Last updated: August 22, 2024

This Privacy Policy (“Policy”) describes how SET SET Inc., dba SetSet (“SetSet”, “we”, “us”, “our”) collects, uses, discloses and otherwise processes the personal information described in this Policy, as well as the rights and choices individuals have regarding that personal information.

Contents

Privacy Policy for SetSet

1. Introduction and Scope

This Privacy Policy (“Policy”) applies to any individual (“you”, “your”, “user”) who visits our website at setset.com (the “Site”), uses our mobile application (the “Application”), or otherwise interacts with SetSet, either online or offline. This includes your use of our subscription services and engagement with the content available on our Site or Application (collectively referred to as our “Services”). Individuals who subscribe to our Services are referred to as our “members.”

For information on the privacy choices available to you regarding your personal information, please refer to Section 7: Your Privacy Choices.

If you are a California resident, please see Section 13: Additional Privacy Information for California Residents for more information about the categories of personal information we collect and your rights under California privacy laws.

If you are a resident of Colorado, Connecticut, Utah, or Virginia, please refer to Section 14: Additional Privacy Information for Colorado, Connecticut, Utah, and Virginia Residents for more information about the categories of personal information we collect and your rights under these state privacy laws.

Please note that depending on your interactions with us, additional privacy notices with more specific details about our information practices may be provided. For instance, this Policy does not apply to our employees in the context of our employment relationship with them.

2. Personal Information We Collect

We collect personal information from you directly, automatically through your use of the Services, and from other unaffiliated sources. The type of personal information we collect varies depending on your use of our Services and our interactions with you.

Personal Information We Collect Directly from You

In general, we may collect the following personal information from you:

- Surveys and Information Gathering: We may offer surveys, quizzes, and other opportunities on and off our Services where we ask for information about you to better understand your interests. This helps us reach out to you about our services and offerings that may be of interest to you and for other purposes.

- Registration and Profile Information: When you subscribe as a member or register for an account with us, we collect personal information such as your name, email address, and phone number. This may also include any personal information you post to your profile or account, including your birthday, preferences, or other details you submit through your account.

- Purchasing Products: When you purchase products on our Services, including subscribing as a member, we collect information such as your name, shipping and billing address, email address, telephone number, account log-in credentials, and purchase history. Payment information, including payment card details and billing address, is also collected and shared with entities processing your payment. If you request a refund, we will collect relevant information.

- Household and Demographic Information: We may collect information about you and your household, such as household size and age ranges, that you provide to us.

- Communications, Interactions, and Reviews: When you contact us via email, phone, text, chat, or other means, we collect and maintain records of your communications. We also maintain records of interactions and communications in forums, social media channels, and customer support requests. If you choose to post a review, it will display your name, review, and rating of our Services.

- SetSet Newsletter: If you sign up for our newsletter, we collect your contact information, including your email address.

- Sweepstakes, Contests, and Promotions: If you participate in any sweepstakes, contests, or promotions, we collect your name, email address, and other registration information.

- Events and Other Requests: We collect personal information related to your participation in our events, workshops, or other activities. This may include information about your registration, video and audio recordings of events, and contents of any online forums or chats associated with the events.

- SetSet Community: If you are a member and participate in our forums or similar events, your username and any information you post, including reviews, comments, and text, will be available to and searchable by all SetSet members.

Personal Information We May Collect Automatically

We automatically collect personal information related to your use of our Services through cookies, pixel tags, and other similar technologies, such as:

- Device and Browsing Information: We may collect information such as IP address, browser type, domain name, access times, date/time stamps, operating system, language, device type, unique ID, Internet service provider, phone carrier and manufacturer, application installations, mobile advertising identifiers, push notifications, referring and exiting URLs, clickstream data, and similar device and browsing information.

- Activities and Usage: We may collect information about your interactions with our Services, such as links clicked, pages viewed, searches performed, features used, items viewed, time spent within the Services, keystrokes, mouse clicks, and other activity-related data. With your consent where required by law, we may also track information about the video and other content you view on our Services and share that information with our vendors and service providers.

- Location Information: We may collect or derive general location information, such as your IP address.

For more information about our use of cookies and similar technologies, please refer to Section 6: Cookies and Tracking.

