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PRIVACY POLICY
LAST UPDATED MAY 1, 2024

Zusammen LLC (“Zusammen”) is committed to protecting your privacy. We have prepared this
Privacy Policy to describe to you our practices regarding the Personal Data (as defined below)
we collect from users of our website, located at www.zusammencincinnati.com (the “Site“).

Questions; Contacting Zusammen; Reporting Violations. If you have any questions or
concerns or complaints about our Privacy Policy or our data collection or processing practices, or
if you want to report any security violations to us, please contact us at the following email
address: legal@zusammencincinnati.com.

A Note About Children. We do not intentionally gather Personal Data from visitors in the US
who are under the age of 13. If a child under 13 submits Personal Data to Zusammen and we
learn that the Personal Data is the information of a child under 13, we will attempt to delete the
information as soon as possible. If you believe that we might have any Personal Data from a
child under 13, please contact us at legal@zusammencincinnati.com.

A Note to Users Outside of the United States. If you are a user of Site who resides in a
country other than the United States this section applies to you:

  • If you reside in the UK or any country within the European Economic Area (“EEA“):

    • Zusammen are the Controllers (for the purposes of the General Data
      Protection Regulation 2016/679 (“GDPR”) and any implementing
      legislation or legislation having equivalent effect in the UK (together, “EU
      Data Protection Legislation
      ”)) of your Personal Data.​

    • The legal basis of our processing of your Personal Data as described in
      this Privacy Policy is our legitimate interests where those interests are not
      overridden by the impact on you (unless our processing is otherwise
      required or permitted by law). If you have questions about the legal basis
      of how we process your personal information, please contact us at the
      address or phone number above.

    • We ask that you not provide us with any Special Category Personal Data
      (as defined in the GDPR), e.g., information related to racial or ethnic
      origin, political opinions, religion or other beliefs, health, biometrics or
      genetic characteristics, or trade union membership, or any criminal
      background information. If you do not consent to our processing and use
      of such sensitive information, you must not submit such sensitive
      information through the Site.

    • We may transfer your Personal Data to a country outside the UK or EEA
      in accordance with requirements prescribed under EU Data Protection
      Legislation. When we transfer your Personal Data outside the UK or EEA,
      we hold it subject to appropriate safeguards and controls and ensure a
      similar degree of protection is afforded to it by implementing at least one
      of the following safeguards:

    • We may transfer your Personal Data to countries that have been deemed to
      provide an adequate level of protection for Personal Data by the European
      Commission. For further details, see https://ec.europa.eu/info/law/law-
      topic/data-protection/international-dimension-data-protection/adequacy-decisions_en
      (opens in a new tab).

  • If you reside in Singapore:​

    • You agree that your accessing or using the Site in any way constitutes
      your agreement that (a) we may process your Personal Data for the
      purposes identified in the Privacy Policy, and (b) your Personal Data may
      be transferred to and processed in the country in which it was collected
      and in other countries, including the United States, where laws regarding
      processing of Personal Data may be less stringent than the laws in your
      country.​

    • We may transfer your Personal Data to a country or territory outside
      Singapore in accordance with requirements prescribed under the
      Singapore Personal Data Protection Act (“PDPA“) to ensure that we
      provide a standard of protection to Personal Data so transferred that is
      comparable to the protection under the PDPA. By providing your Personal
      Data, you consent to such transfer.

1. Types of Data We Collect. “Personal Data” means data that allows someone to identify
or contact you, including, for example, your name, address, telephone number, e-mail address, as
well as any other non-public information about you that is associated with or linked to any of the
foregoing data. “Anonymous Data” means data that is not associated with or linked to your
Personal Data; Anonymous Data does not, by itself, permit the identification of individual
persons. We collect Personal Data and Anonymous Data, as described below.​​​

  1. Information You Provide to Us.​

  • We may collect Personal Data from you, such as your first and last name,
    e-mail, mailing address, and phone number.​

  • If you provide us feedback, post an event or contact us via e-mail, we will
    collect your name and e-mail address, as well as any other content
    included in the form, in order to send you a reply.

