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The original message has been attached to this so you can view it or label similar future email. If you have any questions, see root\@localhost for details. Content preview: La tua iscrizione è scaduta! Gentile Cliente, La tua iscrizione è scaduta! Content analysis details: (3.1 points, 5.0 required) pts rule name description ---- ---------------------- -------------------------------------------------- 0.0 RCVD_IN_VALIDITY_CERTIFIED_BLOCKED RBL: ADMINISTRATOR NOTICE: The query to Validity was blocked. See https://knowledge.validity.com/hc/en-us/articles/20961730681243 for more information. [212.39.90.88 listed in sa-trusted.bondedsender.org] 0.0 URIBL_BLOCKED ADMINISTRATOR NOTICE: The query to URIBL was blocked. See http://wiki.apache.org/spamassassin/DnsBlocklists#dnsbl-block for more information. 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[212.39.90.88 listed in bl.score.senderscore.com] -0.0 SPF_PASS SPF: sender matches SPF record 0.0 KAM_DMARC_STATUS Test Rule for DKIM or SPF Failure with Strict Alignment 0.0 HTML_MESSAGE BODY: HTML included in message 0.8 CPANEL_LOTS_OF_EMPTY_LINE RAW: Spam that has large block of empty lines 0.8 KAM_INFOUSMEBIZ Prevalent use of .info|.us|.me|.me.uk|.biz|xyz|id|rocks|life domains in spam/malware 0.0 T_KAM_HTML_FONT_INVALID Test for Invalidly Named or Formatted Colors in HTML 0.0 T_FILL_THIS_FORM_SHORT Fill in a short form with personal information 1.5 FORM_FRAUD_5 Fill a form and many fraud phrases 0.0 T_FILL_THIS_FORM_FRAUD_PHISH Answer suspicious question(s) X-Spam-Flag: NO You will not see this in a MIME-aware mail reader. --===============2085326154== Content-Type: text/plain; charset="utf-8" MIME-Version: 1.0 Content-Transfer-Encoding: quoted-printable Content-Description: Mail message body = = = = La tua iscrizione =E8 scaduta! Gentile Cliente, La tua iscrizione =E8 scaduta! Ma, come parte del nostro programma fedelt=E0, ora puoi estenderlo gratuit= amente per 90 giorni. = = Estendi gratuitamente = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = Privacy Policy Effective date: June 28, 2023 This Privacy Policy describes Our policies and procedures on the collectio= n, use and disclosure of Your information when You use the Service and tell= s You about Your privacy rights and how the law protects You. We use Your Personal data to provide and improve the Service. By using the= Service, You agree to the collection and use of information in accordance = with this Privacy Policy. = Interpretation and Definitions = Interpretation The words of which the initial letter is capitalized have meanings defined= under the following conditions. The following definitions shall have the same meaning regardless of whethe= r they appear in singular or in plural. = Definitions For the purposes of this Privacy Policy: = You means the individual accessing or using the Service, or the company, or= other legal entity on behalf of which such individual is accessing or usin= g the Service, as applicable. Under GDPR (General Data Protection Regulatio= n), You can be referred to as the Data Subject or as the User as you are th= e individual using the Service. = Company (referred to as either "the Company", "We", "Us" or "Our" in this A= greement) refers to Mountain Communities Supporting Education, Inc. dba The= Collaborative, 91 VT Route 11, Londonderry, VT 05148. For the purpose of t= he GDPR, the Company is the Data Controller. = Affiliate means an entity that controls, is controlled by or is under commo= n control with a party, where "control" means ownership of 50% or more of t= he shares, equity interest or other securities entitled to vote for electio= n of directors or other managing authority. = Account means a unique account created for You to access our Service or par= ts of our Service. = Website refers to The Collaborative, accessible from https://thecollaborati= ve.us = Service refers to the Website. = Country refers to: Vermont, United States = Service Provider means any natural or legal person who processes the data o= n behalf of the Company. It refers to third-party companies or individuals = employed by the Company to facilitate the Service, to provide the Service o= n behalf of the Company, to perform services related to the Service or to a= ssist the Company in analyzing how the Service is used. For the purpose of = the GDPR, Service Providers are considered Data Processors. = Third-party Social Media Service refers to any website or any social networ= k website through which a User can log in or create an account to use the S= ervice. = Facebook Fan Page is a public profile named The Collaborative specifically = created by the Company on the Facebook social network, accessible from http= s://www.facebook.com/thecollaborativeus = Personal Data is any information that relates to an identified or identifia= ble individual. For the purposes for GDPR, Personal Data means any informat= ion relating to You such as a name, an identification number, location data= , online identifier or to one or more factors specific to the physical, phy= siological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any information that ide= ntifies, relates to, describes or is capable of being associated with, or c= ould reasonably be linked, directly or indirectly, with You. = Cookies are small files that are placed on Your computer, mobile device or = any other device by a website, containing the details of Your browsing hist= ory on that website among its many uses. = Device means any device that can access the Service such as a computer, a c= ellphone or a digital tablet. = Usage Data refers to data collected automatically, either generated by the = use of the Service or from the Service infrastructure itself (for example, = the duration of a page visit). = Data Controller, for the purposes of the GDPR (General Data Protection Regu= lation), refers to the Company as the legal person which alone or jointly w= ith others determines the purposes and means of the processing of Personal = Data. = Business, for the purpose of the CCPA (California Consumer Privacy Act), re= fers to the Company as the legal entity that collects Consumers' personal i= nformation and determines the purposes and means of the processing of Consu= mers' personal information, or on behalf of which such information is colle= cted and that alone, or jointly with others, determines the purposes and me= ans of the processing of consumers' personal information, that does busines= s in the State of California. = Consumer, for the purpose of the CCPA (California Consumer Privacy Act), me= ans a natural person who is a California resident. A resident, as defined i= n the law, includes (1) every individual who is in the USA for other than a= temporary or transitory purpose, and (2) every individual who is domiciled= in the USA who is outside the USA for a temporary or transitory purpose. = Sale, for the purpose of the CCPA (California Consumer Privacy Act), means = selling, renting, releasing, disclosing, disseminating, making available, t= ransferring, or otherwise communicating orally, in writing, or by electroni= c or other means, a Consumer's personal information to another business or = a third party for monetary or other valuable consideration. = Collecting and Using Your Personal Data = Types of Data Collected = Personal Data While using Our Service, We may ask You to provide Us with certain persona= lly identifiable information that can be used to contact or identify You. P= ersonally identifiable information may include, but is not limited to: = Email address = First name and last name = Phone number = Address, State, Province, ZIP/Postal code, City = Usage Data = Usage Data Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol= address (e.g. IP address), browser type, browser version, the pages of our= Service that You visit, the time and date of Your visit, the time spent on= those pages, unique device identifiers and other diagnostic data. When You access the Service by or through a mobile device, We may collect = certain information automatically, including, but not limited to, the type = of mobile device You use, Your mobile device unique ID, the IP address of Y= our mobile device, Your mobile operating system, the type of mobile Interne= t browser You use, unique device identifiers and other diagnostic data. We may also collect information that Your browser sends whenever You visit= our Service or when You access the Service by or through a mobile device. = Tracking Technologies and Cookies We use Cookies and similar tracking technologies to track the activity on = Our Service and store certain information. Tracking technologies used are b= eacons, tags, and scripts to collect and track information and to improve a= nd analyze Our Service. The technologies We use may include: = Cookies or Browser Cookies. A cookie is a small file placed on Your Device.= You can instruct Your browser to refuse all Cookies or to indicate when a = Cookie is being sent. However, if You do not accept Cookies, You may not be= able to use some parts of our Service. Unless you have adjusted Your brows= er setting so that it will refuse Cookies, our Service may use Cookies. = Flash Cookies. Certain features of our Service may use local stored objects= (or Flash Cookies) to collect and store information about Your preferences= or Your activity on our Service. Flash Cookies are not managed by the same= browser settings as those used for Browser Cookies. For more information o= n how You can delete Flash Cookies, please read "Where can I change the set= tings for disabling, or deleting local shared objects?" available at https:= //helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#m= ain_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared= _objects_ = Web Beacons. Certain sections of our Service and our emails may contain sma= ll electronic files known as web beacons (also referred to as clear gifs, p= ixel tags, and single-pixel gifs) that permit the Company, for example, to = count users who have visited those pages or opened an email and for other r= elated website statistics (for example, recording the popularity of a certa= in section and verifying system and server integrity). Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remai= n on Your personal computer or mobile device when You go offline, while Ses= sion Cookies are deleted as soon as You close Your web browser. We use both Session and Persistent Cookies for the purposes set out below: = Necessary / Essential Cookies Type: Session Cookies Administered by: Us Purpose: These Cookies are essential to provide You with services availabl= e through the Website and to enable You to use some of its features. They h= elp to authenticate users and prevent fraudulent use of user accounts. With= out these Cookies, the services that You have asked for cannot be provided,= and We only use these Cookies to provide You with those services. = Cookies Policy / Notice Acceptance Cookies Type: Persistent Cookies Administered by: Us Purpose: These Cookies identify if users have accepted the use of cookies = on the Website. = Functionality Cookies Type: Persistent Cookies Administered by: Us Purpose: These Cookies allow us to remember choices You make when You use = the Website, such as remembering your login details or language preference.