Privacy Policy for SetSet

Personal Information We Collect from Other Sources

Payment Information:

When you make a purchase or payment through the Services, the vendors we engage for payment processing collect purchase and payment information from you to process the transaction. This includes your credit card number, purchase details, and payment history. These vendors then provide us with certain information about your payment transaction and purchase, such as your name, payment amount, billing location, and details about the chosen plan.

Other Sources:

We may also collect and receive personal information from other sources, including members, marketing and advertising agencies, analytics firms, social networks, telecommunications providers, and vendors providing services to us. For example, we may receive personal information about you from other members (e.g., via our SetSet forums), from individuals purchasing gifts for you on our Services, or from data analytics and marketing providers to help us reach potential members. Additionally, if you log in to our Services using your Google credentials, we will receive information from Google about you, such as your name, email address, profile picture, and language preference.

3. How We Use Personal Information

We may collect, use, disclose, and otherwise process the personal information we have collected about you for the following purposes:

- Services and Support:

To allow you to create and maintain your account with us, provide and operate our Services, communicate with you about your use of the Services (including via text message or email), provide troubleshooting and technical support, respond to your inquiries, and generally communicate with you about the Services.

- Analytics and Improvement:

To better understand how members access and use the Services and our product and service offerings, and for other research and analytical purposes. This includes evaluating and improving our Services and business operations, informing our marketing and promotion activities, developing our Services and their features, and for internal quality control and training.

- Customization and Personalization:

To tailor the content we send, suggest to you, or display on the Services, including offering location customization and personalized communications, help, and instructions, and otherwise personalize your experience.

- Communicate with You:

To respond to your inquiries, send requested materials, and other information about our Services and offerings, or third-party information and offerings you might find interesting. We also use this information to send you administrative updates, such as changes to our terms, conditions, and policies.

- Marketing and Promotions:

For marketing and promotional purposes, including sending you information about our Services via text message, email, or other means. This may include newsletters, marketing content, and information about events and webinars. We may also use certain information to manage and improve our advertising campaigns to better reach relevant audiences.

- Sweepstakes, Contests, and Promotions:

To administer any sweepstakes, contests, or promotions we offer.

- Research and Surveys:

To administer surveys and questionnaires for market research or user satisfaction purposes.

- Planning and Managing Events:

For event and webinar planning and other management-related purposes, such as registration, attendance, connecting you with other event attendees, and contacting you about relevant events and Services.

- Security and Protection of Rights and Interests:

To protect the Services and our business operations, safeguard our rights or those of our stakeholders, manage and respond to legal disputes and claims, prevent and detect fraud and unauthorized activities, and take action regarding illegal activities, suspected fraud, potential threats to safety, or violations of our Terms of Use.

- Compliance and Legal Process:

To comply with legal or regulatory obligations, including as part of judicial proceedings; to respond to subpoenas, warrants, court orders, or other legal processes; or as part of an investigation or request from law enforcement or a governmental authority.

- Auditing, Reporting, and Other Internal Operations:

To conduct audits and assessments of our operations, privacy, and security controls, financial controls, risk management, and compliance with legal obligations. This also includes assessments of our general business operations, accounting, recordkeeping, and legal functions.

- General Business and Operational Support:

To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions. This includes administering our business, accounting, auditing, compliance, recordkeeping, and legal functions, and enforcing company policies and procedures.

Additionally, to the extent permitted by applicable law, we may combine the personal information we collect with information from publicly available and other sources for any of the purposes described above.

4. How We Disclose Personal Information

We may disclose the personal information we collect for the purposes described above and as follows:

- Through the Site or Application:

Some of the information we collect is displayed on the Site or Application (e.g., in our forums) based on your account profile and settings. Certain information, such as your username, is always visible to others. You can choose whether to hide or display other information, such as your email address.

- Affiliates and Subsidiaries:

We may disclose personal information to our corporate affiliates and subsidiaries.

- Vendors and Service Providers:

We may disclose personal information to vendors and service providers who perform functions on our behalf, such as payment processing, email transmission, survey or contest administration, data hosting, analytics, marketing, and technical and customer support services.

- Marketing and Analytics Providers:

We may disclose certain personal information, such as device and browsing history and activities and usage information, to marketing and advertising networks, data analytics providers, and other companies providing marketing or analytics services on our behalf. For more details, please see Section 6: Cookies and Tracking.