  • We may also collect Personal Data at other points in the Site that states
    that Personal Data is being collected.

 2. Information Collected via Technology.

  • Information Collected by Our Servers. To make our Site more useful to
    you, our servers (which may be hosted by a third party service provider)
    collect information from you, including your browser type, operating
    system, Internet Protocol (“IP“) address (a number that is automatically
    assigned to your computer when you use the Internet, which may vary
    from session to session), domain name, and/or a date/time stamp for your
    visit.​

  • Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP“), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Site, track users’ movements around the Site, and to gather demographic information about our user base as a whole. For example, some of the information may be collected so that when you visit the Site, it will recognize you and the information could then be used to provide information appropriate to your interests. Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Data.

  • Cookies. Like many online services, we use cookies to collect
    information. “Cookies” are text files containing small amounts of
    information which are downloaded to your computer or mobile device
    when you visit a website or mobile application. Cookies are then sent back
    to the originating site on each subsequent visit, or to another site that
    recognizes those cookies. You can find out more information about
    cookies at http://www.allaboutcookies.org/(opens in a new tab). Cookies
    are widely used in order to make sites work, or to work more efficiently,
    as well as to provide information to the owners of the platform. We use
    cookies to enhance the online experience of our visitors and to better
    understand how our site is used. Cookies may tell us, for example,
    whether you have visited our site before or whether you are a new visitor.
    This type of information is collected to make the Site more useful to you.
    “Cookies” are small pieces of information that a website sends to your
    computer’s hard drive while you are viewing the website. We may use
    both session Cookies (which expire once you close your web browser) and
    persistent Cookies (which stay on your computer until you delete them) to
    provide you with a more personal and interactive experience on the Site.

 3. Use of your Personal Data

     General Use. In general, Personal Data you submit to us is used to respond to
requests that you make. We use your Personal Data in the following ways:

  • to provide improved administration of the Site;

  • to improve the quality of experience when you interact with the Site;

  • to send you follow-up communications when you contact us via e-mail,
    submit feedback, or post an event; and

  • to send you administrative e-mail notifications, such as updates regarding
    the Site, security, or support and maintenance advisories.

​​

 4. Creation of Anonymous Data. We may create Anonymous Data records from
Personal Data by excluding information (such as your name) that makes the data
personally identifiable to you. We use this Anonymous Data to analyze request
and usage patterns so that we may enhance the content of, and improve navigation
on, the Site. We reserve the right to use Anonymous Data for any purpose and
disclose Anonymous Data to third parties in our sole discretion.

1. Disclosure of Your Personal Data. We disclose your Personal Data as described below
and as described elsewhere in this Privacy Policy.

  1. Third Party Service Providers. We may share your Personal Data with third
    party service providers to: conduct quality assurance testing; to provide technical
    support; and/or to provide other services to Zusammen. These third party service
    providers are required not to use your Personal Data other than to provide the
    services requested by Zusammen.

  2. Corporate Restructuring. We may share some or all of your Personal Data with
    entities within our group of companies. We may also share some or all of your
    Personal Data in connection with or during negotiation of any merger, financing,
    acquisition or dissolution transaction or proceeding involving sale, transfer,
    divestiture, or disclosure of all or a portion of our business or assets. In the event
    of an insolvency, bankruptcy, or receivership, Personal Data may also be
    transferred as a business asset. If another company acquires our company,
    business, or assets, that company will possess the Personal Data collected by us
    and will assume the rights and obligations regarding your Personal Data as
    described in this Privacy Policy.