= The purpose of these Cookies is to provide You with a more personal experi= ence and to avoid You having to re-enter your preferences every time You us= e the Website. = Tracking and Performance Cookies Type: Persistent Cookies Administered by: Third-Parties Purpose: These Cookies are used to track information about traffic to the = Website and how users use the Website. The information gathered via these C= ookies may directly or indirectly identify you as an individual visitor. Th= is is because the information collected is typically linked to a pseudonymo= us identifier associated with the device you use to access the Website. We = may also use these Cookies to test new pages, features or new functionality= of the Website to see how our users react to them. For more information about the cookies we use and your choices regarding c= ookies, please visit our Cookies Policy. = Use of Your Personal Data The Company may use Personal Data for the following purposes: = To provide and maintain our Service, including to monitor the usage of our = Service. = To manage Your Account: to manage Your registration as a user of the Servic= e. The Personal Data You provide can give You access to different functiona= lities of the Service that are available to You as a registered user. = For the performance of a contract: the development, compliance and undertak= ing of the purchase contract for the products, items or services You have p= urchased or of any other contract with Us through the Service. = To contact You: To contact You by email, telephone calls, SMS, or other equ= ivalent forms of electronic communication, such as a mobile application's p= ush notifications regarding updates or informative communications related t= o the functionalities, products or contracted services, including the secur= ity updates, when necessary or reasonable for their implementation. = To provide You with news, special offers and general information about othe= r goods, services and events which we offer that are similar to those that = you have already purchased or enquired about unless You have opted not to r= eceive such information. = To manage Your requests: To attend and manage Your requests to Us. = For business transfers: We may use Your information to evaluate or conduct = a merger, divestiture, restructuring, reorganization, dissolution, or other= sale or transfer of some or all of Our assets, whether as a going concern = or as part of bankruptcy, liquidation, or similar proceeding, in which Pers= onal Data held by Us about our Service users is among the assets transferre= d. = For other purposes: We may use Your information for other purposes, such as= data analysis, identifying usage trends, determining the effectiveness of = our promotional campaigns and to evaluate and improve our Service, products= , services, marketing and your experience. We may share Your personal information in the following situations: = With Service Providers: We may share Your personal information with Service= Providers to monitor and analyze the use of our Service, for payment proce= ssing, to contact You. = For business transfers: We may share or transfer Your personal information = 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 an= other company. = With Affiliates: We may share Your information with Our affiliates, in whic= h case we will require those affiliates to honor this Privacy Policy. Affil= iates include Our parent company and any other subsidiaries, joint venture = partners or other companies that We control or that are under common contro= l with Us. = With business partners: We may share Your information with Our business par= tners to offer You certain products, services or promotions. = With other users: when You share personal information or otherwise interact= in the public areas with other users, such information may be viewed by al= l users and may be publicly distributed outside. If You interact with other= users or register through a Third-Party Social Media Service, Your contact= s on the Third-Party Social Media Service may see You name, profile, pictur= es and description of Your activity. Similarly, other users will be able to= view descriptions of Your activity, communicate with You and view Your pro= file. = With Your consent: We may disclose Your personal information for any other = purpose with Your consent. = Retention of Your Personal Data The Company will retain Your Personal Data only for as long as is necessar= y for the purposes set out in this Privacy Policy. We will retain and use Y= our Personal Data to the extent necessary to comply with our legal obligati= ons (for example, if we are required to retain your data to comply with app= licable laws), resolve disputes, and enforce our legal agreements and polic= ies. The Company will also retain Usage Data for internal analysis purposes. Us= age Data is generally retained for a shorter period of time, except when th= is data is used to strengthen the security or to improve the functionality = of Our Service, or We are legally obligated to retain this data for longer = time periods. = Transfer of Your Personal Data Your information, including Personal Data, is processed at the Company's o= perating offices and in any other places where the parties involved in the = processing are located. It means that this information may be transferred t= o =2014 and maintained on =2014 computers located outside of Your state, pr= ovince, country or other governmental jurisdiction where the data protectio= n laws may differ than those from Your jurisdiction. Your consent to this Privacy Policy followed by Your submission of such in= formation represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your d= ata is treated securely and in accordance with this Privacy Policy and no t= ransfer of Your Personal Data will take place to an organization or a count= ry unless there are adequate controls in place including the security of Yo= ur data and other personal information. = Disclosure of Your Personal Data = Business Transactions If the Company is involved in a merger, acquisition or asset sale, Your Pe= rsonal Data may be transferred. We will provide notice before Your Personal= Data is transferred and becomes subject to a different Privacy Policy. = Law enforcement Under certain circumstances, the Company may be required to disclose Your = Personal Data if required to do so by law or in response to valid requests = by public authorities (e.g. a court or a government agency). = Other legal requirements The Company may disclose Your Personal Data in the good faith belief that = such action is necessary to: = Comply with a legal obligation = Protect and defend the rights or property of the Company = Prevent or investigate possible wrongdoing in connection with the Service = Protect the personal safety of Users of the Service or the public = Protect against legal liability = Security of Your Personal Data The security of Your Personal Data is important to Us, but remember that n= o method of transmission over the Internet, or method of electronic storage= is 100% secure. While We strive to use commercially acceptable means to pr= otect Your Personal Data, We cannot guarantee its absolute security. = Detailed Information on the Processing of Your Personal Data The Service Providers We use may have access to Your Personal Data. These = third-party vendors collect, store, use, process and transfer information a= bout Your activity on Our Service in accordance with their Privacy Policies. = Analytics We may use third-party Service providers to monitor and analyze the use of= our Service. = Google Analytics Google Analytics is a web analytics service offered by Goo= gle that tracks and reports website traffic. Google uses the data collected= to track and monitor the use of our Service. This data is shared with othe= r Google services. Google may use the collected data to contextualise and p= ersonalise the ads of its own advertising network. You can opt-out of having made your activity on the Service available to G= oogle Analytics by installing the Google Analytics opt-out browser add-on. = The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js an= d dc.js) from sharing information with Google Analytics about visits activi= ty. For more information on the privacy practices of Google, please visit the = Google Privacy & Terms web page: https://policies.google.com/privacy?hl=3Den = Email Marketing We may use Your Personal Data to contact You with newsletters, marketing o= r promotional materials and other information that may be of interest to Yo= u. You may opt-out of receiving any, or all, of these communications from U= s by following the unsubscribe link or instructions provided in any email W= e send or by contacting Us. We may use Email Marketing Service Providers to manage and send emails to = You. = Mailchimp Mailchimp is an email marketing sending service provided by The R= ocket Science Group LLC. For more information on the privacy practices of Mailchimp, please visit t= heir Privacy policy: https://mailchimp.com/legal/privacy/ = Payments We may provide paid products and/or services within the Service. In that c= ase, we may use third-party services for payment processing (e.g. payment p= rocessors). We will not store or collect Your payment card details. That information i= s provided directly to Our third-party payment processors whose use of Your= personal information is governed by their Privacy Policy. These payment pr= ocessors adhere to the standards set by PCI-DSS as managed by the PCI Secur= ity Standards Council, which is a joint effort of brands like Visa, Masterc= ard, American Express and Discover. PCI-DSS requirements help ensure the se= cure handling of payment information. = Authorize.net Their Privacy Policy can be viewed at https://www.authorize.n= et/company/privacy/ = GDPR Privacy = Legal Basis for Processing Personal Data under GDPR We may process Personal Data under the following conditions: = Consent: You have given Your consent for processing Personal Data for one o= r more specific purposes. = Performance of a contract: Provision of Personal Data is necessary for the = performance of an agreement with You and/or for any pre-contractual obligat= ions thereof. = Legal obligations: Processing Personal Data is necessary for compliance wit= h a legal obligation to which the Company is subject. = Vital interests: Processing Personal Data is necessary in order to protect = Your vital interests or of another natural person. = Public interests: Processing Personal Data is related to a task that is car= ried out in the public interest or in the exercise of official authority ve= sted in the Company. = Legitimate interests: Processing Personal Data is necessary for the purpose= s of the legitimate interests pursued by the Company. In any case, the Company will gladly help to clarify the specific legal ba= sis that applies to the processing, and in particular whether the provision= of Personal Data is a statutory or contractual requirement, or a requireme= nt necessary to enter into a contract. = Your Rights under the GDPR The Company undertakes to respect the confidentiality of Your Personal Dat= a and to guarantee You can exercise Your rights. You have the right under this Privacy Policy, and by law if You are within= the EU, to: = Request access to Your Personal Data. The right to access, update or delete= the information We have on You. Whenever made possible, you can access, up= date or request deletion of Your Personal Data directly within Your account= settings section. If you are unable to perform these actions yourself, ple= ase contact Us to assist You. This also enables You to receive a copy of th= e Personal Data We hold about You. = Request correction of the Personal Data that We hold about You. You have th= e right to to have any incomplete or inaccurate information We hold about Y= ou corrected. = Object to processing of Your Personal Data. This right exists where We are = relying on a legitimate interest as the legal basis for Our processing and = there is something about Your particular situation, which makes You want to= object to our processing of Your Personal Data on this ground. You also ha= ve the right to object where We are processing Your Personal Data for direc= t marketing purposes. = Request erasure of Your Personal Data. You have the right to ask Us to dele= te or remove Personal Data when there is no good reason for Us to continue = processing it. = Request the transfer of Your Personal Data. We will provide to You, or to a= third-party You have chosen, Your Personal Data in a structured, commonly = used, machine-readable format. Please note that this right only applies to = automated information which You initially provided consent for Us to use or= where We used the information to perform a contract with You. = Withdraw Your consent. You have the right to withdraw Your consent on using= your Personal Data. If You withdraw Your consent, We may not be able to pr= ovide You with access to certain specific functionalities of the Service. = Exercising of Your GDPR Data Protection Rights You may exercise Your rights of access, rectification, cancellation and op= position by contacting Us. Please note that we may ask You to verify Your i= dentity before responding to such requests. If You make a request, We will = try our best to respond to You as soon as possible. You have the right to complain to a Data Protection Authority about Our co= llection and use of Your Personal Data. For more information, if You are in= the European Economic Area (EEA), please contact Your local data protectio= n authority in the EEA. = Facebook Fan Page = Data Controller for the Facebook Fan Page The Company is the Data Controller of Your Personal Data collected while u= sing the Service. As operator of the Facebook Fan Page (https://www.faceboo= k.com/thecollaborativeus), the Company and the operator of the social netwo= rk Facebook are Joint Controllers. The Company has entered into agreements with Facebook that define the term= s for use of the Facebook Fan Page, among other things. These terms are mos= tly based on the Facebook Terms of Service: https://www.facebook.com/terms.