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Last Revised: January 14, 2022

This Privacy Policy applies to MODERATE LLC (“MODERATE”, “We,” “Us,” or “Our”) and describes the collection, use, disclosure, and protection of information gathered through the MODERATE network of Websites, including MODERATE.com, newsbreakapp.com, email newsletters distributed by us (hereinafter “Web sites” or “Sites”) and through MODERATE published mobile applications (hereinafter “Apps”) (together hereinafter “Services”). MODERATE is committed to protecting the confidentiality and security of information it collects through its Websites and Apps. Please read the following carefully. Your use of the Web sites and Apps is governed by this Privacy Policy, along with MODERATE’s Terms of Use (available here: https://www.MODERATE.com/terms). Our Privacy Policy or Terms of Use does not apply to any third-party websites, services or applications, even if they are accessible through our Services.

By using our Sites and Apps, you are accepting the practices described in our Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Sites and Apps. We reserve the right to modify or amend the terms of our Privacy Policy from time to time without notice. Your continued use of our Sites and Apps following the posting of changes to these terms will mean you accept those changes.

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  1. Revisions to this Privacy Policy. Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of these changes by posting them on the Services or other notification, and we’ll update the “Last Updated Date” above to indicate when those changes will become effective. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services.

  2. Information We Collected or Received. We collect the following information, much of these are device-related and non-personal information, which alone cannot be used to identify you.

    • Usage Information. We collect information about how you use our App, such as the type of content you view, and the time, frequency and duration of your activities, advertisement interactions and other usage information and performance data related to the Sites and Apps and usage of them.

    • Information You Provide When Sign-In. If you register for an account with us, you will provide us your username, email address.

  3. How Do We Use Your Information. Our primary purposes for the collection and processing of information is to provide our Services (to perform our contract with you), to improve our Services, to administer your use of the Services, to market the Services to you, and to enable you to enjoy and easily navigate our Services. Also, we may process your information where we have a legitimate interest (e.g., fraud prevention, network and information security, research (including marketing research), and direct marketing), and as you otherwise consent.
    We will use your information in one or more of the following ways:
    Performing Services for You:

    • As necessary for the Apps to function or provide you with Services properly;

    • Automatically update the App on your device;

    • Improve user experience;

    • Perform statistical, demographic, and marketing analyses of users of the App;

    • Communicate with you about your questions, claims or technical support; and

    • Communicate with you about changes to our policies, and send you information about features and enhancements on our Sites and Apps.

  5. Internal Research and Development; Quality Control:

    • In the aggregate to help us evaluate and modify existing services and to help us develop additional services that are likely to be of interest to our users;

    • Optimize or improve our products, services and operations; and

    • To monitor quality control and ensure compliance with our legal obligations, codes and ordinances, policies and procedures.

  6. California Residents Only.
    As a California resident, you will have other following rights with respect to your personal information of prior 12 months:

    • Right to know. You have the right to request that we disclose to you the personal Information we collect, use, or disclose, and information about our data practices, including the categories of personal information we collect, the categories of sources of such information, our business purpose for collecting or sharing such information, and the categories of third parties with whom we share such information;

    • Right to receive a copy. You have the right to receive a copy of the personal information we have collected about you;

    • Right to request deletion. You have the right to request that we delete your Personal Information that we have collected from you subject to certain exceptions;

    • Right to non-discrimination. We will not discriminate against you for exercising any of these rights.

  7. To exercise these rights, you can choose to:

  8. The Security of Your Information. We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you from unauthorized access, use or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the security of any information.

  9. Data Retention. We retain the information we collect for as long as your use of our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

  10. Links to Other Sites. Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-party Services that you access.

  11. Data Processing. Our site and data are maintained on AWS servers located in the U.S., and your information is processed and stored in the U.S..  If you are visiting our Sites from outside the U.S., please be advised that your information is transferred in the U.S.

  12. Our Policy toward People under 13. Our Services are not directed to people under 13 and we do not knowingly collect information from individuals under the age of 13. If you are between 13 and 18, you must have permission from your legal guardian before you are permitted to use the Services. If we learn that we have collected information of an individual under 13 we will take steps to delete such information from our files as soon as possible.

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