Privacy Policy | Afresh Technologies

Scope of this privacy policy

This Privacy Policy applies to personal information that Afresh collects, uses, discloses, and otherwise processes when you:

• Access or use our website available at afresh.com or any other website operated or made available by Afresh where this Privacy Policy is posted (collectively, the "Website");
• Access or use the Afresh platform and any related products, services or functionality we make available (collectively, the "Platform");
• Communicate with us through any written, electronic, or oral communications, including by email, text message, or phone, such as through events or marketing communications.
• Interact with us in the context of our internal recruiting efforts, such as by making inquiries concerning career opportunities or by applying for a job with us.

For purposes of this Privacy Policy, we refer to our Website, Platform, and any other online service we provide that links to this Privacy Policy as the "Services." We provide the Platform to our customers under our agreement with them and solely for their benefit and the benefit of personnel that they authorize to use the Platform ("Authorized Users"). We are data processors of the data or other content that our customers and their Authorized Users input, upload, submit or otherwise make available to the Platform and any other data we may process on their behalf (collectively, "Customer Content"). Our processing of such data is governed by our agreement with the customer, and the customer is responsible for the collection and use of such Customer Content.

Personal information we collect and how

As used in this Privacy Policy, "personal information" means any information that identifies or could be used to identify an individual person. For example, personal information may include name, email address, and phone number. It also includes other non-public information that we associate with such identifying information. Personal information does not include aggregated or anonymized information. The personal information we collect and how we collect it depends on how you use the Services. We collect the following types of personal information, as described below.

(a) Information you provide

We collect personal information that you provide directly to us when you access or use the Services or when you interact with us. We collect information that you provide to us in the following ways:

• Registration, account information, and demos. If you sign up for a demo or if you register or create an account to use the Services, Afresh collects personal information to set up and manage your account, such as your name, company, email address, postal address, phone number, account credentials, and account ID.
• Support requests, inquiries, feedback, questionnaires. If you contact us, such as by submitting a contact form or sending an email, contacting customer support, or submitting feedback, we collect your name, company, job title, email address, phone number, country, the details of your question or request, and any other information you choose to include in your message. We may also collect information you provide if you complete surveys or questionnaires that we make available.
• Marketing communications and newsletters. If you submit a request to receive newsletters and marketing communication from us, we will collect your name and contact information, such as your email address.
• Interactions through social media, and other third-party platforms. If you interact with us through any third-party platforms, such as Github, or through any of our pages or feeds on social media sites or platforms, such as Facebook, Twitter/X or LinkedIn, we may collect information such as your name, username, demographic information, contact information such as email address, location, and publicly-posted data such as your social media activity.
• Attending Events. If you sign up for or attend a webinar or other event hosted by Afresh, we collect registration and attendance information. If you attend a conference, trade show, or other event that Afresh attends or sponsors, we may collect information about individuals who attend the event and/or information from individuals who interact with us or express an interest in us. This information may include your name and email address as well as any professional background information you may choose to share.
• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
• Apply for a job or interact with us for our recruiting purposes: If you submit an application for a job or otherwise interact with us for our internal recruiting purposes, such as by emailing us to inquire about an open job, we collect information such as your name, contact information, which may include email and phone number, resume information, which may include job history and education information, job application information, which includes the job you’re applying for and any information you choose to submit with your application, and certain social media profile information, such as your LinkedIn profile information. Afresh tries not to collect sensitive personal information unless it’s necessary to comply with applicable laws. In some circumstances, we may need to collect, or request on a voluntary disclosure basis, some sensitive personal information for legitimate recruiting-related purposes. For example, information about your racial/ethnic origin, gender and disabilities may be collected for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government reporting obligations. Information about your physical or mental condition may be collected in order to consider accommodations we need to make for the recruitment process and/or subsequent job role.