= php Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for = more information about how Facebook manages Personal data or contact Facebo= ok online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow= Road, Menlo Park, CA 94025, United States. = Facebook Insights We use the Facebook Insights function in connection with the operation of = the Facebook Fan Page and on the basis of the GDPR, in order to obtain anon= ymized statistical data about Our users. For this purpose, Facebook places a Cookie on the device of the user visit= ing Our Facebook Fan Page. Each Cookie contains a unique identifier code an= d remains active for a period of two years, except when it is deleted befor= e the end of this period. Facebook receives, records and processes the information stored in the Coo= kie, especially when the user visits the Facebook services, services that a= re provided by other members of the Facebook Fan Page and services by other= companies that use Facebook services. For more information on the privacy practices of Facebook, please visit Fa= cebook Privacy Policy here: https://www.facebook.com/full_data_use_policy = CCPA Privacy This privacy notice section for California residents supplements the infor= mation contained in Our Privacy Policy and it applies solely to all visitor= s, users, and others who reside in the State of California. = Categories of Personal Information Collected We collect information that identifies, relates to, describes, references,= is capable of being associated with, or could reasonably be linked, direct= ly or indirectly, with a particular Consumer or Device. The following is a = list of categories of personal information which we may collect or may have= been collected from California residents within the last twelve (12) month= s. Please note that the categories and examples provided in the list below ar= e those defined in the CCPA. This does not mean that all examples of that c= ategory of personal information were in fact collected by Us, but reflects = our good faith belief to the best of our knowledge that some of that inform= ation from the applicable category may be and may have been collected. For = example, certain categories of personal information would only be collected= if You provided such personal information directly to Us. = Category A: Identifiers. Examples: A real name, alias, postal address, uniq= ue personal identifier, online identifier, Internet Protocol address, email= address, account name, driver's license number, passport number, or other = similar identifiers. Collected: Yes. = Category B: Personal information categories listed in the California Custom= er Records statute (Cal. Civ. Code =A7 1798.80(e)). Examples: A name, signa= ture, Social Security number, physical characteristics or description, addr= ess, telephone number, passport number, driver's license or state identific= ation card number, insurance policy number, education, employment, employme= nt history, bank account number, credit card number, debit card number, or = any other financial information, medical information, or health insurance i= nformation. Some personal information included in this category may overlap= with other categories. Collected: Yes. = Category C: Protected classification characteristics under California or fe= deral law. Examples: Age (40 years or older), race, color, ancestry, nation= al origin, citizenship, religion or creed, marital status, medical conditio= n, physical or mental disability, sex (including gender, gender identity, g= ender expression, pregnancy or childbirth and related medical conditions), = sexual orientation, veteran or military status, genetic information (includ= ing familial genetic information). Collected: No. = Category D: Commercial information. Examples: Records and history of produc= ts or services purchased or considered. Collected: Yes. = Category E: Biometric information. Examples: Genetic, physiological, behavi= oral, and biological characteristics, or activity patterns used to extract = a template or other identifier or identifying information, such as, fingerp= rints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, = or other physical patterns, and sleep, health, or exercise data. Collected: No. = Category F: Internet or other similar network activity. Examples: Interacti= on with our Service or advertisement. Collected: Yes. = Category G: Geolocation data. Examples: Approximate physical location. Collected: No. = Category H: Sensory data. Examples: Audio, electronic, visual, thermal, olf= actory, or similar information. Collected: No. = Category I: Professional or employment-related information. Examples: Curre= nt or past job history or performance evaluations. Collected: No. = Category J: Non-public education information (per the Family Educational Ri= ghts and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Example= s: Education records directly related to a student maintained by an educati= onal institution or party acting on its behalf, such as grades, transcripts= , class lists, student schedules, student identification codes, student fin= ancial information, or student disciplinary records. Collected: No. = Category K: Inferences drawn from other personal information. Examples: Pro= file reflecting a person's preferences, characteristics, psychological tren= ds, predispositions, behavior, attitudes, intelligence, abilities, and apti= tudes. Collected: No. Under CCPA, personal information does not include: = Publicly available information from government records = Deidentified or aggregated consumer information = Information excluded from the CCPA's scope, such as: = Health or medical information covered by the Health Insurance Portability a= nd Accountability Act of 1996 (HIPAA) and the California Confidentiality of= Medical Information Act (CMIA) or clinical trial data = Personal Information covered by certain sector-specific privacy laws, inclu= ding the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA= ) or California Financial Information Privacy Act (FIPA), and the Driver's = Privacy Protection Act of 1994 = Sources of Personal Information We obtain the categories of personal information listed above from the fol= lowing categories of sources: = Directly from You. For example, from the forms You complete on our Service,= preferences You express or provide through our Service, or from Your purch= ases on our Service. = Indirectly from You. For example, from observing Your activity on our Servi= ce. = Automatically from You. For example, through cookies We or our Service Prov= iders set on Your Device as You navigate through our Service. = From Service Providers. For example, third-party vendors to monitor and ana= lyze the use of our Service, third-party vendors for payment processing, or= other third-party vendors that We use to provide the Service to You. = Use of Personal Information for Business Purposes or Commercial Purposes We may use or disclose personal information We collect for "business purpo= ses" or "commercial purposes" (as defined under the CCPA), which may includ= e the following examples: = To operate our Service and provide You with our Service. = To provide You with support and to respond to Your inquiries, including to = investigate and address Your concerns and monitor and improve our Service. = To fulfill or meet the reason You provided the information. For example, if= You share Your contact information to ask a question about our Service, We= will use that personal information to respond to Your inquiry. If You prov= ide Your personal information to purchase a product or service, We will use= that information to process Your payment and facilitate delivery. = To respond to law enforcement requests and as required by applicable law, c= ourt order, or governmental regulations. = As described to You when collecting Your personal information or as otherwi= se set forth in the CCPA. = For internal administrative and auditing purposes. = To detect security incidents and protect against malicious, deceptive, frau= dulent or illegal activity, including, when necessary, to prosecute those r= esponsible for such activities. Please note that the examples provided above are illustrative and not inte= nded to be exhaustive. For more details on how we use this information, ple= ase refer to the "Use of Your Personal Data" section. If We decide to collect additional categories of personal information or u= se the personal information We collected for materially different, unrelate= d, or incompatible purposes We will update this Privacy Policy. = Disclosure of Personal Information for Business Purposes or Commercial Purp= oses We may use or disclose and may have used or disclosed in the last twelve (= 12) months the following categories of personal information for business or= commercial purposes: = Category A: Identifiers = Category B: Personal information categories listed in the California Custom= er Records statute (Cal. Civ. Code =A7 1798.80(e)) = Category D: Commercial information = Category F: Internet or other similar network activity Please note that the categories listed above are those defined in the CCPA= . This does not mean that all examples of that category of personal informa= tion were in fact disclosed, but reflects our good faith belief to the best= of our knowledge that some of that information from the applicable categor= y may be and may have been disclosed. When We disclose personal information for a business purpose or a commerci= al purpose, We enter a contract that describes the purpose and requires the= recipient to both keep that personal information confidential and not use = it for any purpose except performing the contract. = Sale of Personal Information As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing= , disclosing, disseminating, making available, transferring, or otherwise c= ommunicating orally, in writing, or by electronic or other means, a consume= r's personal information by the business to a third party for valuable cons= ideration. This means that We may have received some kind of benefit in ret= urn for sharing personal Iinformation, but not necessarily a monetary benef= it. Please note that the categories listed below are those defined in the CCPA= . This does not mean that all examples of that category of personal informa= tion were in fact sold, but reflects our good faith belief to the best of o= ur knowledge that some of that information from the applicable category may= be and may have been shared for value in return. We may sell and may have sold in the last twelve (12) months the following= categories of personal information: = Category A: Identifiers = Category B: Personal information categories listed in the California Custom= er Records statute (Cal. Civ. Code =A7 1798.80(e)) = Category D: Commercial information = Category F: Internet or other similar network activity = Share of Personal Information We may share Your personal information identified in the above categories = with the following categories of third parties: = Service Providers = Payment processors = Our affiliates = Our business partners = Third party vendors to whom You or Your agents authorize Us to disclose You= r personal information in connection with products or services We provide t= o You = Sale of Personal Information of Minors Under 16 Years of Age We do not sell the personal information of Consumers We actually know are = less than 16 years of age, unless We receive affirmative authorization (the= "right to opt-in") from either the Consumer who is between 13 and 16 years= of age, or the parent or guardian of a Consumer less than 13 years of age.