Thank you for using eDiscovery Collect by GoldFynch for your data collection needs. This Policy explains what information we collect, how we collect it, and why we collect information when you use the System. We take your privacy extremely seriously, and we never sell lists or email addresses.

This Policy is effective from June 16th, 2021 (the “Effective Date”).

1. Introduction

Allow us to introduce ourselves and get a few definitions out of the way, so that this policy is clear and easy to understand. Mazira, LLC, dba GoldFynch, dba GoldFynch.com, dba ediscoverycollect.com, the provider (“Provider”) of the “eDiscovery Collect by GoldFynch” service (“Service”), takes the privacy of users seriously. We developed this privacy policy (“Policy”) to describe how Personal Information is collected, used, disclosed, and protected by Provider when you visit or interact with the Website(s) of the Service, and any part of the System. This Policy does not apply to any other website, product, or service operated by Provider, or to any of our offline activities. When we say “you” or “User,” we are referring to the person or entity that chooses to interact with or make use of the Services. Please refer to the Terms of Service for the meaning of any capitalized terms that are not defined in this Policy.

2. Changes and Updates to this Policy

We may change this Policy from time to time. If there are material changes to this Policy, we will notify you by email (sent to the e-mail address used while signing up to use the Service) or by means of a notice on this Website. If we make any material changes to this Policy, the changes will apply from the updated Effective Date mentioned above. We encourage you to check this Policy whenever you use our Website and services to understand how your Personal Information is used.

We do not treat the information of any User differently from that of any other User. Therefore, if you object to changes we make to this Policy, please inform us; we will in such a case have to terminate your access to System and your Customer Data along with your Personal Information with immediate effect.

3. Scope

This Policy applies to any information that we’ve collected, or will collect, about and/or from you in the course of your usage of the System.

4. Your Information

We gather information from you in various ways when you use the Website and services. The information collected consists of (i) Personal Information, (ii) imported information from your email and cloud storage accounts, and aggregate data. As used in this Policy, the term “Personal Information” means information that specifically identifies an individual (such as name, e-mail address, telephone number, address, credit card number, and Internet Protocol (IP) addresses for logged-in users), and demographic and other information when directly linked to information that can identify an individual.

5. Information You Provide to Us

When you use the System, consult with our customer service team, send us an email, or communicate with us in any way, you’re giving us information that we collect. That information may include (but is not limited to) your and your Users’ IP address, name, physical address, email address, phone number, credit card information, operating system, as well as details like gender, occupation, location, birth date, purchase history, and other demographic information. Once you grant us permission, our Service will access your email or cloud storage accounts and import the information that you instruct it to in order to facilitate its download; it only reads information and will not change any data. By giving us this information, you consent to your information being collected, used, disclosed, transferred to the United States and stored by us, as described in our Terms of Use and this Policy.

The following are examples of the sort of information we may collect from you.

• Registration information — When you create a Collection with us, we collect your email address, and other information used to authenticate your identity and access your Collection(s) and data.
• Import/Attachment information — When you use the System to import and manage documents, emails, images and other electronic files, we collect and keep some of the information about a file (e.g. file type, size, filename, date).
• Payment information — If you make a payment to avail of our services, we, or our payment-processing vendor, collect your credit card information and billing address insofar as is necessary or appropriate to fulfill the purpose of the User’s interaction with Provider.
• Access information —We gather data of the sort that web browsers and servers typically make available, such as internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the System, to track users’ movements around the site, and to gather demographic information about our user base as a whole. Ordinarily, this is non-personally-identifying information. To the extent such information contains or is linked to personally identifiable information, such information will be protected in accordance with this Policy.