  3. Other Disclosures. Regardless of any choices you make regarding your Personal
    Data (as described in Section 8 below), Zusammen may disclose Personal Data if
    it believes in good faith that such disclosure is necessary (a) in connection with
    any legal investigation; (b) to comply with relevant laws or to respond to
    subpoenas or warrants served on Zusammen; (c) to protect or defend the rights or
    property of Zusammen or users of the Site; and/or (d) to investigate or assist in
    preventing any violation or potential violation of the law, this Privacy Policy, or
    our Terms of Use.

1. Third Party Websites. The Site may contain links to third party websites. When you
click on a link to any other website or location, you will leave our Site and go to another site, and
another entity may collect Personal Data or Anonymous Data from you. We have no control
over, do not review, and cannot be responsible for, these outside websites or their content. Please
be aware that the terms of this Privacy Policy do not apply to these outside websites or content,
or to any collection of your Personal Data after you click on links to such outside websites. We
encourage you to read the privacy policies of every website you visit. The links to third party
websites or locations are for your convenience and do not signify our endorsement of such third
parties or their products, content or websites.​​

1. Your Choices Regarding Information. You have several choices regarding the use of
information on the Site:

  1. Email Communications. We may periodically send you promotional e-mails if
    you have indicated that you would like us to do so. When you receive newsletters
    or promotional communications from us, you may indicate a preference to stop
    receiving further communications from us and you will have the opportunity to
    “opt-out” by following the unsubscribe instructions provided in the e-mail you
    receive or by contacting us directly (please see contact information above).
    Despite your indicated e-mail preferences, we may send you service related
    communications, including notices of any updates to our Terms of Use or Privacy
    Policy.

  2. Cookies. If you decide at any time that you no longer wish to accept Cookies
    from the Site for any of the purposes described above, then you can instruct your
    browser, by changing its settings, to stop accepting Cookies or to prompt you
    before accepting a Cookie from the websites you visit. Consult your browser’s
    technical information. If you do not accept Cookies, however, you may not be
    able to use all portions, or all functionality, of the Site. If you have any questions
    about how to disable or modify Cookies, please let us know at the contact
    information provided above.

  3. Changing or Deleting Your Personal Data. Personal Data will be retained for
    such period as may be required to fulfil the purposes set out in this Privacy Policy,
    or such other period as may be required by law. You may request deletion of your
    Personal Data by us, and we will use commercially reasonable efforts to honor
    your request, but please note that we may be required by law to keep such
    information and not delete it (or to keep this information for a certain time, in
    which case we will comply with your deletion request only after we have fulfilled
    such requirements). When we delete any information, it will be deleted from the
    active database, but may remain in our archives. If you reside in the EEA, in the
    event that such Personal Data remains in our archives, Zusammen will ensure that
    this data is put beyond use. If you reside in Singapore, we will take commercially
    reasonable efforts to ensure that your Personal Data in our possession or under
    our control is destroyed and/or anonymized as soon as it is reasonable to assume
    that (i) the purpose for which your Personal Data was collected is no longer being
    served by the retention of such Personal Data; and (ii)

  4. Your Rights Regarding Your Personal Data.

    1. If you reside in the UK or EEA, you have certain, you have certain rights
      regarding your Personal Data and may, in certain circumstances, ask us to
      take the following actions in relation to such data:

      1. provide you with information about our processing of your Personal Data and give you access to such data.​

      2. update or correct inaccuracies in your Personal Data.

      3. delete your Personal Data.

      4. transfer a machine-readable copy of your Personal Data to you or a third party of your choice.

      5. restrict the processing of your Personal Data.

      6. object to our reliance on our legitimate interests as the basis of our processing of your Personal Data that impacts your rights.

 2. If you reside in Singapore, you may request to access and/or correct your
Personal Data currently in our possession by writing to us. Please note that
we may charge you a reasonable fee for the handling and processing of
your requests to access your Personal Data.​

1. Changes to This Privacy Policy. This Privacy Policy may be updated from time to time
for any reason. We will notify you of any changes to our Privacy Policy by posting the new
Privacy Policy and we will change the “Last Updated” date above. You should consult this
Privacy Policy regularly for any changes.

​

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