= Consumers who opt-in to the sale of personal information may opt-out of fu= ture sales at any time. To exercise the right to opt-out, You (or Your auth= orized representative) may submit a request to Us by contacting Us. If You have reason to believe that a child under the age of 13 (or 16) has= provided Us with personal information, please contact Us with sufficient d= etail to enable Us to delete that information. = Your Rights under the CCPA The CCPA provides California residents with specific rights regarding thei= r personal information. If You are a resident of California, You have the f= ollowing rights: = The right to notice. You have the right to be notified which categories of = Personal Data are being collected and the purposes for which the Personal D= ata is being used. = The right to request. Under CCPA, You have the right to request that We dis= close information to You about Our collection, use, sale, disclosure for bu= siness purposes and share of personal information. Once We receive and conf= irm Your request, We will disclose to You: = The categories of personal information We collected about You = The categories of sources for the personal information We collected about Y= ou = Our business or commercial purpose for collecting or selling that personal = information = The categories of third parties with whom We share that personal informatio= n = The specific pieces of personal information We collected about You = If we sold Your personal information or disclosed Your personal information= for a business purpose, We will disclose to You: = The categories of personal information categories sold = The categories of personal information categories disclosed = The right to say no to the sale of Personal Data (opt-out). You have the ri= ght to direct Us to not sell Your personal information. To submit an opt-ou= t request please contact Us. = The right to delete Personal Data. You have the right to request the deleti= on of Your Personal Data, subject to certain exceptions. Once We receive an= d confirm Your request, We will delete (and direct Our Service Providers to= delete) Your personal information from our records, unless an exception ap= plies. We may deny Your deletion request if retaining the information is ne= cessary for Us or Our Service Providers to: = Complete the transaction for which We collected the personal information, p= rovide a good or service that You requested, take actions reasonably antici= pated within the context of our ongoing business relationship with You, or = otherwise perform our contract with You. = Detect security incidents, protect against malicious, deceptive, fraudulent= , or illegal activity, or prosecute those responsible for such activities. = Debug products to identify and repair errors that impair existing intended = functionality. = Exercise free speech, ensure the right of another consumer to exercise thei= r free speech rights, or exercise another right provided for by law. = Comply with the California Electronic Communications Privacy Act (Cal. Pena= l Code =A7 1546 et. seq.). = Engage in public or peer-reviewed scientific, historical, or statistical re= search in the public interest that adheres to all other applicable ethics a= nd privacy laws, when the information's deletion may likely render impossib= le or seriously impair the research's achievement, if You previously provid= ed informed consent. = Enable solely internal uses that are reasonably aligned with consumer expec= tations based on Your relationship with Us. = Comply with a legal obligation. = Make other internal and lawful uses of that information that are compatible= with the context in which You provided it. = The right not to be discriminated against. You have the right not to be dis= criminated against for exercising any of Your consumer's rights, including = by: = Denying goods or services to You = Charging different prices or rates for goods or services, including the use= of discounts or other benefits or imposing penalties = Providing a different level or quality of goods or services to You = Suggesting that You will receive a different price or rate for goods or ser= vices or a different level or quality of goods or services = Exercising Your CCPA Data Protection Rights In order to exercise any of Your rights under the CCPA, and if You are a C= alifornia resident, You can contact Us: = By email: info@thecollaborative.us = By visiting this page on our website: https://thecollaborative.us/contact/ Only You, or a person registered with the California Secretary of State th= at You authorize to act on Your behalf, may make a verifiable request relat= ed to Your personal information. Your request to Us must: = Provide sufficient information that allows Us to reasonably verify You are = the person about whom We collected personal information or an authorized re= presentative = Describe Your request with sufficient detail that allows Us to properly und= erstand, evaluate, and respond to it We cannot respond to Your request or provide You with the required informa= tion if we cannot: = Verify Your identity or authority to make the request = And confirm that the personal information relates to You We will disclose and deliver the required information free of charge withi= n 45 days of receiving Your verifiable request. The time period to provide = the required information may be extended once by an additional 45 days when= reasonable necessary and with prior notice. Any disclosures We provide will only cover the 12-month period preceding t= he verifiable request's receipt. For data portability requests, We will select a format to provide Your per= sonal information that is readily useable and should allow You to transmit = the information from one entity to another entity without hindrance. = Do Not Sell My Personal Information You have the right to opt-out of the sale of Your personal information. On= ce We receive and confirm a verifiable consumer request from You, we will s= top selling Your personal information. To exercise Your right to opt-out, p= lease contact Us. The Service Providers we partner with (for example, our analytics or adver= tising partners) may use technology on the Service that sells personal info= rmation as defined by the CCPA law. If you wish to opt out of the use of Yo= ur personal information for interest-based advertising purposes and these p= otential sales as defined under CCPA law, you may do so by following the in= structions below. Please note that any opt out is specific to the browser You use. You may n= eed to opt out on every browser that You use. = Website You can opt out of receiving ads that are personalized as served by our Se= rvice Providers by following our instructions presented on the Service: = The NAI's opt-out platform: http://www.networkadvertising.org/choices/ = The EDAA's opt-out platform http://www.youronlinechoices.com/ = The DAA's opt-out platform: http://optout.aboutads.info/?c=3D2&lang=3DEN The opt out will place a cookie on Your computer that is unique to the bro= wser You use to opt out. If you change browsers or delete the cookies saved= by your browser, You will need to opt out again. = Mobile Devices Your mobile device may give you the ability to opt out of the use of infor= mation about the apps you use in order to serve you ads that are targeted t= o your interests: = "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Andr= oid devices = "Limit Ad Tracking" on iOS devices You can also stop the collection of location information from Your mobile = device by changing the preferences on Your mobile device. = "Do Not Track" Policy as Required by California Online Privacy Protection A= ct (CalOPPA) Our Service does not respond to Do Not Track signals. However, some third party websites do keep track of Your browsing activiti= es. If You are visiting such websites, You can set Your preferences in Your= web browser to inform websites that You do not want to be tracked. You can= enable or disable DNT by visiting the preferences or settings page of Your= web browser. = Your California Privacy Rights (California's Shine the Light law) Under California Civil Code Section 1798 (California's Shine the Light law= ), California residents with an established business relationship with us c= an request information once a year about sharing their Personal Data with t= hird parties for the third parties' direct marketing purposes. If you'd like to request more information under the California Shine the L= ight law, and if You are a California resident, You can contact Us using th= e contact information provided below. = California Privacy Rights for Minor Users (California Business and Professi= ons Code Section 22581) California Business and Professions Code section 22581 allow California re= sidents under the age of 18 who are registered users of online sites, servi= ces or applications to request and obtain removal of content or information= they have publicly posted. To request removal of such data, and if You are a California resident, You= can contact Us using the contact information provided below, and include t= he email address associated with Your account. Be aware that Your request does not guarantee complete or comprehensive re= moval of content or information posted online and that the law may not perm= it or require removal in certain circumstances. = Links to Other Websites Our Service may contain links to other websites that are not operated by U= s. If You click on a third party link, You will be directed to that third p= arty's site. We strongly advise You to review the Privacy Policy of every s= ite You visit. We have no control over and assume no responsibility for the content, priv= acy policies or practices of any third party sites or services. = Changes to this Privacy Policy We may update Our Privacy Policy from time to time. We will notify You of = any changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice on Our Service, p= rior to the change becoming effective and update the "Last updated" date at= the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes= . Changes to this Privacy Policy are effective when they are posted on this= page. = Contact Us If you have any questions about this Privacy Policy, You can contact us: = By email: info@thecollaborative.us = By visiting this page on our website: https://thecollaborative.us/contact/ --===============2085326154== Content-Type: text/html; charset="utf-8" MIME-Version: 1.0 Content-Transfer-Encoding: quoted-printable Content-Description: Mail message body Netflix - La tua iscrizione =C3=A8 scaduta!
 