Additionally, we may disclose your personal information in the following circumstances:

- To Operate Our Business:

We may disclose personal information to our business partners, such as entities offering payment processing services, to operate our business and provide our Services.

- In Support of Business Transfers:

If we or our affiliates are acquired by, merged with, or invested in by another company, or if any of our assets are transferred to another company (whether as part of a bankruptcy or insolvency proceeding or otherwise), we may disclose or transfer the personal information we have collected from you to the other company. We may also disclose personal information as necessary before completing such a transaction or other corporate transactions like financing or restructuring, to lenders, auditors, and external advisors (e.g., attorneys and consultants).

- Compliance and Legal Obligations:

We may disclose personal information to comply with legal and compliance obligations and respond to legal processes. For example, we may disclose personal information in response to subpoenas, court orders, and other lawful requests by government officials and law enforcement, including responding to national security or law enforcement disclosure requirements.

- Security and Protection of Legal Rights and Interests:

We may disclose personal information where we believe it is necessary to protect the Services, our rights and property, or the rights, property, and safety of others. This includes preventing, detecting, investigating, and responding to fraud, unauthorized activities, unauthorized access, illegal activities, and misuse of the Services, as well as addressing potential threats to health, safety, or legal rights. We may also disclose personal information related to litigation and other legal claims or proceedings in which we are involved and for our internal accounting, auditing, compliance, recordkeeping, and legal functions.

5. Aggregate and Deidentified Information

Notwithstanding any other provisions in this Policy, SetSet may use, disclose, and process aggregate and deidentified information related to our platform and services with third parties for purposes such as quality control, analytics, research, and development. When we utilize or share de-identified data (data that is no longer reasonably linked to an identifiable person, household, or device), we will maintain and use this data in its deidentified state and will not attempt to re-identify it, except to verify the effectiveness of our deidentification methods, as required by applicable privacy laws.

6. Cookies and Tracking

SetSet, along with our service providers, uses cookies, pixels, local storage objects, log files, APIs, and other tracking mechanisms—including session replay technology—to automatically collect information about your browsing activities, device interactions, and other activities within our platform. This information helps us analyze how users engage with our services, identify and fix errors, secure our platform, and optimize overall performance. You have the ability to manage these tracking technologies, as described below. Additionally, we may aggregate this information for broader analytics and demographic purposes. If you reside in the UK, EEA, or Switzerland, further details on our use of cookies and tracking tools can be found in our UK/EEA/Swiss Cookie Policy [here].

- Cookies: Cookies are alphanumeric identifiers that we transfer to your device via your web browser. Some cookies facilitate easier navigation of our platform, while others enable a faster login process, enhance security, or track usage data.

- Pixel Tags: Pixel tags (also known as web beacons or clear GIFs) are small graphics embedded within web pages and online content that function similarly to cookies. We use pixel tags in connection with our services to monitor user activities, manage content, and compile usage statistics. They are also used in emails to track response rates and measure communication effectiveness.

- Local Storage Objects: Local storage allows us to store data in your browser that persists even after the window is closed. This may be used to cache information for faster page loading and to link your activities with your profile. You can clear this data through your browser settings.

- Analytics: We employ tools like Google Analytics to assess the usage of our platform. These tools use cookies, pixel tags, and other tracking technologies to gather usage data, which is then used to generate reports that help us improve our services and user experiences. For more on Google’s privacy practices, visit the Google Privacy Policy [here](https://policies.google.com/technologies/partner-sites). You can opt out of Google Analytics by downloading the Google Analytics Opt-out Browser Add-on [here](https://tools.google.com/dlpage/gaoptout).

- Cross-Device Tracking: We and our partners may use collected data across different devices (e.g., mobile phones, tablets, computers) to identify and target users more effectively.

- Customer Lists and Matching: Subject to legal requirements, we may share customer list information (such as names, email addresses, and other contact details, often in hashed form) with third parties to deliver targeted ads and content. In some cases, these third parties may enhance our customer lists with additional demographic or other information to improve our marketing efforts.

- Advertising: SetSet partners with ad networks, analytics providers, and marketing companies to personalize content and deliver targeted ads within our platform and on third-party sites. These partners may use cookies, pixel tags, and other tools to collect data about your activities within our services and on other sites, as well as information like IP addresses and unique device identifiers. This data helps us and our partners serve relevant ads and assess their effectiveness.