6. Cookies, Web Beacons and Tracking

When you use the System, we may store “cookies,” “tags,” or “scripts,” which is a small amount of data sent from a website to your computer and stored on your computer. We and our analytics service providers (like Google) use those cookies to collect information about your visit and your use of our Website or System. You can modify your browser setting to reject our cookies or to prompt you before accepting a cookie by editing your browser options. However, if a browser is set not to accept cookies or if a user rejects a cookie, some portions of the Website and Service may not function properly. For example, you may not be able to sign in and access your Collections. We may also use cookies and web beacons to collect information regarding your web browsing activities such as the address of the page you are visiting, the address of the referrer page you previously visited, the time and duration for which you view the page, your browsing environment and your display settings.

Among other things, the use of cookies and web beacons enables us to: improve our Website and communications with you by seeing which areas and features are most popular; count the number of computers accessing our Website; personalize and improve your experience; record your preferences: and allow you to visit our Website without re-entering your email and login credentials. Most browsers automatically accept cookies as the default setting.

Third-Party Cookies — Provider uses third parties to track and analyze usage and volume statistical information from individuals who visit the Website. Provider uses this information to serve users better. The use of cookies by our service providers is not covered by this Policy. We do not have access or control over these cookies.

Information from the use of our Mobile Apps: When you access our System through the web browser of your mobile device or through any future mobile app, we may collect information about the type of device and operating system you use. We may ask you if you want to receive push notifications about activity in your Collection(s). If you opt into these notifications and no longer want to receive them, you may turn them off through your operating system. We do not access or track any location-based information from your mobile device unless you have given us permission. We may use mobile analytics software to help us better understand how customers use our application. We may collect information about how often you use the application and other performance data. We don’t collect or link that data with any personally identifiable information.

7. How We Use Your Personal Information

In general, we use your personal information to process your requests or transactions, to provide you with information or services you request, to inform you about other information, events, promotions, products, or services we think will be of interest to you, to facilitate your use of, and our administration and operation of, the Website and our services and to otherwise serve you and our users. For example, we may use your personal information:

• to validate your email address for the purpose of logging into System;
• to send you System Alert Messages;
• to request feedback and to enable us to develop, customize and improve the Website and our products and services;
• to conduct marketing analysis, to send you surveys or newsletters, to contact you about services, products, activities, special events or offers from us or our partners and for other marketing, informational, product development and promotional purposes;
• to send you a welcoming email and to contact you about your use of the Website and services;
• to send you informational and promotional content that you may choose (or “opt in”) to receive;
• to inform you of updates to products and services from us that better meet your needs;
• to perform after-sales services;
• for legal reasons such as arbitration;
• to enable collaboration or file sharing (if available) with other users you designate;
• for other purposes about which we notify you;
• to bill and collect money owed to us; and
• to enforce compliance with our Terms of Service and applicable law.

8. How We Share Your Personal Information

We will share your Personal Information with third parties only in the ways that are described in this Policy. We do not sell your Personal Information to third parties.

• Service providers — We may use third-party partners to help us operate and maintain our Website and deliver our products and services. We may also share your Personal Information and website usage information with our service providers and other third parties that provide products or services for or through the Website or for our business (such as website or database hosting companies, address list hosting companies, communications providers, email service providers, analytics companies, distribution companies, fulfillment companies, credit card/payment processing companies and other similar service providers that use such information on our behalf). Note that we may use a service such as Google Analytics to review website use. In such cases, any information that such a service has keyed to your IP number will be correlated with the logs of your visits to our site for whatever purpose that service's policy allows.
• Aggregate statistics — We may disclose non-personally identifiable aggregate statistics regarding user behavior as a measure of interest in, and use of, our Website and emails to third parties in the form of aggregate data, such as overall patterns or demographic reports, which do not describe or identify any individual user. Information relating to aggregate statistics may be collected using third-party cookies and other third-party tracking devices.
• Legally compelled disclosure — We may disclose your Personal Information if required to do so by law or subpoena or if we believe that such action is necessary to (a) conform to the law, comply with a judicial or court order or comply with legal process served on us or Affiliated Parties; (b) protect and defend our rights and property, our Website, the users of the Website, and/or our affiliated parties; or (c) act under circumstances to protect the safety of users of our Website, us, or third parties.
• Business transfer — If Provider, or substantially all of its assets, were acquired, or in the unlikely event that Provider goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge and agree that such transfers may occur, and that any acquirer of Provider may continue to use your Personal Information as set forth in this Policy.