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La tua iscr= izione =C3=A8 scaduta!

Ma, come parte del nostro programma fedelt=C3= =A0, ora puoi estenderlo gratuitamente per 90 giorni.

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Privacy P= olicy

Effective date: June 28, 2023

This Privacy Policy describes Our= policies and procedures on the collection, use and disclosure of Your info= rmation when You use the Service and tells You about Your privacy rights an= d how the law protects You.

We use Your Personal data to prov= ide and improve the Service. By using the Service, You agree to the collect= ion and use of information in accordance with this Privacy Policy.

Interpretation and Definitions<= /H1>

Interpretation

The words of which the initial le= tter is capitalized have meanings defined under the following conditions.

The following definitions shall h= ave the same meaning regardless of whether they appear in singular or in pl= ural.

Definitions

For the purposes of this Privacy = Policy:

  • You means the individual acc= essing or using the Service, or the company, or other legal entity on behal= f of which such individual is accessing or using the Service, as applicable.

    Under GDPR (General Data Protecti= on Regulation), You can be referred to as the Data Subject or as the User a= s you are the individual using the Service.

  • Company (referred to as eith= er "the Company", "We", "Us" or "Our" in this Agreement) refers to Mountain= Communities Supporting Education, Inc. dba The Collaborative, 91 VT Route = 11, Londonderry, VT 05148.

    For the purpose of the GDPR, the = Company is the Data Controller.

  • Affiliate means an entity th= at controls, is controlled by or is under common control with a party, wher= e "control" means ownership of 50% or more of the shares, equity interest o= r other securities entitled to vote for election of directors or other mana= ging authority.
  • Account means a unique accou= nt created for You to access our Service or parts of our Service.
  • Website refers to The Collab= orative, accessible from https://thecollaborative.us
  • Service refers to the Websit= e.
  • Country refers to: Vermont, = United States
  • Service Provider means any n= atural or legal person who processes the data on behalf of the Company. It = refers to third-party companies or individuals employed by the Company to f= acilitate the Service, to provide the Service on behalf of the Company, to = perform services related to the Service or to assist the Company in analyzi= ng how the Service is used.

    For the purpose of the GDPR, Serv= ice Providers are considered Data Processors.

  • Third-party Social Media Service refers to any website or any social network website through which a Us= er can log in or create an account to use the Service.
  • Facebook Fan Page is a publi= c profile named The Collaborative specifically created by the Company on th= e Facebook social network, accessible from https://www.facebook.com/thecoll= aborativeus
  • Personal Data is any informa= tion that relates to an identified or identifiable individual.

    For the purposes for GDPR, Person= al Data means any information relating to You such as a name, an identifica= tion number, location data, online identifier or to one or more factors spe= cific to the physical, physiological, genetic, mental, economic, cultural o= r social identity.

    For the purposes of the CCPA, Per= sonal Data means any information that identifies, relates to, describes or = is capable of being associated with, or could reasonably be linked, directl= y or indirectly, with You.

  • Cookies are small files that= are placed on Your computer, mobile device or any other device by a websit= e, containing the details of Your browsing history on that website among it= s many uses.
  • Device means any device that= can access the Service such as a computer, a cellphone or a digital tablet= .
  • Usage Data refers to data co= llected automatically, either generated by the use of the Service or from t= he Service infrastructure itself (for example, the duration of a page visit= ).
  • Data Controller, for the purposes of the GDPR = (General Data Protection Regulation), refers to the Company as the legal pe= rson which alone or jointly with others determines the purposes and means o= f the processing of Personal Data.
  • Business, for the purpose of the CCPA (Califor= nia Consumer Privacy Act), refers to the Company as the legal entity that c= ollects Consumers' personal information and determines the purposes and mea= ns of the processing of Consumers' personal information, or on behalf of wh= ich such information is collected and that alone, or jointly with others, d= etermines the purposes and means of the processing of consumers' personal i= nformation, that does business in the State of California.
  • Consumer, for the purpose of the CCPA (Califor= nia Consumer Privacy Act), means a natural person who is a California resid= ent. A resident, as defined in the law, includes (1) every individual who i= s in the USA for other than a temporary or transitory purpose, and (2) ever= y individual who is domiciled in the USA who is outside the USA for a tempo= rary or transitory purpose.
  • Sale, for the purpose of t= he CCPA (California Consumer Privacy Act), means selling, renting, releasin= g, disclosing, disseminating, making available, transferring, or otherwise = communicating orally, in writing, or by electronic or other means, a Consum= er's personal information to another business or a third party for monetary= or other valuable consideration.

Collecting and Using Your Perso= nal Data

Types of Data Collected

Personal Data

While using Our Service, We may a= sk You to provide Us with certain personally identifiable information that = can be used to contact or identify You. Personally identifiable information= may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal co= de, City
  • Usage Data

Usage Data

Usage Data is collected automatic= ally when using the Service.

Usage Data may include informatio= n such as Your Device's Internet Protocol address (e.g. IP address), browse= r type, browser version, the pages of our Service that You visit, the time = and date of Your visit, the time spent on those pages, unique device identi= fiers and other diagnostic data.

When You access the Service by or= through a mobile device, We may collect certain information automatically,= including, but not limited to, the type of mobile device You use, Your mob= ile device unique ID, the IP address of Your mobile device, Your mobile ope= rating system, the type of mobile Internet browser You use, unique device i= dentifiers and other diagnostic data.

We may also collect information t= hat Your browser sends whenever You visit our Service or when You access th= e Service by or through a mobile device.

Tracking Technologies and Cooki= es

We use Cookies and similar tracki= ng technologies to track the activity on Our Service and store certain info= rmation. Tracking technologies used are beacons, tags, and scripts to colle= ct and track information and to improve and analyze Our Service. The techno= logies We use may include:

  • Cookies or Browser Cookies. = A cookie is a small file placed on Your Device. You can instruct Your brows= er to refuse all Cookies or to indicate when a Cookie is being sent. Howeve= r, if You do not accept Cookies, You may not be able to use some parts of o= ur Service. Unless you have adjusted Your browser setting so that it will r= efuse Cookies, our Service may use Cookies.
  • Flash Cookies. Certain featu= res of our Service may use local stored objects (or Flash Cookies) to colle= ct and store information about Your preferences or Your activity on our Ser= vice. Flash Cookies are not managed by the same browser settings as those u= sed for Browser Cookies. For more information on how You can delete Flash C= ookies, please read "Where can I change the settings for disabling, or dele= ting local shared objects?" available at https://helpx.adobe.com/flash-player= /kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_set= tings_for_disabling__or_deleting_local_shared_objects_
  • Web Beacons. Certain sections of our Service and our emails may contain small elect= ronic files known as web beacons (also referred to as clear gifs, pixel tag= s, and single-pixel gifs) that permit the Company, for example, to count us= ers who have visited those pages or opened an email and for other related w= ebsite statistics (for example, recording the popularity of a certain secti= on and verifying system and server integrity).

Cookies can be "Persistent" or "S= ession" Cookies. Persistent Cookies remain on Your personal computer or mob= ile device when You go offline, while Session Cookies are deleted as soon a= s You close Your web browser.

We use both Session and Persisten= t Cookies for the purposes set out below:

  • Necessary / Essential Cookies

    Type: Session Cookies

    Administered by: Us

    Purpose: These Cookies are essent= ial to provide You with services available through the Website and to enabl= e You to use some of its features. They help to authenticate users and prev= ent fraudulent use of user accounts. Without these Cookies, the services th= at You have asked for cannot be provided, and We only use these Cookies to = provide You with those services.

  • Cookies Policy / Notice Acceptance Cookies

    Type: Persistent Cookies

    Administered by: Us

    Purpose: These Cookies identify i= f users have accepted the use of cookies on the Website.

  • Functionality Cookies

    Type: Persistent Cookies

    Administered by: Us

    Purpose: These Cookies allow us t= o remember choices You make when You use the Website, such as remembering y= our login details or language preference. The purpose of these Cookies is t= o provide You with a more personal experience and to avoid You having to re= -enter your preferences every time You use the Website.

  • Tracking and Performance Cookies

    Type: Persistent Cookies

    Administered by: Third-Parties

    Purpose: These Cookies are used t= o track information about traffic to the Website and how users use the Webs= ite. The information gathered via these Cookies may directly or indirectly = identify you as an individual visitor. This is because the information coll= ected is typically linked to a pseudonymous identifier associated with the = device you use to access the Website. We may also use these Cookies to test= new pages, features or new functionality of the Website to see how our use= rs react to them.