7. Your Privacy Choices

SetSet provides several options for managing your personal information and privacy preferences, including cookie settings, advertising preferences, marketing communications, and account information. These preferences are often browser- and device-specific, so you may need to adjust them for each device and browser you use.

- Account Information: As a member, you can review and update much of the personal information we hold about you by emailing us at hi@getsetset.com.

- Cookie Settings: You can prevent cookies from tracking your activity by adjusting your browser settings to block certain cookies or notify you when a cookie is set. Visitors who disable cookies can still browse our platform, but some features may not work properly. You can adjust your cookie preferences on our site [here].

- Industry Ad Choice Programs: Control how third-party ad companies use your information to display targeted ads by visiting the Digital Advertising Alliance’s opt-out page [here](https://youradchoices.com/appchoices) or, for EU residents, the European Interactive Digital Advertising Alliance [here](https://www.youronlinechoices.com). Please note that opting out of targeted ads does not mean you will no longer see ads; you may still receive non-targeted or "contextual" ads.

- Marketing and Other Communications: Opt out of marketing emails by using the unsubscribe link in any marketing email we send. To opt out of text messages, reply “STOP” or “NO” to any text you receive from us.

California, Colorado, Connecticut, Utah, Virginia, UK, EEA, and Swiss residents should refer to the respective sections in this Privacy Policy for information about additional rights under relevant privacy laws. For more information about our privacy practices and how to exercise your rights, please refer to the 'Contact Us' section below.

8. External Links and Features

Our platform may include links to third-party websites or features. Additionally, where allowed by law, we may send you communications containing links to external third-party services or sites that we believe may be of interest to you (for example, third-party sites offering SetSet-branded merchandise). Please note that any access to and use of these linked websites or features is not governed by this Privacy Policy but is instead subject to the privacy policies of those third-party entities. SetSet is not responsible for the privacy practices of these unaffiliated entities, including their collection and use of your personal information. We recommend reviewing the privacy policies and terms of any third-party websites or features before using them.

9. Security

We have put in place security measures intended to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, please be aware that, despite our best efforts, no security measures can provide absolute security.

10. Retention

SetSet retains the personal information we collect only as long as reasonably necessary for the purposes described in this Privacy Policy or as otherwise disclosed to you at the time of collection. For instance, we retain your information as needed to comply with legal obligations related to tax, accounting, and recordkeeping, as well as for an additional period to protect, defend, or establish our rights, defend against potential claims, and comply with applicable laws.

11. Changes to this Policy

This Privacy Policy is periodically reviewed and updated in accordance with applicable law to ensure it accurately reflects our information practices. When we update this Policy, we will revise the “Last Updated” date at the top of this document and make the updated policy available on our platform.

If we make significant changes to this Policy that materially affect our practices concerning the use of personal information we previously collected, we will endeavor to notify users, such as by posting a prominent notice on our platform.

12. Contact Us

If you have any questions or concerns regarding this Privacy Policy or how SetSet handles your personal information, please contact us at hi@getsetset.com.

13. Additional Privacy Information for California Residents

This section of the Privacy Policy provides additional details specifically for California residents, in compliance with the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), and its implementing regulations.

Scope: This section applies to "personal information" as defined by the CCPA, whether collected online or offline. This section does not cover or apply to our handling of personal information that is exempt under the CCPA, such as publicly available information or aggregated or de-identified information.

Categories of Personal Information Collected and Disclosed: While our processing of personal information varies based on our relationship and interactions with you, the table below outlines the general categories of personal information (as defined by the CCPA) that SetSet has collected about California residents in the past twelve (12) months, along with the categories of third parties to whom we may disclose this information for business or commercial purposes.

Sales and Sharing of Personal Information

California privacy laws define a “sale” as the disclosure or availability of personal information to a third party in exchange for monetary or other valuable consideration, while “sharing” includes making personal information available to third parties for cross-context behavioral advertising purposes. While SetSet does not disclose personal information to third parties in exchange for direct monetary compensation, we may “sell” or “share” certain technical information—such as your IP address, digital identifiers, web browsing behavior, interactions with our ads, and analytics data—with third-party partners in data analytics, marketing, and advertising. This is done to enhance, manage, and evaluate our services and advertising efforts. Importantly, SetSet does not sell or share sensitive personal information, nor do we sell personal information related to individuals under the age of 16.