9. User Access and Choice to Opt In/Out

If your Personal Information changes in any way, we invite you to correct, delete, or update it as soon as possible by emailing support@goldfynch.com from the email address used to create your Collection.

If you no longer desire our service, you may email support@goldfynch.com to delete your Customer Data. We will respond to your request within 30 calendar days.

We may send you communications or data regarding our Website and services, including but not limited to (i) notices about your use of our Websites and services, including any notices concerning violations of use, (ii) updates, and (iii) promotional information and materials regarding our products and services. You may opt out of receiving promotional emails from us by following the opt-out instructions provided in those emails. You may also opt out of receiving promotional emails and other promotional communications from us at any time by emailing support@goldfynch.com with your specific request. Opt-out requests will not apply to transactional service messages, such as security alerts and notices about your current Collections and other services. To stop receiving emails entirely, you would have to deactivate your Collection(s). Please email support@goldfynch.com from the email address associated with your Collection(s) with a deactivation request and we will respond to your request within 30 calendar days.

10. Your Rights for Protection of Personal Data Under the EU GDPR (General Data Protection Regulation)

If you are a resident of the EEA, you have the data protection rights listed below:

• If you wish to make a correction, access, update, or request deletion of your Personal Information, you can do so at any time by emailing privacy@goldfynch.com.
• You can also object to the processing of your Personal Information, ask us to restrict the processing of your Personal Information, or request porting of your Personal Information. To exercise any or all these rights, email privacy@goldfynch.com.
• As always, you have the right to opt out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" link in the marketing emails we send you. If for some reason you receive other marketing material from us, please contact us at privacy@goldfynch.com.
• If we have collected your Personal Information (we have always only done so only with your consent,) you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to an authority in charge of data protection about our collection and use of your Personal Information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

If applicable, our GDPR Data Protection Addendum contains further details about how and why we use your information and how we comply with GDPR requirements.

11. Information Security

We have employed reasonable physical, organizational, and technical safeguards to protect information we collect from you to prevent its loss, misuse, and unauthorized access, disclosure, alteration, and destruction. In addition, highly confidential personal information such as credit card number and password that we request from you on our Website is protected with encryption, such as Secured Socket Layer (SSL) protocol, during transmission over the internet.

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. While we take reasonable efforts to guard Personal Information we knowingly collect directly from you, no security system is impenetrable. It is your responsibility to ensure that you keep all login and user information issued to you by us (“Credentials”) safe and that it is not accessible to unauthorized individuals. Please inform us immediately if your Credentials have been compromised in any manner whatsoever. You will also need to close your browser at the end of a session to protect against unauthorized access. If you have specific needs or obligations regarding any passively-collected Personal Information you choose to include in documents you store on our System, please satisfy yourself that such information is maintained at adequate levels of protection to meet those needs or obligations before you upload it to the System.

12. Third Parties

Our Website may include links to other websites whose privacy practices may differ from ours. If you submit Personal Information to any of those sites, your information is governed by their respective privacy policies. Our Website also includes social media features, such as social media buttons or interactive mini-programs that run on our Website. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Such features and mini-programs are either hosted by a third party or hosted directly on our Website and your interactions with them are governed by the privacy policy of the company providing it.

13. Questions & Concerns

If you have any questions or comments, or if you want to update, delete, or change any Personal Information we hold, or you have a concern about the way in which we have handled any privacy matter, please email us at privacy@goldfynch.com, or write to us at:

Mazira LLC
Attn.: Privacy Officer
136 S Dubuque Street
Iowa City, IA 52240