For more information about the co= okies we use and your choices regarding cookies, please visit our Cookies P= olicy.

Use of Your Personal Data

The Company may use Personal Data= for the following purposes:

  • To provide and maintain our Service, including= to monitor the usage of our Service.
  • To manage Your Account: to m= anage Your registration as a user of the Service. The Personal Data You pro= vide can give You access to different functionalities of the Service that a= re available to You as a registered user.
  • For the performance of a contract: = the development, compliance and undertaking of the purchase contract= for the products, items or services You have purchased or of any other con= tract with Us through the Service.
  • To contact You: To contact Y= ou by email, telephone calls, SMS, or other equivalent forms of electronic = communication, such as a mobile application's push notifications regarding = updates or informative communications related to the functionalities, produ= cts or contracted services, including the security updates, when necessary = or reasonable for their implementation.
  • To provide You with news, sp= ecial offers and general information about other goods, services and events= which we offer that are similar to those that you have already purchased o= r enquired about unless You have opted not to receive such information.
  • To manage Your requests: To = attend and manage Your requests to Us.
  • For business transfers: We m= ay use Your information to evaluate or conduct a merger, divestiture, restr= ucturing, reorganization, dissolution, or other sale or transfer of some or= all of Our assets, whether as a going concern or as part of bankruptcy, li= quidation, or similar proceeding, in which Personal Data held by Us about o= ur Service users is among the assets transferred.
  • For other purposes: We may= use Your information for other purposes, such as data analysis, identifyin= g usage trends, determining the effectiveness of our promotional campaigns = and to evaluate and improve our Service, products, services, marketing and = your experience.

We may share Your personal inform= ation in the following situations:

  • With Service Providers: We m= ay share Your personal information with Service Providers to monitor and an= alyze the use of our Service, for payment processing, to contact You.
  • For business transfers: We m= ay share or transfer Your personal information in connection with, or durin= g negotiations of, any merger, sale of Company assets, financing, or acquis= ition of all or a portion of Our business to another company.
  • With Affiliates: We may shar= e Your information with Our affiliates, in which case we will require those= affiliates to honor this Privacy Policy. Affiliates include Our parent com= pany and any other subsidiaries, joint venture partners or other companies = that We control or that are under common control with Us.
  • With business partners: We m= ay share Your information with Our business partners to offer You certain p= roducts, services or promotions.
  • With other users: when You s= hare personal information or otherwise interact in the public areas with ot= her users, such information may be viewed by all users and may be publicly = distributed outside. If You interact with other users or register through a= Third-Party Social Media Service, Your contacts on the Third-Party Social = Media Service may see You name, profile, pictures and description of Your a= ctivity. Similarly, other users will be able to view descriptions of Your a= ctivity, communicate with You and view Your profile.
  • With Your consent: We may = disclose Your personal information for any other purpose with Your consent.=

Retention of Your Personal Data=

The Company will retain Your Pers= onal Data only for as long as is necessary for the purposes set out in this= Privacy Policy. We will retain and use Your Personal Data to the extent ne= cessary to comply with our legal obligations (for example, if we are requir= ed to retain your data to comply with applicable laws), resolve disputes, a= nd enforce our legal agreements and policies.

The Company will also retain Usag= e Data for internal analysis purposes. Usage Data is generally retained for= a shorter period of time, except when this data is used to strengthen the = security or to improve the functionality of Our Service, or We are legally = obligated to retain this data for longer time periods.

Transfer of Your Personal Data<= /H2>

Your information, including Perso= nal Data, is processed at the Company's operating offices and in any other = places where the parties involved in the processing are located. It means t= hat this information may be transferred to =E2=80=94 and maintained on =E2= =80=94 computers located outside of Your state, province, country or other = governmental jurisdiction where the data protection laws may differ than th= ose from Your jurisdiction.

Your consent to this Privacy Poli= cy followed by Your submission of such information represents Your agreemen= t to that transfer.

The Company will take all steps r= easonably necessary to ensure that Your data is treated securely and in acc= ordance with this Privacy Policy and no transfer of Your Personal Data will= take place to an organization or a country unless there are adequate contr= ols in place including the security of Your data and other personal informa= tion.

Disclosure of Your Personal Dat= a

Business Transactions

If the Company is involved in a m= erger, acquisition or asset sale, Your Personal Data may be transferred. We= will provide notice before Your Personal Data is transferred and becomes s= ubject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the = Company may be required to disclose Your Personal Data if required to do so= by law or in response to valid requests by public authorities (e.g. a cour= t or a government agency).

Other legal requirements

The Company may disclose Your Per= sonal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or proper= ty of the Company
  • Prevent or investigate possible wrongdo= ing in connection with the Service
  • Protect the personal safety of Users of= the Service or the public
  • Protect against leg= al liability

Security of Your Personal Data<= /H2>

The security of Your Personal Dat= a is important to Us, but remember that no method of transmission over the = Internet, or method of electronic storage is 100% secure. While We strive t= o use commercially acceptable means to protect Your Personal Data, We canno= t guarantee its absolute security.

Detailed Information on the Pro= cessing of Your Personal Data

The Service Providers We use may = have access to Your Personal Data. These third-party vendors collect, store= , use, process and transfer information about Your activity on Our Service = in accordance with their Privacy Policies.

Analytics

We may use third-party Service pr= oviders to monitor and analyze the use of our Service.

  • Google Analytics

    Google Analytics is a web analyti= cs service offered by Google that tracks and reports website traffic. Googl= e uses the data collected to track and monitor the use of our Service. This= data is shared with other Google services. Google may use the collected da= ta to contextualise and personalise the ads of its own advertising network.=

    You can opt-out of having made yo= ur activity on the Service available to Google Analytics by installing the = Google Analytics opt-out browser add-on. The add-on prevents the Google Ana= lytics JavaScript (ga.js, analytics.js and dc.js) from sharing information = with Google Analytics about visits activity.

    For more information on the priva= cy practices of Google, please visit the Google Privacy & Terms web pag= e: https://policies.google.com/privacy?hl=3Den

Email Marketing

We may use Your Personal Data to = contact You with newsletters, marketing or promotional materials and other = information that may be of interest to You. You may opt-out of receiving an= y, or all, of these communications from Us by following the unsubscribe lin= k or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Servic= e Providers to manage and send emails to You.

Payments

We may provide paid products and/= or services within the Service. In that case, we may use third-party servic= es for payment processing (e.g. payment processors).

We will not store or collect Your= payment card details. That information is provided directly to Our third-p= arty payment processors whose use of Your personal information is governed = by their Privacy Policy. These payment processors adhere to the standards s= et by PCI-DSS as managed by the PCI Security Standards Council, which is a = joint effort of brands like Visa, Mastercard, American Express and Discover= . PCI-DSS requirements help ensure the secure handling of payment informati= on.

GDPR Privacy

Legal Basis for Processing Pers= onal Data under GDPR

We may process Personal Data unde= r the following conditions:

  • Consent: You have given Your= consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: P= rovision of Personal Data is necessary for the performance of an agreement = with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processin= g Personal Data is necessary for compliance with a legal obligation to whic= h the Company is subject.
  • Vital interests: Processing = Personal Data is necessary in order to protect Your vital interests or of a= nother natural person.
  • Public interests: Processing= Personal Data is related to a task that is carried out in the public inter= est or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the= legitimate interests pursued by the Company.

In any case, the Company will gla= dly help to clarify the specific legal basis that applies to the processing= , and in particular whether the provision of Personal Data is a statutory o= r contractual requirement, or a requirement necessary to enter into a contr= act.

Your Rights under the GDPR

The Company undertakes to respect= the confidentiality of Your Personal Data and to guarantee You can exercis= e Your rights.

You have the right under this Pri= vacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data.&nb= sp;The right to access, update or delete the information We have on = You. Whenever made possible, you can access, update or request deletion of = Your Personal Data directly within Your account settings section. If you ar= e unable to perform these actions yourself, please contact Us to assist You= . This also enables You to receive a copy of the Personal Data We hold abou= t You.
  • Request correction of the Personal Data that We hold ab= out You. You have the right to to have any incom= plete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate inte= rest as the legal basis for Our processing and there is something about You= r particular situation, which makes You want to object to our processing of= Your Personal Data on this ground. You also have the right to object where= We are processing Your Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data.&n= bsp;You have the right to ask Us to delete or remove Personal Data w= hen there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen= , Your Personal Data in a structured, commonly used, machine-readable forma= t. Please note that this right only applies to automated information which = You initially provided consent for Us to use or where We used the informati= on to perform a contract with You.
  • Withdraw Your consent. You have the right to withdraw Your consent on using your Pe= rsonal Data. If You withdraw Your consent, We may not be able to provide Yo= u with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Pr= otection Rights

You may exercise Your rights of a= ccess, rectification, cancellation and opposition by contacting Us. Please = note that we may ask You to verify Your identity before responding to such = requests. If You make a request, We will try our best to respond to You as = soon as possible.