You may choose not to provide personal information directly to us or to not use the Services. However, some personal information is necessary so that we can provide you with the Services you have requested. Failure to provide this information may prevent us from providing you with access to our Services.

(b) Information we collect automatically

When you access or use the Services, we or our third-party agents or service providers automatically collect information about the device you use to access the Services and your activity when you use the Services. Depending on your activity, the information may include:

• Device and Usage Information: We collect certain information about your device and how you interact with the Services each time you access or use them.
  • Log data includes your Internet Protocol (“IP”) address, browser type and settings, the date and time of your request, and how you interact with our Services.
  • Device information may include your browser type and version, browser settings, time zone, unique device identifiers, information about your approximate location (as determined through your IP address), mobile, computer, and/or device hardware information (e.g., operating system version, hardware model, IMEI number, and other unique device identifiers, MAC address, and device settings), device event information, log information, and crash data.
  • Usage information may include features that you use, clickstream data, access dates and times, and how you interact with the Services. When you visit the Website, this information may also include referring / exit pages and URLs, how you interact with links on the Website, landing pages, and pages viewed. We also may collect the date and time you open the App or an email communication from us or click on any links in an email, and we or our service provider may associate this information with the email address we already have from you. We may also use the information we collect automatically (for example, IP address, and unique device identifiers) to identify the same unique person across the Services to provide a more seamless and personalized experience to you.
• Cookies and Other Tracking Technologies: We and our third-party service providers or agents may collect information using one or more Cookies or similar technologies such as pixels (collectively “Cookies”). Cookies may collect information such as your IP address, unique device identifiers, your browser settings, and information about how you use the Services (e.g., the pages you view, the links you click). Please refer to the Cookies and Tracking Technologies section below for more information about our use of Cookies and your choices related to Cookies.

(c) Customer content

We collect, receive, or access Customer Content that our customers and their Authorized Users input or submit while using the Services, including any personal information contained in such Customer Content. We process Customer Content pursuant to our agreements with our customers.

(d) Information from third parties

Depending on the Services you use or how you use the Services, we collect and process personal information we receive from third parties, and we may combine personal information we receive from you with personal information we obtain from other sources. We may receive the following types of information from third parties:

• Afresh’s Service Providers: We receive information from our service providers or agents who perform business services for Afresh, such as Website activity information from third parties that assist us in operating our Website and transactional data from our third-party infrastructure service providers and security and fraud detection providers.
• Analytics, Marketing, Advertising Providers, and Afresh Partners: We may receive information from third parties that perform data analytics, targeted advertising, marketing and/or lead generation functions for Afresh, such as lead generation providers, third-party data enrichment tools, and analytics vendors. We may also receive contact information from Afresh business partners with whom we operate co-branded events, webinars, services and marketing campaigns or joint offerings.
• Recruiting Information from Third-Parties: We may collect information from third-party social media and jobs platforms, such as LinkedIn, for our recruiting purposes. We may also receive information from third-party recruiters and agencies that assist us with our recruiting activities.

How we use personal information

We use the personal information we collect in the following ways:

• To provide and operate the Services;
• To create and manage your Afresh account and any user account(s);
• To respond to your inquiries and requests, or otherwise communicate with you, and to provide you with assistance related to the Services;
• To provide technical support for, secure, and protect the Services, including to detect and prevent fraud, abuse, or security risks, and to troubleshoot;
• To conduct research and analytics related to the Services, such as to understand how they are being used and where improvements may be needed;
• To personalize and improve user experience with the Services, such as to present tailored content;
• To update, improve, and/or enhance the Services, and develop new features, functionalities, and/or Services;
• To better understand your personal preferences and to enable us to provide you with improved and personalized communications;
• To compile aggregate data, such as about traffic and interaction with or on the Services;
• To send you newsletters, promotional and marketing communications that may be of interest to you;
• For our internal recruiting and hiring purposes;
• For our advertising purposes, such as to display personalized advertisements to you regarding the Services on third-party sites and measure their success;
• To tailor the content and advertising we display to you or others and to analyze trends and statistics;
• To provide notices, transactional updates, and other information to you about, or in connection with, our Services;
• To enforce our agreements, resolve disputes or otherwise to carry out our obligations and enforce our rights, and to protect our business interests and rights of third parties;
• To audit our compliance with legal and contractual requirements and internal policies;
• To comply with legal and contractual obligations and requirements, law enforcement requests, and legal process;
• For our business transfers;
• To keep you updated about changes to policies related to our Services (including this Privacy Policy); and
• For any other purpose with your consent.

