worker” functionality in the Services.

Payment Information. If you make a purchase through our Services, your payment-related information, such as credit card or other financial information, is collected by our third-party payment processor on our behalf.

Careers. If you decide to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide us as part of your job application, such as your contact information, current employment information, and other information you choose to submit with your application and on your resume. If you apply for a job with us through a third-party platform (such as LinkedIn or Indeed), we will collect the information you make available to us through such third-party platform.

B. Information We Collect When You Use Our Services

Location Information. When you use our Services, we may infer your general location information. For example, your IP address may indicate your general geographic region.

Device Information. We receive information about the device and software you use to access our Services, including internet protocol (IP) address, web browser type, operating system version, and device identifiers.

Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, including but not limited to the pages, videos, or other content you view, the buttons and documents you interact with, the feedback you share with us, the searches you conduct, and the dates and times of your visits.

Analytics Partners. We use analytics services such as Google Analytics and Azure Cloud Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, applications, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/ and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Information from Cookies and Similar Technologies. We and our third-party partners may collect personal information using cookies, which are small files of letters and numbers that we store on your browser or the hard drive of your computer. They contain information that is transferred to your computer’s hard drive. We and our third-party partners may also use pixel tags and web beacons on our Services. These are tiny graphic images placed on web pages or in our emails that allow us to determine whether you have performed a specific action. We use cookies, beacons, invisible tags, and similar technologies (collectively “Cookies”) to collect information about your browsing activities and to distinguish you from other users of our Services. This aids your experience when you use our Services and allows us to improve the functionality of our Services. Cookies can be used for performance management (i.e., collecting information on how our Services are being used for analytics purposes). They can also be used for functionality management, enabling us to make your visit more efficient by, for example, remembering language preferences, passwords, and log-in details. Below is an overview of the types of Cookies we and third parties may use to collect personal information.

Strictly Necessary Cookies. Some Cookies are strictly necessary to make our Services available to you. We cannot provide you with our Services without this type of Cookies. We use the following necessary Cookies: ASP.NET_SessionId, __RequestVerificationToken, OptanonConsent, vuid, player.

Name	More Information	Retention

ASP.NET_SessionId	MOBIT™	session
__RequestVerificationToken	MOBIT™	session
OptanonConsent	Vimeo	5 months
vuid	Vimeo	5 months
player	Vimeo	5 months

Functional Cookies. Functional Cookies are used to recognize you when you return to our Services. This enables us to adapt our content for you and remember your preferences. For example, we use functional Cookies to remember your choice of language or region. We use the following functional Cookies: None.

Analytical or Performance Cookies. We also use Cookies for website analytics purposes in order to operate, maintain and improve our Services. We may use our own analytics Cookies or use third-party analytics providers such as Google Analytics and Azure Cloud Analytics. Google uses the data collected to track and monitor the use of our Service. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en. We also encourage you to review the Google’s policy for safeguarding your data: https://support.google.com/analytics/answ
er/6004245. These providers may also collect information about your use of other websites, apps, and online resources. We also use the following analytical or performance Cookies: None.

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from our Services, you may not be able to utilize the features of our Services to their fullest potential.

D. Information We Receive from Third Parties

Partners. We may receive additional information about you, from third parties such as data or marketing partners and combine it with other information we have about you.

HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect:

To provide, maintain, debug, improve, and enhance our Services;
To understand and analyze how you use our Services, and develop new products, services, features, and functionalities;
To understand and analyze usage patterns;
To process your job application;
To communicate with you, provide you with updates and other information relating to our Services and its promotions, provide information that you request, respond to comments and questions, and otherwise provide customer support;
To send you SMS, MMS, calls, or push notifications;
To find and prevent fraud, and respond to trust and safety issues that may arise;
To aggregate and otherwise de-identify for other business purposes;
For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
For other purposes for which we provide specific notice at the time the information is collected.

LEGAL BASES FOR PROCESSING EUROPEAN INFORMATION

If you are located in the European Economic Area or the United Kingdom, we only process your personal information when we have a valid “legal basis,” including as set forth below.