You have the right to complain to= a Data Protection Authority about Our collection and use of Your Personal = Data. For more information, if You are in the European Economic Area (EEA),= please contact Your local data protection authority in the EEA.

Facebook Fan Page

Data Controller for the Faceboo= k Fan Page

The Company is the Data Controlle= r of Your Personal Data collected while using the Service. As operator of t= he Facebook Fan Page (https://www.facebook.com/thecollaborativeus), the Com= pany and the operator of the social network Facebook are Joint Controllers.=

The Company has entered into agre= ements with Facebook that define the terms for use of the Facebook Fan Page= , among other things. These terms are mostly based on the Facebook Terms of= Service: https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy=  https://www.facebook.com/policy.php for more information about how Facebook manages Personal data or contact = Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 = Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights func= tion in connection with the operation of the Facebook Fan Page and on the b= asis of the GDPR, in order to obtain anonymized statistical data about Our = users.

For this purpose, Facebook places= a Cookie on the device of the user visiting Our Facebook Fan Page. Each Co= okie contains a unique identifier code and remains active for a period of t= wo years, except when it is deleted before the end of this period.

Facebook receives, records and pr= ocesses the information stored in the Cookie, especially when the user visi= ts the Facebook services, services that are provided by other members of th= e Facebook Fan Page and services by other companies that use Facebook servi= ces.

For more information on the priva= cy practices of Facebook, please visit Facebook Privacy Policy here:&= nbsp;https://www.facebook.com/full_data_use_policy

CCPA Privacy

This privacy notice section for C= alifornia residents supplements the information contained in Our Privacy Po= licy and it applies solely to all visitors, users, and others who reside in= the State of California.

Categories of Personal Informat= ion Collected

We collect information that ident= ifies, relates to, describes, references, is capable of being associated wi= th, or could reasonably be linked, directly or indirectly, with a particula= r Consumer or Device. The following is a list of categories of personal inf= ormation which we may collect or may have been collected from California re= sidents within the last twelve (12) months.

Please note that the categories a= nd examples provided in the list below are those defined in the CCPA. This = does not mean that all examples of that category of personal information we= re in fact collected by Us, but reflects our good faith belief to the best = of our knowledge that some of that information from the applicable category= may be and may have been collected. For example, certain categories of per= sonal information would only be collected if You provided such personal inf= ormation directly to Us.

  • Category A: Identifiers.

    Examples: A real name, alias, pos= tal address, unique personal identifier, online identifier, Internet Protoc= ol address, email address, account name, driver's license number, passport = number, or other similar identifiers.

    Collected: Yes.

  • Category B: Personal information categories listed in t= he California Customer Records statute (Cal. Civ. Code =C2=A7 1798.80(e)).<= /STRONG>

    Examples: A name, signature, Soci= al Security number, physical characteristics or description, address, telep= hone number, passport number, driver's license or state identification card= number, insurance policy number, education, employment, employment history= , bank account number, credit card number, debit card number, or any other = financial information, medical information, or health insurance information= . Some personal information included in this category may overlap with othe= r categories.

    Collected: Yes.

  • Category C: Protected classification characteristics un= der California or federal law.

    Examples: Age (40 years or older)= , race, color, ancestry, national origin, citizenship, religion or creed, m= arital status, medical condition, physical or mental disability, sex (inclu= ding gender, gender identity, gender expression, pregnancy or childbirth an= d related medical conditions), sexual orientation, veteran or military stat= us, genetic information (including familial genetic information).

    Collected: No.

  • Category D: Commercial information.

    Examples: Records and history of = products or services purchased or considered.

    Collected: Yes.

  • Category E: Biometric information.

    Examples: Genetic, physiological,= behavioral, and biological characteristics, or activity patterns used to e= xtract a template or other identifier or identifying information, such as, = fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke,= gait, or other physical patterns, and sleep, health, or exercise data.

    Collected: No.

  • Category F: Internet or other similar network activity.=

    Examples: Interaction with our Se= rvice or advertisement.

    Collected: Yes.

  • Category G: Geolocation data.

    Examples: Approximate physical lo= cation.

    Collected: No.

  • Category H: Sensory data.

    Examples: Audio, electronic, visu= al, thermal, olfactory, or similar information.

    Collected: No.

  • Category I: Professional or employment-related informat= ion.

    Examples: Current or past job his= tory or performance evaluations.

    Collected: No.

  • Category J: Non-public education information (per the F= amily Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R= . Part 99)).

    Examples: Education records direc= tly related to a student maintained by an educational institution or party = acting on its behalf, such as grades, transcripts, class lists, student sch= edules, student identification codes, student financial information, or stu= dent disciplinary records.

    Collected: No.

  • Category K: Inferences drawn from o= ther personal information.

    Examples: Profile reflecting a pe= rson's preferences, characteristics, psychological trends, predispositions,= behavior, attitudes, intelligence, abilities, and aptitudes.

    Collected: No.

Under CCPA, personal information = does not include:

  • Publicly available information from gov= ernment records
  • Deidentified or aggregated consumer inf= ormation
  • Information exclude= d from the CCPA's scope, such as:
    • Health or medical information covered b= y the Health Insurance Portability and Accountability Act of 1996 (HIPAA) a= nd the California Confidentiality of Medical Information Act (CMIA) or clin= ical trial data
    • Personal Informatio= n covered by certain sector-specific privacy laws, including the Fair Credi= t Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Fin= ancial Information Privacy Act (FIPA), and the Driver's Privacy Protection = Act of 1994

Sources of Personal Information=

We obtain the categories of perso= nal information listed above from the following categories of sources:

  • Directly from You. For example, from the forms= You complete on our Service, preferences You express or provide through ou= r Service, or from Your purchases on our Service.
  • Indirectly from You. For example, from observi= ng Your activity on our Service.
  • Automatically from You. For example, through c= ookies We or our Service Providers set on Your Device as You navigate throu= gh our Service.
  • From Service Providers. Fo= r example, third-party vendors to monitor and analyze the use of our Servic= e, third-party vendors for payment processing, or other third-party vendors= that We use to provide the Service to You.

Use of Personal Information for= Business Purposes or Commercial Purposes

We may use or disclose personal i= nformation We collect for "business purposes" or "commercial purposes" (as = defined under the CCPA), which may include the following examples:

  • To operate our Service and provide You = with our Service.
  • To provide You with support and to resp= ond to Your inquiries, including to investigate and address Your concerns a= nd monitor and improve our Service.
  • To fulfill or meet the reason You provi= ded the information. For example, if You share Your contact information to = ask a question about our Service, We will use that personal information to = respond to Your inquiry. If You provide Your personal information to purcha= se a product or service, We will use that information to process Your payme= nt and facilitate delivery.
  • To respond to law enforcement requests = and as required by applicable law, court order, or governmental regulations= .
  • As described to You when collecting You= r personal information or as otherwise set forth in the CCPA.
  • For internal administrative and auditin= g purposes.
  • To detect security = incidents and protect against malicious, deceptive, fraudulent or illegal a= ctivity, including, when necessary, to prosecute those responsible for such= activities.

Please note that the examples pro= vided above are illustrative and not intended to be exhaustive. For more de= tails on how we use this information, please refer to the "Use of Your Pers= onal Data" section.

If We decide to collect additiona= l categories of personal information or use the personal information We col= lected for materially different, unrelated, or incompatible purposes We wil= l update this Privacy Policy.

Disclosure of Personal Informat= ion for Business Purposes or Commercial Purposes

We may use or disclose and may ha= ve used or disclosed in the last twelve (12) months the following categorie= s of personal information for business or commercial purposes:

  • Category A: Identifiers
  • Category B: Personal information catego= ries listed in the California Customer Records statute (Cal. Civ. Code =C2= =A7 1798.80(e))
  • Category D: Commercial information
  • Category F: Interne= t or other similar network activity

Please note that the categories l= isted above are those defined in the CCPA. This does not mean that all exam= ples of that category of personal information were in fact disclosed, but r= eflects our good faith belief to the best of our knowledge that some of tha= t information from the applicable category may be and may have been disclos= ed.

When We disclose personal informa= tion for a business purpose or a commercial purpose, We enter a contract th= at describes the purpose and requires the recipient to both keep that perso= nal information confidential and not use it for any purpose except performi= ng the contract.

Sale of Personal Information

As defined in the CCPA, "sell" an= d "sale" mean selling, renting, releasing, disclosing, disseminating, makin= g available, transferring, or otherwise communicating orally, in writing, o= r by electronic or other means, a consumer's personal information by the bu= siness to a third party for valuable consideration. This means that We may = have received some kind of benefit in return for sharing personal Iinformat= ion, but not necessarily a monetary benefit.