We may combine any of the information that we collect from you with other information, including information that we obtain from third parties, or with information derived from any other products or services we provide. We will use this information for the purposes described in this Privacy Policy.

How we disclose personal information

We transmit, disclose, grant access, make available and provide personal information to or with the following types of third parties.

(a) Corporate account administrators

If you are using the Services through a corporate account, the administrators of that account may access and control your Afresh account.

(b) Service providers

We disclose personal information with our third-party vendors, consultants, agents, contractors, and service providers that help us provide our Services or with any of the purposes described in this Privacy Policy. Depending on how you use the Services, the following categories of Service Providers may collect data on our behalf or receive personal information:

• Hosting service providers,
• Analytics providers,
• Advertising and marketing partners,
• Providers of business operations and communication tools, such as email and messaging software providers,
• Customer relationship management and customer support service providers,
• Security and fraud-prevention providers;
• Other third-party service providers that help us provide features and functions for the Services, and
• Professional advisors, agents and service providers, such as auditors, lawyers, consultants, accountants and insurers.

(c) Afresh partners and affiliates

We share personal information with any existing Afresh affiliates. From time to time, we may work with other businesses to sponsor or host conferences or webinars, market related services, promote joint ventures or other similar collaborations. We may disclose personal information, such as your name and email address, with our partners in these situations.

(d) Legal, compliance and regulatory purposes

We may disclose personal information if we believe that it is necessary to:

• comply with a law, regulation, legal process, or legitimate governmental request;
• protect the safety or security of the Services, users of the Services, or any person;
• investigate, prevent, or take action regarding illegal or suspected illegal activities;
• prevent spam, abuse, fraud, or other malicious activity of actors using or accessing the Services; or
• protect our rights or property or the rights or property of those who use the Services.

Non-public information about our users will not be released to law enforcement except in response to an appropriate legal process such as a subpoena, court order, or other valid legal process that has been reviewed by Afresh. However, if we receive information that provides us with a good faith belief that there is an exigent emergency, we may provide information to law enforcement trying to prevent or mitigate the danger, to be determined on a case-by-case basis.

(e) Business transfers

We may disclose personal information to third parties we choose to acquire or with buyers, successors, or others in connection with a merger, divestiture, restructuring, reorganization, financing due diligence, initial public offering, dissolution, or other sale or transfer of some or all of our assets or transition of service to another provider, whether as a going concern or as part of bankruptcy, receivership, liquidation or similar proceeding, as permitted by law and/or contract.

(f) With your consent

There may be situations where you are asked to consent to disclose personal information with third parties for additional reasons not included in this Privacy Policy.

Cookies and tracking technologies

As described above in this Privacy Policy, we collect and may permit third parties to collect information using cookies and other similar technologies.

(a) What are cookies?

Cookies are small data files that are placed on your device set by us or by third parties when you visit a website or other online service. In addition to cookies, we may use other technologies that are similar in function, such as pixels, also called web beacons or single-pixel tags/gifs, local or web storage, and embedded scripts.