Consent. We may process your personal information where you have consented to certain processing of your personal information. For example, we may process your personal information to send you marketing communications or to use Cookies where you have consented to such use.
Contractual Necessity. We may process your personal information where required to provide you with our Services. For example, we may need to process your personal information to respond to your inquiries or requests.
Compliance with a Legal Obligation. We may process your personal information where we have a legal obligation to do so. For example, we may process your personal information to comply with tax, labor and accounting obligations.
Legitimate Interests. We may process your personal information where we or a third party have a legitimate interest in processing your personal information. Specifically, we have a legitimate interest in using your personal information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services. We only rely on our or a third party’s legitimate interests to process your personal information when these interests are not overridden by your rights and interests.

HOW WE SHARE THE INFORMATION WE COLLECT

We do not share or otherwise disclose information we collect from you except as described below or otherwise disclosed to you at the time of the collection.

Affiliates. We may share any information we receive with our affiliates for any of the purposes described in this Privacy Policy.

Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Services.

Analytics Partners. We use analytics services such as Google Analytics and Azure Cloud Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/ and opt out of them by downloading the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout.

Marketing. We do not rent, sell, or share information about you with nonaffiliated companies for their direct marketing purposes unless we have your permission.

As Required by Law and Similar Disclosures. We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety.

Merger, Sale, or Other Asset Transfers. We may disclose and transfer your personal information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our business or assets.

Consent. We may also disclose personal information with your permission.

YOUR CHOICES

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. It may take up to ten business days for us to process your request. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

California Residents. If you are located in California, you should consult our CCPA California Resident Privacy Notice for additional choices regarding your data.

Your European Privacy Rights. If you are located in the EEA or the UK, you have additional rights described below.

You may request access to the personal information we maintain about you, update and correct inaccuracies in your personal information, restrict or object to the processing of your personal information, have your personal information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your personal information to another company. In addition, you have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

You may withdraw any consent you previously provided to us regarding the processing of your personal information at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

You may exercise these rights by contacting us using the contact details at the end of this Privacy Policy. Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain personal information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

How to Block Cookies. You can block Cookies by setting your internet browser to block some or all Cookies. However, if you use your browser settings to block all Cookies (including essential Cookies) you may not be able to access all or parts of our Services. By using our Services, you consent to our use of Cookies and our processing of personal information collected through such Cookies, in accordance with this Privacy Policy. You can withdraw your consent at any time by deleting placed Cookies and disabling Cookies in your browser, or as explained below. You can change your browser settings to block or notify you when you receive a Cookie, delete Cookies or browse our Services using your browser’s anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of Cookies or similar technologies which store information on your device, you should change your browser settings accordingly. You should understand that some features of our Services may not function properly if you do not accept Cookies or these technologies. Where required by applicable law, you will be asked to consent to certain Cookies and similar technologies before we use or install them on your computer or other device.

THIRD PARTIES

Our Services may contain links to other websites, products, or services that we do not own or operate (“Third-Party Services”). We are not responsible for the privacy practices of these Third-Party Services. Please be aware that this Privacy Policy does not apply to your activities on these Third-Party Services or any information you disclose to these Third-Party Services. We encourage you to read the privacy policies of these Third-Party Services.

RETENTION

We take measures to delete your personal information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When we process personal information for our own purposes, we determine the retention period taking into account various criteria, such as the type of services provided to you, the nature and length of our relationship with you, possible re-enrollment with our Services, the impact on our Services we provide to you if we delete some information from or about you, and mandatory retention periods provided by law and the statute of limitations.

SECURITY

We make reasonable efforts to protect your personal information by using physical and electronic safeguards designed to improve the security of the personal information we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your personal information.

INTERNATIONAL VISITORS

Our Services are hosted in the United States (“U.S.”) and intended for visitors located within the U.S. If you choose to use our Services from the EEA, the UK or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the U.S. for storage and processing. We may transfer information from the EEA or the UK to the U.S. and other third countries based on European Commission-approved or UK Government-approved standard contractual clauses, or otherwise in accordance with applicable data protection laws. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our Services. By providing any information, including personal information, on or to our Services, you consent to such transfer, storage, and processing.

CHILDREN’S PRIVACY

We do not knowingly collect, maintain, or use personal information from children under 16 years of age, and no parts of our Services are directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, please alert us at support@engagetg.com.

CHANGES TO THIS PRIVACY POLICY

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted.