Please note that the categories l= isted below are those defined in the CCPA. This does not mean that all exam= ples of that category of personal information were in fact sold, but reflec= ts our good faith belief to the best of our knowledge that some of that inf= ormation from the applicable category may be and may have been shared for v= alue in return.

We may sell and may have sold in = the last twelve (12) months the following categories of personal informatio= n:

  • Category A: Identifiers
  • Category B: Personal information catego= ries listed in the California Customer Records statute (Cal. Civ. Code =C2= =A7 1798.80(e))
  • Category D: Commercial information
  • Category F: Interne= t or other similar network activity

Share of Personal Information

We may share Your personal inform= ation identified in the above categories with the following categories of t= hird parties:

  • Service Providers
  • Payment processors
  • Our affiliates
  • Our business partners
  • Third party vendors= to whom You or Your agents authorize Us to disclose Your personal informat= ion in connection with products or services We provide to You

Sale of Personal Information of= Minors Under 16 Years of Age

We do not sell the personal infor= mation of Consumers We actually know are less than 16 years of age, unless = We receive affirmative authorization (the "right to opt-in") from either th= e Consumer who is between 13 and 16 years of age, or the parent or guardian= of a Consumer less than 13 years of age. Consumers who opt-in to the sale = of personal information may opt-out of future sales at any time. To exercis= e the right to opt-out, You (or Your authorized representative) may submit = a request to Us by contacting Us.

If You have reason to believe tha= t a child under the age of 13 (or 16) has provided Us with personal informa= tion, please contact Us with sufficient detail to enable Us to delete that = information.

Your Rights under the CCPA

The CCPA provides California resi= dents with specific rights regarding their personal information. If You are= a resident of California, You have the following rights:

  • The right to notice. You hav= e the right to be notified which categories of Personal Data are being coll= ected and the purposes for which the Personal Data is being used.
  • The right to request. Under = CCPA, You have the right to request that We disclose information to You abo= ut Our collection, use, sale, disclosure for business purposes and share of= personal information. Once We receive and confirm Your request, We will di= sclose to You:
    • The categories of personal information = We collected about You
    • The categories of sources for the perso= nal information We collected about You
    • Our business or commercial purpose for = collecting or selling that personal information
    • The categories of third parties with wh= om We share that personal information
    • The specific pieces of personal informa= tion We collected about You
    • If we sold Your per= sonal information or disclosed Your personal information for a business pur= pose, We will disclose to You:
      • The categories of personal information = categories sold
      • The categories of p= ersonal information categories disclosed
  • The right to say no to the sale of Personal Data (opt-o= ut). You have the right to direct Us to not sell= Your personal information. To submit an opt-out request please contact Us.=
  • The right to delete Personal Data. = You have the right to request the deletion of Your Personal Data, su= bject to certain exceptions. Once We receive and confirm Your request, We w= ill delete (and direct Our Service Providers to delete) Your personal infor= mation from our records, unless an exception applies. We may deny Your dele= tion request if retaining the information is necessary for Us or Our Servic= e Providers to:
    • Complete the transaction for which We c= ollected the personal information, provide a good or service that You reque= sted, take actions reasonably anticipated within the context of our ongoing= business relationship with You, or otherwise perform our contract with You= .
    • Detect security incidents, protect agai= nst malicious, deceptive, fraudulent, or illegal activity, or prosecute tho= se responsible for such activities.
    • Debug products to identify and repair e= rrors that impair existing intended functionality.
    • Exercise free speech, ensure the right = of another consumer to exercise their free speech rights, or exercise anoth= er right provided for by law.
    • Comply with the California Electronic C= ommunications Privacy Act (Cal. Penal Code =C2=A7 1546 et. seq.).
    • Engage in public or peer-reviewed scien= tific, historical, or statistical research in the public interest that adhe= res to all other applicable ethics and privacy laws, when the information's= deletion may likely render impossible or seriously impair the research's a= chievement, if You previously provided informed consent.
    • Enable solely internal uses that are re= asonably aligned with consumer expectations based on Your relationship with= Us.
    • Comply with a legal obligation.
    • Make other internal= and lawful uses of that information that are compatible with the context i= n which You provided it.
  • The right not to be discriminated a= gainst. You have the right not to be discriminat= ed against for exercising any of Your consumer's rights, including by:
    • Denying goods or services to You
    • Charging different prices or rates for = goods or services, including the use of discounts or other benefits or impo= sing penalties
    • Providing a different level or quality = of goods or services to You
    • Suggesting that You= will receive a different price or rate for goods or services or a differen= t level or quality of goods or services

Exercising Your CCPA Data Prote= ction Rights

In order to exercise any of Your = rights under the CCPA, and if You are a California resident, You can contac= t Us:

  • By email: info@thecollaborative.us
  • By visiting this pa= ge on our website: https://thecollaborative.us/contact/

Only You, or a person registered = with the California Secretary of State that You authorize to act on Your be= half, may make a verifiable request related to Your personal information.

Your request to Us must:

  • Provide sufficient information that all= ows Us to reasonably verify You are the person about whom We collected pers= onal information or an authorized representative
  • Describe Your reque= st with sufficient detail that allows Us to properly understand, evaluate, = and respond to it

We cannot respond to Your request= or provide You with the required information if we cannot:

  • Verify Your identity or authority to ma= ke the request
  • And confirm that th= e personal information relates to You

We will disclose and deliver the = required information free of charge within 45 days of receiving Your verifi= able request. The time period to provide the required information may be ex= tended once by an additional 45 days when reasonable necessary and with pri= or notice.

Any disclosures We provide will o= nly cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We= will select a format to provide Your personal information that is readily = useable and should allow You to transmit the information from one entity to= another entity without hindrance.

Do Not Sell My Personal Informa= tion

You have the right to opt-out of = the sale of Your personal information. Once We receive and confirm a verifi= able consumer request from You, we will stop selling Your personal informat= ion. To exercise Your right to opt-out, please contact Us.

The Service Providers we partner = with (for example, our analytics or advertising partners) may use technolog= y on the Service that sells personal information as defined by the CCPA law= . If you wish to opt out of the use of Your personal information for intere= st-based advertising purposes and these potential sales as defined under CC= PA law, you may do so by following the instructions below.

Please note that any opt out is s= pecific to the browser You use. You may need to opt out on every browser th= at You use.

Website

You can opt out of receiving ads = that are personalized as served by our Service Providers by following our i= nstructions presented on the Service:

The opt out will place a cookie o= n Your computer that is unique to the browser You use to opt out. If you ch= ange browsers or delete the cookies saved by your browser, You will need to= opt out again.

Mobile Devices

Your mobile device may give you t= he ability to opt out of the use of information about the apps you use in o= rder to serve you ads that are targeted to your interests:

  • "Opt out of Interest-Based Ads" or "Opt= out of Ads Personalization" on Android devices
  • "Limit Ad Tracking"= on iOS devices

You can also stop the collection = of location information from Your mobile device by changing the preferences= on Your mobile device.

"Do Not Track" Policy as Requir= ed by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to D= o Not Track signals.

However, some third party website= s do keep track of Your browsing activities. If You are visiting such websi= tes, You can set Your preferences in Your web browser to inform websites th= at You do not want to be tracked. You can enable or disable DNT by visiting= the preferences or settings page of Your web browser.

Your California Privacy Rights = (California's Shine the Light law)

Under California Civil Code Secti= on 1798 (California's Shine the Light law), California residents with an es= tablished business relationship with us can request information once a year= about sharing their Personal Data with third parties for the third parties= ' direct marketing purposes.

If you'd like to request more inf= ormation under the California Shine the Light law, and if You are a Califor= nia resident, You can contact Us using the contact information provided bel= ow.

California Privacy Rights for M= inor Users (California Business and Professions Code Section 22581)

California Business and Professio= ns Code section 22581 allow California residents under the age of 18 who ar= e registered users of online sites, services or applications to request and= obtain removal of content or information they have publicly posted.

To request removal of such data, = and if You are a California resident, You can contact Us using the contact = information provided below, and include the email address associated with Y= our account.

Be aware that Your request does n= ot guarantee complete or comprehensive removal of content or information po= sted online and that the law may not permit or require removal in certain c= ircumstances.

Links to Other Websites

Our Service may contain links to = other websites that are not operated by Us. If You click on a third party l= ink, You will be directed to that third party's site. We strongly advise Yo= u to review the Privacy Policy of every site You visit.

We have no control over and assum= e no responsibility for the content, privacy policies or practices of any t= hird party sites or services.

Changes to this Privacy Policy<= /H1>

We may update Our Privacy Policy = from time to time. We will notify You of any changes by posting the new Pri= vacy Policy on this page.

We will let You know via email an= d/or a prominent notice on Our Service, prior to the change becoming effect= ive and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Pr= ivacy Policy periodically for any changes. Changes to this Privacy Policy a= re effective when they are posted on this page.

Contact Us

If you have any questions about t= his Privacy Policy, You can contact us:

  • By email: info@thecollaborative.us
  • By visiting this pa= ge on our website: https://thecollaborative.us/contact/
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