Sources of Personal Information

We may collect personal information from a variety of sources, including but not limited to:

- You, directly

- Other users of our services

- Internet service providers, operating systems, and platforms

- Advertising networks, social networks, and data analytics providers

- Publicly available information and data brokers

- Government entities

Purposes of Collection, Use, and Disclosure of Personal Information

As outlined in Section 3 (**How We Use Personal Information**) and Section 4 (**How We Disclose Personal Information**), SetSet collects, uses, discloses, and processes personal information for various business or commercial purposes, which may include:

- Providing services and support

- Conducting analytics and improving our offerings

- Customizing and personalizing your experience

- Communicating with you

- Marketing and promotional activities

- Research and surveys

- Planning and managing events

- Ensuring security and protecting rights and interests

- Compliance with legal obligations

- Auditing, reporting, and other internal operations

- General business and operational support

Sensitive Personal Information

SetSet does not collect, use, or disclose sensitive personal information beyond the purposes authorized by the California Consumer Privacy Act (CCPA). We do not engage in practices that would require us to seek your explicit consent to use or disclose your sensitive personal information under the CCPA regulations (Cal. Code. Regs., tit. 11, § 7027 (2022)).

Retention

For details on how SetSet retains your personal information, please refer to Section 11 (Retention).

Your Rights and Choices

The CCPA grants California residents specific rights regarding their personal information, subject to certain exceptions:

- Know/Access: The right to know the personal information we have collected about you, including the categories of personal information, sources, purposes for collection, categories of third parties to whom we disclose it, and the specific pieces of personal information we hold.

- Deletion: The right to request the deletion of personal information that we have collected about you.

- Correction: The right to correct any inaccurate personal information we maintain.

- Opt-out rights: The right to opt out of the “sale” or “sharing” of your personal information, as defined by the CCPA.

- Limit certain uses and disclosures of sensitive personal information:** Although SetSet does not engage in such practices, you have the right to limit the use and disclosure of sensitive personal information under certain circumstances.

- Right to non-discrimination: The right not to be discriminated against for exercising your CCPA rights.

Submitting CCPA Requests

California residents can exercise their CCPA rights as follows:

- Requests to Know/Access, Correct, and Delete:** You can submit a request to SetSet to exercise your rights to know/access, delete, and correct your personal information by submitting a privacy request by emailing us at hi@getsetset.com

Verification of Requests

To ensure the security of your personal information, SetSet will take steps to verify your identity when you make a request. We will do this by matching the information you provide with the information we have in our records. You will need to complete all required fields on our webform (or provide the necessary information via the toll-free number provided). We will process your request based on the personal information in our records that is linked or reasonably linkable to the information you provide. In certain cases, we may ask for additional information to verify your request or to process it appropriately. If we are unable to verify your request, we will notify you.

If you choose to use an authorized agent to submit a request on your behalf, the agent must contact us via the toll-free number or online webform. Authorized agents will be required to provide proof of their authorization, and we may also require the relevant consumer to directly verify their identity and the agent's authority.

Requests to Opt-Out

Our website supports Global Privacy Control (GPC) signals, which means that if we detect your browser is sending a GPC signal, we will, to the extent required by law, treat it as a request to opt-out for that specific browser and device from "sales" and "sharing" (as defined by the CCPA) that involve cookies and tracking tools.

California residents may also opt out of "sales" and "sharing" through cookies and other online tracking technologies on our website by adjusting their cookie privacy preferences using our cookie preference manager. This can be accessed by clicking [here](https://globalprivacycontrol.org/). Keep in mind that if you return to our website using a different device or browser, you will need to re-enable GPC or adjust your cookie preferences again for each browser and device you use.

You can also exercise your opt-out rights for "sales" and "sharing" beyond cookies and tracking technologies by submitting an opt-out request via our request form or by calling us toll-free at 1 (856) 712-9799.

Financial Incentives

SetSet may offer consumers the opportunity to participate in sweepstakes, giveaways, and similar programs that might be considered "financial incentives" under the CCPA. For example, you may have the chance to enter a sweepstakes to win prizes such as gift cards, merchandise, and other services by providing your contact information and joining our marketing lists. Alternatively, you might provide your contact details and feedback about our services in exchange for gift cards, merchandise, or other products.

As part of these programs, we collect certain personal information, such as identifiers and other personal details. Participation in these programs is voluntary. If you wish to participate, you may opt-in when we reach out to you or when a program is available on our Services. You can opt out of these programs at any time by emailing us at hi@getsetset.com.

Rights Under California Shine the Light Law

Under California's "Shine the Light" law (Cal. Civ. Code § 1798.83), California residents who provide us with certain personal information are entitled to request and receive, once per calendar year and free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing purposes in the previous calendar year. To submit a "Shine the Light" request, please email us at hi@getsetset.com. Be sure to include a current California address and your attestation that you are a California resident.

Contact Us

For any questions or concerns about this Privacy Policy or how we handle your personal information, please refer to the "Contact Us" section above.

13a. California Applicant Privacy Notice

This California Applicant Privacy Notice (the “Applicant Notice”) outlines how SetSet (“SetSet”, “we”, “our”, or “us”) collects and uses personal information related to California residents who are external job applicants and potential candidates for positions with SetSet (each an “Applicant”; “you” or “your”). This notice is intended to meet our notice and privacy policy requirements under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and its implementing regulations (together, the “CCPA”).

The information provided in this Applicant Notice offers a general overview of how we handle Applicant personal information. We may provide additional notices specific to certain data practices, such as those required by other laws (e.g., if we conduct a background check) or notices that apply when Applicants browse or use our website. We encourage you to review this Applicant Notice alongside any other privacy notices we may provide.

A. Scope

This Applicant Notice applies to the personal information we collect and process about Applicants in connection with reviewing, assessing, considering, managing, storing, or processing their applications or evaluating them for positions with SetSet. Your use of our website or submission of an application or related information through our website is governed by our Privacy Policy and Terms of Use, which include terms regarding limitations on liability and dispute resolution. Our Terms of Use are incorporated by reference into this Applicant Notice.

This notice does not cover our collection of personal information that is not subject to the CCPA, such as consumer credit reports, background checks, publicly available data, or other information exempt under the CCPA. It also does not apply to personal information collected from contractors or employees, which is governed by separate privacy notices.

B. Categories of Personal Information Collected and Disclosed

The table below generally identifies the categories of personal information about Applicants that we collect and have collected in the past twelve (12) months. It also identifies the categories of other entities to whom we may disclose this information for business or commercial purposes. In certain circumstances (such as where required by law), we may seek your consent or provide you with choices before collecting or using specific personal information.

| Category of Personal Information | Examples | Disclosed to |

|-----------------------------------------------|-------------------------------------------------|-------------------------------------------------------|

| Identifiers | Name, email address, phone number, etc. | Service providers, background check agencies |

| Professional or employment-related info | Employment history, qualifications, etc. | Service providers, potential employers |

| Education information | Academic records, certifications, etc. | Educational institutions, credential verification |

| Internet or other electronic network activity | IP address, browsing history (when using our site) | Analytics providers, IT security service providers |

| Geolocation data | Physical location data (when visiting our offices) | Security personnel, facility management services

| Inferences | Preferences, abilities, or aptitudes inferred from other data | Recruitment analytics and HR systems

In certain cases, we may ask for your explicit consent before collecting or using certain personal information, especially when required by law.

Please refer to our main Privacy Policy for additional details on how we manage, retain, and protect personal information. If you have any questions about this Applicant Notice or need further information, please contact us as detailed in the "Contact Us" section of our Privacy Policy.

Sales and Sharing of Personal Information

Under California privacy laws, the term "sale" is broadly defined as disclosing or making personal information available to a third party in exchange for monetary or other valuable consideration. "Sharing" includes disclosing or making personal information available to a third party for purposes of cross-context behavioral advertising. SetSet does not sell or share (as defined by the CCPA) personal information or sensitive personal information about Applicants covered by this Applicant Notice, including those under the age of 16.

Sources of Personal Information

We may collect personal information about Applicants from various sources, as outlined below:

- Directly from you: Information you provide to us directly through your application or other communications.

- Recruiters and recruiting platforms: Information obtained from external recruiters or platforms that help match candidates with job opportunities.

- Referrals and references: Information provided by individuals referring you to a position or from references you provide.

- Internet service providers: Information collected through your interactions with our online platforms.

- Operating systems and platforms: Data gathered from the systems and platforms you use to interact with our Services.

- Government entities: Information available from public records or provided by government agencies.