• Pixels: Also called web beacons, or “clear gifs,” and single-pixel tags/gifs, or web tags, are tiny graphics with a unique identifier placed on a website or in an email that gathers information about your interaction with that website or email. Because of their small size, they are not visible. Pixels can also enable us and third parties to place cookies on your browser.
• Local or Web Storage: Local or web storage refers to other places on a browser or device where information can be stored. It includes both your own device storage and browser cache.
• Embedded Scripts: An embedded script is a programming code that is designed to collect information about your interactions with the Services, such as the links you click. The code is temporarily downloaded onto your device, is active only while you are connected to the Services and is deactivated or deleted after you are no longer connected.

We use the term “Cookie” throughout this Privacy Policy to cover all these technologies. You can find more information about cookies at: www.allaboutcookies.org.

(b) Types of cookies

Cookies are often described by who created and placed them and how long they last. Types of Cookies generally include the following:

• Persistent Cookies and Session Cookies
  • Persistent Cookies: A persistent Cookie stays in your browser and will be read by us when you return. A persistent Cookie helps us recognize you as an existing user, so it is easier for you to return and interact with our Services.
  • Session Cookies: A session Cookie is temporary and enables you to move from page to page on our Services and allows information that you enter to be remembered. A session Cookie is deleted when you close your browser or after a short time.
• First-Party Cookies and Third-Party Cookies
  • First-party Cookies: These are Cookies set by the publisher of the website or online service you are visiting. First-party Cookies may be set either by us or by a service provider at our request.
  • Third-party Cookies: These are Cookies that are set by a party other than the publisher of the website you are visiting.

(c) What types of information do cookies collect?

Cookies collect different types of information depending on the type of Cookie and its purpose. Some examples of information that may be collected by Cookies when you use our Services include:

• The pages or features you visit within our Services;
• The buttons you click on our Services;
• The date and time you visit our Services;
• The amount of time you spend on our Services;
• The IP address used to connect your device to the internet; and
• Your device (such as computer, mobile phone) and connection information such as your browser type and version and operating system.

(d) How do we use cookies?

Afresh uses Cookies for purposes such as providing content or features on our Services, helping us remember you and your preferences, and improving your user experience by making our Services more efficient and relevant to you. We, our service providers, and/or agents acting on our behalf, use the following persistent and session Cookies (which may be first-party or third-party Cookies) on our Services:

• Strictly Necessary Cookies: These Cookies are essential because they enable our Services to work properly, and they cannot be disabled. Without these Cookies, some of our Services cannot be provided. These Cookies do not gather information about you for advertising purposes. For example, these Cookies are used to:
  • Remember the information that you fill in when performing certain activities on your Services;
  • Pass information from one page to the next, for example when filling out forms;
  • Read your browser and device settings to optimize the display of our Services;
  • Identify misuse of our Services;
  • Load our Services uniformly to maintain accessibility;
  • Authenticate users and prevent fraud.
• Functional Cookies: We use functional Cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these Cookies can be used to remember your name or preferences on our Services. We do not use functional Cookies for online advertising. While these Cookies can be disabled, this may result in less functionality during your use of our Services. For example, we use these Cookies to:
  • Provide you a personalized experience, such as remembering how you have customized our Services;
  • Remember the information that you fill in when performing certain activities on our Services;
  • Store your preferences such as language and location.
• Performance or Analytics Cookies: These Cookies help us understand how our Services are being accessed, used, or are performing. These performance or analytics Cookies may collect information about the content you view, what websites you visit immediately before and after visiting our Services, and your system and geographic information. The information generated by these Cookies will be transmitted to and stored by the applicable analytics services. For example, we may use performance or analytics Cookies to:
  • Maintain and continually improve our Services;
  • Keep track of the number of visitors to the pages within our Services;
  • Keep track of the length of time that each visitor spends on the pages within our Services;
  • Determine the order in which a visitor visits the various pages or features within our Services;
  • Identify performance issues with our Services;
  • Assess which parts of our Services need improvement.
• Advertising Cookies: These third-party cookies are used to deliver advertisements that are relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of advertising campaigns. Advertising cookies are usually placed by advertising platforms that work with other organizations to deliver personalized experiences to you. These cookies are used to:
  • Keep track of how you interact with the advertisements that we serve;
  • Keep track of which advertisements you have already been shown so that you are not always shown the same ones;
  • Keep track of how many visitors click on the advertisement;
  • Improve reporting on campaign performance.

(e) Targeted advertising

Our third-party advertising partners may collect information about your activity on our Services using tracking technologies, which include pixels and other Cookies. Tracking data collected by these third-party advertising partners is used to decide which ads you see and helps us provide more customized advertising and marketing.

(f) How to manage or delete cookies

You can exercise your preferences concerning Cookies served on our Services by taking the steps outlined below.

• Browser Settings: You may alter the Cookie settings in your browser settings at any time. You may accept all or only certain Cookies. If you disable Cookies in your browser settings, however, you may find that certain sections of our Services will not work.
• First-Party Cookies: If you do not want Cookies placed on your device, you can adjust the setting of your Internet browser to reject some or all Cookies and to alert you when a Cookie is placed on your device. To do this, follow the instructions provided by your browser (usually located within the “Help,” “Tools,” or “Edit” settings). While adjusting your browser setting can prevent the future placement of Cookies, it does not remove existing persistent Cookies.
• Third-Party Cookies: Browsers also allow you to block third-party Cookies using the steps described above for first-party Cookies.
• Preferences Tools: There are several services available that can assist you with managing your Cookie preferences, including industry groups, standards associations, and tools provided by the Cookie providers and social media sites. Please note that we have no affiliation with, and are not responsible for, third-party websites.
• Global Privacy Control and Privacy plug-ins: You can block cookies used for interest-based ads by installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery, or uBlock Origin and configuring them to block third-party cookies/trackers. For more information, please visit https://globalprivacycontrol.org
• Google Analytics: You may download the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout. DAA: You may use the Digital Advertising Alliance (“DAA”) consumer choice tools to apply opt-outs to interest-based advertising and other applicable uses of web-viewing data by DAA participating companies by visiting http://optout.aboutads.info/?c=2&lang=EN#completed.
• NAI: You may also manage opt-outs through the Network Advertising Initiative (“NAI”) opt-out tool at http://optout.networkadvertising.org/?c=1
• Web Beacons and Pixels: You may avoid web beacons and pixels by disabling the functionality that allows remote images to load in your email account and refraining from clicking on any links in email messages.

Opting out through these mechanisms does not block all online advertising. You will continue to receive generic advertisements. To learn more about how to manage Cookies and opt-out of Cookies being placed on your devices, please visit www.allaboutcookies.org.

Video content

The Services may offer certain video content. When you view video content, we disclose information about the video content you view to our Service Providers, which may include third-party advertising partners.

“Do Not Track” preferences

Afresh Services do not monitor for or behave differently if your browser or device transmits a “Do Not Track” or similar message. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, Afresh does not currently alter our practices when we receive a “Do Not Track” signal from a visitor’s browser except as specifically required by law. For information about “Do Not Track” please visit All About DNT.

Third-party links

We may provide links to other websites or resources with which we do not have a contractual relationship and over which we do not have control (“External Websites”). This Privacy Policy does not apply to or cover External Websites. Such links are not paid advertisements, nor do they constitute an endorsement by Afresh of those External Websites and are provided to you only as a convenience. By clicking on links to the External Websites, the operators of the External Websites may collect personal information. We are not responsible for the content or data collection practices of those External Websites, and your use of External Websites is subject to their respective terms of use and privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

Third-party social media plugins

The Services may offer Social Media Platform sharing features and other integrated tools that enable you to share or view certain content via social media sites (such as the X (Twitter) “Follow” button). These features may function as cookies or web beacons when you interact with them and collect information such as information about your device or your interactions with the Services, such as what you are viewing through the Services. If you are logged in to your account with the third party, the third party may be able to link information about your interactions with the Services to your account with them. Please refer to each third party’s privacy policies to learn more about its data practices.

