Unless we specifically state otherwise, the Celo Foundation is the data processor of the Personal Data we process, and is therefore responsible for ensuring that the systems and processes we use are compliant with data protection laws, to the extent applicable to us.

Celo Foundation personnel are required to comply with this Privacy Policy and complete data protection training, where appropriate.

The Celo Foundation collects information that you provide directly to us when you browse our Site, register to receive newsletter requests or other information, provide feedback through surveys, participate in any interactive features on our Sites including contests, promotions, challenges, activities or events. We also collect data provided by job applicants or others on our Sites or offline means in connection with employment or consulting opportunities, which may also be subject to other Policies. We may also collect Computer Internet Protocol (IP) address, unique device identifier (“UDID”), cookies, web beacons, web server logs and other technologies and other data linked to a device, and data about usage of our Sites (Usage Data). A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. Other types of information we may collect include your name, email address, username, password, phone number, location and any other information you choose to provide. We may use these automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner may include your device IP address, identifiers associated with your devices, types of devices connected to our services, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Site.

We use the Personal Data that we collect:

• To make our Sites more intuitive and easier to use we use device data, cookies and other information that you may provide. This data is necessary for our legitimate interests in monitoring how our Sites are used to help us improve these Sites, and the information and tools available on these Sites.

• To provide relevant marketing including providing you with information about events or services that may be of interest to you. It is necessary for our legitimate interests to process this information in order to provide you with tailored and relevant marketing, updates and invitations.

• To consider individuals for employment and contractor opportunities and manage on-boarding processes we use job applicant data. The processing is necessary for the purposes of recruitment and on-boarding.

• To carry out any other purpose for which the information was collected.

We may also use automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner may include your device IP address, identifiers associated with your devices, types of devices connected to our services, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Site. The information we collect through cookies and similar technologies helps Celo (1) remember your information so you will not have to re-enter it; (2) understand how you use and interact with our website; (3) measure the usability of our website and the effectiveness of our communications; and (4) otherwise manage and enhance our website, and help ensure it is working properly. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our website.

You have control regarding our use of Personal Data for direct marketing. In certain markets, you will need to expressly consent before receiving marketing. In all markets, you can choose to not receive marketing communications at any time. If you no longer wish to receive marketing communications from Celo, or remain on a mailing list to which you previously subscribed, or receive any other marketing communication, please follow the unsubscribe link in the relevant communications or contact us as specified below.

• With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;

• In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;

• If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of us or any third-party;

• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company;

• With your consent or at your direction; and

• We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

If you are an individual from the European Economic Area (“EEA”), we collect and process your Personal Data only where we have legal basis for doing so under applicable EU laws. The legal basis depends on the Services you use and how you use them. This means we collect and use your personal data only:

• To operate our business, including to improve and develop our services, for fraud prevention purposes, improve user experience, or other legitimate interest;

• To fulfill contractual responsibilities; and/or

• As otherwise in compliance with law.

If you have any questions about the legal basis for processing, please contact us at the address listed in the “Contact Us” section.

We may transfer your Personal Data to countries outside the United Kingdom and the European Economic Area (“EEA”), including, but not limited to the United States, where Celo’s headquarters and some of its IT systems (including email) are located.

Protecting your information is important to us. We maintain administrative, technical and physical safeguards designed to protect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use of Personal Data.

We strive to only keep your Personal Data only for the period of time needed for legitimate business purposes. In certain circumstances, however, legal or regulatory obligations may require us to retain records for a longer than we otherwise would.

Our Services are not directed to children under the age of 16. If you learn that a child under the age of 16 has provided us with personal information without consent, please contact us.

If you are in the EEA you have have the right, subject to certain exceptions, to request a copy of the Personal Data we are processing about you, to require that any incomplete or inaccurate Personal Data is amended, to request that we delete your Personal Data (although we may not be able to delete certain data due to legal or other obligations), to object to the use of your Personal Data or to withdraw consent. If you are in the EEA, you also have a right to lodge a complaint with the local data protection authority if you believe that we have not complied with the applicable data protection laws. You may also contact us to address and resolve concerns you may have about our use of your Personal Data. Please contact us at [email protected].

We reserve the right to change and update this Privacy Policy from time to time. If we make changes, you will be notified of the change by the date at the top of Privacy Policy, which will reflect the last date updated.

Certain third-party services, websites, or applications you use, or navigate to from our Services may have separate user terms and privacy policies that are independent of this Policy. This includes, for example, websites owned and operated by our customers or partners. We are not responsible for the privacy practices of these third-party services or applications. We recommend carefully reviewing the user terms and privacy statement of each third-party service, website, and/or application prior to use.