- Social networks: Data collected from social media platforms if you interact with our pages or content.

- Publicly available information: Information from public sources.

- Service providers, representatives, and agents: Information provided by third parties that perform services on our behalf.

- Affiliates and subsidiaries: Data shared within our corporate family to support our operations.

Retention

SetSet retains the personal information we collect for as long as it is reasonably necessary for the purposes described in this policy or as otherwise disclosed to you at the time of collection. For instance, we may retain your information to fulfill tax, accounting, and recordkeeping obligations, to consider you for future positions (with your consent), or for an additional period necessary to protect, defend, or establish our legal rights, defend against potential claims, and comply with legal obligations.

Purposes for Collecting, Using, Disclosing, and Processing Personal Information

Subject to applicable legal restrictions, SetSet collects, uses, discloses, and processes Applicant personal information as reasonably necessary for the following purposes:

1. Recruiting, Hiring, Managing, and Evaluating Applicants

- Reviewing and Assessing Applications: To review, assess, and consider candidates for employment, including scheduling and conducting interviews, and identifying suitable candidates, possibly in collaboration with external recruiters.

- Evaluating Qualifications: To verify the information provided by Applicants and to screen or evaluate their qualifications, suitability, and relevant characteristics for the role.

- Job Offers and Compensation: To extend offers, negotiate terms, and assess salary and compensation matters.

- Legal Compliance: To satisfy legal and regulatory obligations related to the hiring process.

- Communication: To communicate with Applicants regarding their application status and other potential job opportunities that may be of interest.

- Future Consideration: To maintain Applicant personal information for future consideration.

- Equal Opportunity: To support our commitment to equal opportunity employment policies and practices.

2. Contacting You About Potential Positions

- Identifying Suitable Roles: To identify other positions within SetSet for which an Applicant may be qualified or interested.

- Communication: To contact Applicants regarding these opportunities. If you prefer not to be contacted about potential positions, you can notify us using the contact information provided below.

3. Security and Monitoring

- Incident Response: To detect, prevent, investigate, and respond to security and privacy incidents.

- Access Controls: To manage physical and technical access controls and maintain the security and functionality of our systems and assets.

- Monitoring: To monitor access and use of our systems to ensure security, including the use of electronic access systems and video monitoring to secure our offices, premises, and physical assets.

4. Health and Safety

- Screenings: To conduct appropriate health and safety screenings of Applicants before they enter or access specific locations or premises.

- Contact Tracing: To engage in contact tracing and other health-related safety measures.

5. Auditing, Accounting, and Corporate Governance

- Audits: To conduct financial, tax, and accounting audits, as well as audits of our business operations, security controls, and compliance with legal obligations.

- **Internal Business Purposes**: For general internal business operations and governance.

6. M&A and Other Business Transactions

- Transaction Planning: For planning, due diligence, and execution of commercial transactions, such as mergers, acquisitions, asset sales, transfers, bankruptcy, reorganization, or similar business transactions.

7. Defending and Protecting Rights

- Legal Defense: To protect and defend the rights and interests of SetSet and third parties, manage job applicant and other legal disputes, respond to legal claims, and otherwise establish, defend, or protect our rights or interests, including in litigation contexts.

8. Complying with Legal Obligations

- Legal Compliance: To comply with applicable legal obligations, including those related to hiring eligibility, responding to subpoenas and court orders, and adhering to employment and labor laws, Social Security and tax laws, environmental regulations, workplace safety laws, and other relevant laws and guidelines.

Sensitive Personal Information

SetSet does not collect, use, or disclose sensitive personal information about Applicants beyond what is authorized by the CCPA (as per Cal Civ. Code § 1798.121 and § 7027(m) of the CCPA regulations).

D. Your CCPA Rights

As a California Applicant, you have specific rights under the California Consumer Privacy Act (CCPA) regarding your personal information. These rights are subject to certain limitations and exceptions:

1. Right to Know/Access

- You have the right to know what personal information SetSet has collected about you. This includes the categories of personal information, the sources from which the personal information was collected, the business or commercial purposes for collecting, selling, or sharing the information, the categories of third parties with whom we share your information, and the specific pieces of personal information we have collected about you.

2. Right to Deletion

- You have the right to request the deletion of personal information that SetSet has collected about you, subject to certain exceptions.

3. Right to Correction

- You have the right to request the correction of inaccurate personal information that SetSet maintains about you.

4. Right to Opt Out of Sales and Sharing

- You have the right to opt out of the sale and sharing of your personal information. However, as noted earlier, SetSet does not sell or share Applicant personal information as defined by the CCPA, so this right is not applicable to your Applicant information.

5. Right to Limit Use or Disclosure of Sensitive Personal Information

- You have the right to request the limitation of certain uses and disclosures of sensitive personal information. However, SetSet does not use or disclose Applicant sensitive personal information beyond what is authorized by the CCPA, so this right is not applicable to your Applicant information.

6. Right to Non-Discrimination

- You have the right not to be subjected to discriminatory treatment for exercising your rights under the CCPA.

Submitting CCPA Requests

California Applicants may exercise their CCPA privacy rights as follows:

Requests to Know/Access, Correct, and Delete

- You may submit a request to SetSet to exercise your CCPA rights to know/access, delete, and correct your personal information by using our online privacy request form or by calling us toll-free at 1 (856) 712-9799.

Verification of Your Request

- To process your request, SetSet will take steps to verify your identity by matching the information you provide with the information in our records. To verify your request, you must:

- Provide sufficient information that allows us to reasonably verify that you are the individual about whom we collected personal information or that you are an authorized representative. This may involve completing all required fields on our webform or providing similar information via phone.

- Describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.

- In some cases, SetSet may request additional information to verify your request or where necessary to process it. Authorized agents may initiate a request on behalf of another individual by using one of the above methods. Authorized agents will be required to provide proof of their authorization, and SetSet may require the relevant Applicant to directly verify their identity and the authority of the authorized agent.

E. Contact Us About This Applicant Notice

For additional details or questions regarding our use of your personal information as described in this Applicant Notice, you may contact us at hi@setset.com.

14. Additional Privacy Information for Colorado, Connecticut, Utah, and Virginia Residents

This section addresses the privacy rights under the Colorado Privacy Act (ColoPA), Connecticut Privacy Act (CPOMA), Utah Consumer Privacy Act (UCPA), and Virginia Consumer Data Protection Act (VCDPA) (collectively referred to as "State Privacy Laws"). For the purpose of this section, "Personal Data" refers to any information that is linked or reasonably linkable to an identified or identifiable natural person. Personal Data does not include de-identified data, publicly available information (as defined under the State Privacy Laws), or any other Personal Data excluded from the scope of the State Privacy Laws.

Please refer to Sections 2 ("Personal Information We Collect") and 3 ("How We Use Personal Information") for information on the categories of Personal Data we process as a controller and the purposes for processing such data. Additionally, Section 4 ("How We Disclose Personal Information") provides details on the categories of third parties to whom we disclose Personal Data as described in Section 2.

If you are a resident of Colorado, Connecticut, Utah, or Virginia, you may exercise the following rights with respect to your Personal Data:

1. Right to Confirm and Access

- You have the right to confirm whether we process your Personal Data and request access to such data.

2. Right to Delete

- You have the right to request the deletion of Personal Data that you have provided to us or that we have obtained about you.

3. Right to Correct

- You have the right to request the correction of inaccuracies in your Personal Data.

4. Right to Opt-Out

- You have the right to opt out of the sale of your Personal Data. Additionally, you can opt out of the processing of your Personal Data:

- For purposes of targeted advertising; and

- For certain types of profiling that produce legal or similarly significant effects.

5. Right to Data Portability

- You have the right to obtain a copy of your Personal Data in a portable and, to the extent technically feasible, readily usable format.

Please note that there are exceptions and limitations to these rights. To exercise your rights to know, correct, or delete your Personal Data, please contact us by email hi@getsetset.com

You may also opt out of any "sales" of Personal Data through cookies and other online tracking technologies by adjusting your cookie privacy preferences in our cookie preference manager, accessible [here]. If you access our website from a different device or browser, you will need to enable Global Privacy Control (GPC) or set your cookie preferences for each device and browser you use. More information about GPC is available at: [https://globalprivacycontrol.org/](https://globalprivacycontrol.org/).

Appeal Process

If you are a resident of Colorado, Connecticut, or Virginia and we refuse to take action on your request, you have the right to appeal this refusal. You may file an appeal by emailing us at hi@getsetset.com.