Children’s privacy

Our Services are not intended for use by anyone younger than the age of 18 or under the applicable legal age of the relevant country. We do not knowingly collect personal information from children younger than the age of 18 without the consent of a parent or legal guardian, as required under applicable law. If you learn or believe that a child under the age of 18 has provided us with personal information, please contact us using the methods provided in the Contact Us section of this Privacy Policy below.

Your choices

(a) Marketing preferences

To stop receiving, or opt-out of, promotional email communications from Afresh, click on the “unsubscribe” link or follow the relevant opt-out instructions within the marketing communication. If you opt-out of receiving marketing emails, we will still send you transactional emails, such as for responses to your requests or communications about your account. To stop receiving SMS marketing communications from Afresh, you can opt out at any time by responding with the opt-out notice indicated in the SMS communication.

(b) Third party advertising and analytics

Afresh works with third-party network advertisers, ad agencies, and other advertising partners to serve Afresh ads online. We may use information we have learned about you to target ads to you and to allow our third-party advertising partners (e.g., Meta/Facebook, Google, Apple Search Ads, etc.) to manage our advertising on their websites. We also use third-party analytics providers to provide us with information regarding the use of the Services and the effectiveness of our advertisements. For more information about the tracking technologies that these third parties use and your options, please see the Cookies and Tracking Technologies section.

How long we retain personal information

We retain personal information for the purposes stated in this Privacy Policy and as required under applicable law. To determine how long we keep personal information, we consider the amount, nature, and sensitivity of personal information, the reasons for which we collect and process the information, and applicable legal requirements.

How we protect personal information

At Afresh, we take our responsibility to protect the security and privacy of personal information seriously. We have implemented what we believe to be reasonable and appropriate security measures designed to prevent personal information from being lost, used, accessed, altered, or disclosed in an unauthorized or unlawful way. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and we cannot and do not guarantee that personal information is completely secure and safe from such risks. By using the Services, you understand and assume the risks associated with your activities on the Internet.

If you have reason to believe that your information is no longer secure, please let us know by contacting us using the methods provided in the Contact Us section of this Privacy Policy.

California “Shine the Light” disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to opt-out of the sharing of certain categories of personal information with third parties for their direct marketing purposes. We do not currently share or disclose personal information with third parties for their own direct marketing purposes.

Notice to Nevada residents

Under Nevada law, Nevada “consumers” (individuals who are seeking or acquiring goods/services for personal, family, or household purposes) may opt out of the sale of covered personal information. Afresh does not currently sell covered information of Nevada consumers as defined under applicable Nevada law. You may submit an opt-out request by sending your request to the email address or mailing address specified in the Contact Us Section below, along with your full name, complete mailing address (including street address, city, state, and zip code), email address (so that we can contact you, if needed, in connection with the request) and confirmation that you are a Nevada resident.

International data transfers

The personal information that we collect or receive may be transferred to and processed in countries located outside of your country of residence to the countries where we or our third-party service providers process it. The data protection laws of the countries where personal information is processed may not be as comprehensive as or equivalent to those in your country of residence. Whenever we transfer personal information internationally, we take steps to protect it as required under applicable law.

Changes to this privacy policy

We may update this Privacy Policy from time to time. When we update this Privacy Policy, we will revise the “Last Updated and Effective Date” at the top of this Privacy Policy and post a link to the updated Privacy Policy on our Services. Changes to this Privacy Policy are effective when they are posted. If we make any material changes, we will provide you with notice as required under applicable law. Please review this Privacy Policy periodically to ensure you are aware of any such changes.

Contact us

If you have any questions about this Privacy Policy or our privacy practices, please contact us:

• By email at legal@afreshtechnologies.com; or
• By postal mail at this address:

Afresh Technologies, Inc.

490 43rd Street, Unit #121

Oakland, CA 94609

USA