CONTACT INFORMATION

If you have any questions, comments, or concerns about our processing activities, please email us at support@engagetg.com or write to us at:

Engage Technologies Group, Inc.

3540 E. Longwing Lane, Suite 300

Meridian, Idaho

83646

Engage Technologies, Inc. California Resident Privacy Notice

This California Resident Privacy Notice supplements the information and disclosures contained in our Privacy Policy. It applies to individuals residing in California from whom we collect Personal Information as a business under the CCPA.

Personal Information Collection, Disclosure, and Sale

For the purposes of this notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).

Personal Information does not include information that is:

Lawfully made available from government records.
Deidentified or aggregated.
Otherwise excluded from the scope of the CCPA.

The chart below provides the categories of Personal Information (as defined by the CCPA) we have collected, disclosed for a business purpose, or sold in the preceding twelve months since this notice was last updated. The examples of Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.

Category	We Collect	We Disclose	We Sell

A. Identifiers Examples: Name, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.	Yes	Yes	No
B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e) Examples: Name, postal address, telephone number, credit card number, debit card number, or any other financial information.	Yes	Yes	No
C. Characteristics of Protected Classifications under California or Federal Law Examples: Race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status.	No	No	No
D. Commercial Information Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No	No	No
E. Biometric Information Examples: Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	No	No	No
F. Internet or Other Electronic Network Activity Information Examples: Information regarding a consumer’s interaction with an internet website, application or advertisement.	Yes	Yes	No
G. Geolocation Data Examples: General physical location.	Yes	Yes	No
H. Sensory Information Examples: Audio, electronic, visual, thermal, olfactory, or similar information.	No	No	No
I. Professional or Employment-Related Information Examples: Job application or resume information, past and current job history, and job performance information.	Yes	Yes	No
J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99) Examples: Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.	No	No	No
K. Inferences Drawn from Personal Information Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No	No	No

Use of Personal Information

We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes below:

To provide, maintain, debug, improve, and enhance our Services;
To understand and analyze how you use our Services, and develop new products, services, features, and functionalities;
To understand and analyze usage patterns;
To process your job application;
To communicate with you, provide you with updates and other information relating to our Services and its promotions, provide information that you request, respond to comments and questions, and otherwise provide customer support;
To send you SMS, calls, or push notifications;
To find and prevent fraud, and respond to trust and safety issues that may arise;
To aggregate and otherwise de-identify for other business purposes;
For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;
To facilitate transactions and payments;
For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
For other purposes for which we provide specific notice at the time the information is collected.

Collection of Personal Information

In the preceding twelve months since this notice was last updated, we have collected Personal Information from the following categories of sources:

You/Your Devices: You or your devices directly.
Users: Other users of our services.
Affiliates.
OS/Platform Provider: Operating systems and platforms.
Partners: Business partners.
Public: Publicly accessible sources.

Disclosure of Personal Information

In the preceding twelve months since this notice was last updated, we disclosed Personal Information to the following categories of third parties:

OS/Platform Providers: Operating systems and platforms.
- Personal Information we share: First Name, Phone Number to Apple iOS, Android, Windows mobile operating systems

Integrated Third Parties: Third parties integrated into our services.

- Personal Information we share: First Name, Phone Number

Your California Privacy Rights

If you are a California resident, you may exercise the following rights.

Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed or sold Personal Information; and (5) specific pieces of Personal Information we have collected about you during the past twelve months.

Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.

Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, please authenticate your account by logging into your account.

Right to Opt Out. In some circumstances, you may opt out of the sale of your Personal Information. We do not sell your Personal Information.

Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

Shine the Light. We do not rent, sell, or share Personal Information with nonaffiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light” law (Civil Code § 1798.83), unless we have your permission.

Submit Requests. To exercise your rights under the CCPA, please call 208-902-9030, send an email via our Contact Information section, or visit our website www.engagetg.com.

Authorizing an Agent. If you are acting as an authorized agent to make a request to know, delete, or opt out on behalf of a California resident, please call 208-902-9030, send an email via our Contact Information section, or visit our website www.engagetg.com and attach a written authorization signed by the resident.

Contact Information

If you have any questions, comments, or concerns about this notice or our processing activities please email us at support@engagetg.com or write to us at: