Privacy Policy 

Last Updated: [October 20th, 2021] 

1. General Information 

PLEASE READ THIS PRIVACY STATEMENT AND NOTIVE OF PRIVACY PRACTICES  CAREFULLY. 

The Possibility Movement, Inc. dba The Possibility Company , and our parent companies,  subsidiaries and affiliates (collectively, the “Company”, “our”, “us” and “we”) respect your privacy and  are committed to protecting it through our compliance with this privacy policy (“Privacy Policy”). 

This Privacy Policy describes the types of information we may collect from you, the user, (“you”  and “your”) or that you may provide when you visit the mobile application ([Zaahah Mobile]) (the “App”)  the aHa digital wallet or the websites (www.possibilitycompany.com and www.zaahah.com),) and any  affiliated third party websites that may contain a link to this Privacy Policy, including, without limitation,  any pages, facilities, services, or capabilities accessible on or by any top-level domain owned by us or any  subsite, subdomain, subdirectory, virtual site, or virtual directory thereof (the “Website” and, together with  the App, the “Electronic Platforms”) and our practices for collecting, using, maintaining, protecting, and  disclosing that information. 

This Privacy Policy applies to information we collect: 

• on or through the Electronic Platforms; 
• in email, text, and other electronic messages between you and the Electronic Platforms or us; 
• when you interact with our advertising and applications on third party websites and services, if  those applications or advertising include links to this Privacy Policy; and 

This Privacy Policy does not apply to information collected by: 

• us offline or through any other means, including on any other website operated by us or any third  party (including our affiliates and subsidiaries) that does not link to this Privacy Policy; and  
• any third party (including our affiliates and subsidiaries), including through any application or  content (including advertising) that may link to or be accessible from or on the Electronic  Platforms. 

Please read this Privacy Policy carefully to understand our policies and practices regarding your  information and how we will treat it. If you do not agree with our policies and practices, including our use  and disclosure of your Personal Information, please do not use our Electronic Platforms and do not provide  us with any of your information. By accessing or using the Electronic Platforms, you agree to the terms of  this Privacy Policy and consent to our privacy practices described in this Privacy Policy, including our use  and disclosure of your Personal Information as described in Section Error! Reference source not found. below. This Privacy Policy may change from time to time as described in Section Error! Reference source  not found. below. Your continued use of the Electronic Platforms after we make changes is deemed and  treated as your acceptance of those changes, so please check the Privacy Policy periodically for updates. 

 

2. Changes to Our Privacy Policy 

We reserve the right to revise or update this Privacy Policy at any time, and You agree to be  bound by those revisions or updates. It is our policy to post any changes we make to our Privacy Policy  on this page [with a notice that the Privacy Policy has been updated on the Website’s home page]. If  we make material changes to how we treat our users’ Personal Information, we will notify you by email  to the primary email address specified in your account and through a notice on the Website home page.  The date the Privacy Policy was last revised is identified at the top of this webpage as the “Last Updated”  date. When you use any Electronic Platform after any updates to this Privacy Policy, you agree to and  accept the updates and the included revisions and modifications. You are responsible for ensuring we  have an up-to-date active and deliverable email address for you, and for periodically visiting our  Electronic Platforms and this Privacy Policy to check for any changes. 

3. Contact Information and Electronic Communication 

By using our Electronic Platforms or providing your personal information to us, You agree that we  can communicate with you electronically regarding any legal, regulatory, technical, security, privacy and  any administrative or consumer notification obligations that may be related to your use of the Electronic  Platforms. If You have any questions about this Privacy Policy or about Electronic Platforms related to the  Privacy Policy, you can contact us by e-mail at privacy@possibilitycompany.com. 

4. Children Under the Age of 13 

Our Electronic Platforms are not intended for children under thirteen (13) years of age. No one  under age 13 may register or provide any information to any Electronic Platform. We do not knowingly  allow children under 13 or collect their information and do not direct our Electronic Platforms for use by  individuals under the age of 13. If you are under 13, do not use or provide any information on the  Electronic Platforms or on or through any of its features/register, make any purchases through the  Electronic Platforms, use any of the interactive or public comment features of the Electronic Platforms or  provide any information about yourself to us, including your name, address, telephone number, email  address, or any screen name or user name you may use. If we learn we have collected or received  Personal Information from a child under 13 without verification of parental consent, we will delete that  information. If you believe we might have any information from or about a child under 13, please contact  us at privacy@possibilitycompany.com and we will promptly remove the information. 

5. Information We Collect About You and How We Collect It. 

We collect several types of information from and about users of our Electronic Platforms, including  information: 

• by which you may be personally identified, such as your name, postal address, e-mail address,  telephone number, school, or any other information the Electronic Platforms collects that is defined  as personal or personally identifiable information under any applicable law (“Personal  Information”); 
• that is about you but individually does not identify you; and/or 
• about your internet connection, the equipment you use to access our Electronic Platforms and usage  details. 

We collect this information:

• Directly from you when you provide it to us. 
• Automatically as you navigate through an Electronic Platform. Information collected automatically  may include usage details, IP addresses, and information collected through cookies, web beacons,  and other tracking technologies. 
• From third parties, for example, our business partners. 

5.1 Information You Provide to Us. The information we collect, including Personal  Information, on or through our Electronic Platforms may include: 

• Information that you provide by filling in forms on our Electronic Platforms. This includes  information provided at the time of registering to use our Electronic Platforms, posting material to  or through an Electronic Platform, or requesting further services. We may also ask you for  information when you enter a contest or promotion sponsored by us, and when you report a problem  with our Electronic Platforms or ask us a question. 
• Records and copies of your correspondence (including email addresses), if you contact us. • Your responses to surveys that we might ask you to complete for research purposes. • Your search queries on the Electronic Platforms. 

While it is your choice whether to provide the requested information or not, we cannot provide  certain services you may request if you do not provide the requested information. 

You also may provide information to be published or displayed (hereinafter, “posted”) on public  areas of the Electronic Platforms, or transmitted to other users of the Electronic Platforms or third parties  (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at  your own risk. Although [we limit access to certain pages/you may set certain privacy settings for such  information by logging into your account profile], please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Electronic Platforms with  whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that  your User Contributions will not be viewed by unauthorized persons. Any User Contributions you post or  otherwise provide are at your own risk.  

5.2 Information We Collect Through Automatic Data Collection Technologies and Do Not-Track Signals. As you navigate through and interact with our Electronic Platforms, we may use  automatic data collection technologies to collect certain information about your equipment, browsing  actions, and patterns, including: 

• Usage Details. Details of your visits to our Electronic Platforms, including traffic data, location  data, logs, and other communication data and the resources that you access and use on the  Electronic Platforms. 
• Device Information. We may collect information about your computer or mobile device and  internet connection, including the device’s unique device identifier, IP address, operating system,  browser type, mobile network information, and the device’s telephone number.
• Stored Information and Files. The Electronic Platforms also may access metadata and other  information associated with other files stored on your device. This may include, for example,  photographs, audio and video clips, personal contacts, and address book information. 
• Location Information. The Electronic Platforms [collect/do not collect] real-time information  about the location of your device. [●]. 

We also will not use these technologies to collect information about your online activities over time  and across third party websites or other online services (behavioral tracking).  

Do-Not-Track is a public-private initiative, http://www.w3.org/2011/tracking-protection/, that has  developed a technical “flag” or signal that an end-user may be able to activate within their browser software  to notify websites that they do not wish to be “tracked” by third parties as defined by the initiative. The  initiative, however, has not reached a consensus as to exactly what technical or other actions those parties  receiving the signal should take. As a result, Do-Not-Track has not yet been standardized and most websites,  including us and our Electronic Platforms, do not alter their behavior or change their services when their  websites receive a “do-not-track” flag or signal.  

The information we collect automatically is statistical data and may include Personal Information,  or we may maintain it or associate it with Personal Information we collect in other ways or receive from  third parties. It helps us to improve our Electronic Platforms and to deliver a better and more personalized  service, including by enabling us to: 

• Estimate our audience size and usage patterns. 
• Store information about your preferences, allowing us to customize our Electronic Platforms according to your individual interests. 
• Speed up your searches. 
• Recognize you when you return to our Electronic Platforms. 

The technologies we use for this automatic data collection may include: 

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer.  You may refuse to accept browser cookies by activating the appropriate setting on your browser.  However, if you select this setting you may be unable to access certain parts of our Electronic  Platforms. Unless you have adjusted your browser setting so that it will refuse cookies, our system  will issue cookies when you direct your browser to our Website.  
• Flash Cookies. Certain features of our Electronic Platforms may use local stored objects (or Flash  cookies) to collect and store information about your preferences and navigation to, from, and on  our Electronic Platforms. Flash cookies are not managed by the same browser settings as are used  for browser cookies. For information about managing your privacy and security settings for Flash  cookies, see Section 9 below. 
• Web Beacons. Our Electronic Platforms and our e-mails may contain small electronic files known  as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for  example, to count users who have visited those pages or opened an email and for other related  website statistics (for example, recording the popularity of certain website content and verifying  system and server integrity).  

6. How We Use Your Information. 

We use information that we collect about you or that you provide to us, including any Personal  Information: 

• To present our Electronic Platforms and their contents to you. 
• To provide you with information, products, or services that you request from us. • To fulfill any other purpose for which you provide it. 
• To provide you with notices about your account, including expiration and renewal notices.] 
• To carry out our obligations, including contractual obligations, and enforce our rights arising from  any contracts entered into between you and us, including for billing and collection and to enforce  our Terms of Use. 
• To notify you about changes to our Electronic Platforms or any products or services we offer or  provide though it. 
• To allow you to participate in interactive features on our Electronic Platforms. • In any other way we may describe when you provide the information to us. 
• As set forth in a separate agreement between you and us.  
• To improve the Electronic Platforms by solving technical problems, to calculate overall usage  statistics, for internal marketing and promotional purposes, and for service development and  content improvement. 
• To maintain the security and integrity of the Electronic Platforms and our IT systems. • For any other purpose with your consent. 

We may also use your information to contact you about our own and third parties goods and  services that may be of interest to you. If you do not want us to use your information in this way, please  adjust your user preferences in your account profile. If you wish to stop receiving certain emails please  click the “unsubscribe” link at the bottom of the email. For more information, see Section 8 below. 

We may use the information we have collected from you to enable us to display advertisements to  our advertisers’ target audiences. Even though we do not disclose your Personal Information for these  purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser  may assume that you meet its target criteria.] 

We will retain your Personal Information for as long as necessary to fulfill the purpose(s) for  which it was collected and to comply with applicable laws, and your consent to such purposes(s) remains  valid during such time. When Personal Information is no longer needed or legally required, it will be  permanently deleted or de-identified so that it can no longer be associated with a specific individual. 

7. Disclosure of Your Information. 

We may disclose aggregated, non-personally identifiable information about our users, and  information that does not identify any individual, without restriction.  

We may disclose Personal Information that we collect or you provide as described in this Privacy  Policy:

• To our parent companies, subsidiaries, and affiliates. 
• To contractors, service providers, and other third parties we use to support our business and who  are bound by contractual obligations to keep Personal Information confidential and use it only for  the purposes for which we disclose it to them. 
• To a buyer or other successor in the event of 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 Personal Information held by us  about our users is among the assets transferred. 
• To fulfill the purpose for which you provide it.  
• As set forth in any separate agreement between you and us.  
• For any other purpose disclosed by us when you provide the information. 
• With your consent. 

We may also disclose your Personal Information: 

• To comply with any court order, law, or legal process, including to respond to any government,  law enforcement, or regulatory request. 
• To enforce or apply our terms of use located at https://possibilitycompany.com/terms-of-service/ (“Terms of Service”), other agreements, and any other documents included or referenced therein  (all of which are incorporated into and made a part of this Privacy Policy by this reference). 
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us,  our customers, other users, service providers, or others. This includes exchanging information with  other companies and organizations for the purposes of fraud protection. 

8. Choices About How We Use and Disclosure Your Information. 

We strive to provide you with choices regarding the Personal Information you provide to us. We  have created mechanisms to provide you with the following control over your information:  

• Tracking Technologies and Advertising. We do not track your online activity but track cookies  related to your use of the Electronic Platform to improve the service delivered. You can set your  browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn  how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s  website. If you disable or refuse cookies, please note that some parts of our Electronic Platforms may then be inaccessible or not function properly. 
• Disclosure of Your Information for Third Party Advertising. We do not disclose your Personal  Information with unaffiliated or non-agent third parties for promotional purposes.  
• Promotional Offers from us. If you do not wish to have your contact information used by us to  promote our own or third parties’ products or services, you can opt-out by logging into an Electronic  Platform and adjusting your user preferences in your account profile by checking or unchecking  the relevant boxes. If we have sent you a promotional email, you may update your preferences to  unsubscribe.  

In the future, only approved and vetted advertisers, can utilize our Electronic Platform and they will  never be provided with Personal Identifiable Information. However, we do not control third parties’ collection or use of your information to serve interest-based advertising. These third parties may provide  you with ways to choose not to have your information collected or used in this way. You can opt out of  receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website,  available here: http://optout.networkadvertising.org/?c=1#!/ 

9. Accessing and Correcting Your Information. 

You can review and change your Personal Information by logging into the Electronic Platforms  and visiting your account profile page. 

You may also send us an email at account@possibilitycompany.com to request access to, correct  or delete any Personal Information that you have provided to us. We cannot delete your Personal  Information except by also deleting your user account. We may not accommodate a request to change  information if we believe the change would violate any law or legal requirement or cause the information  to be incorrect.] 

If you delete your User Contributions from our Electronic Platforms, copies of your User  Contributions may remain viewable in cached and archived pages, or might have been copied or stored by  other Electronic Platforms users. 

10. Your California Privacy Rights. 

This section is required under California law. California residents are entitled to information about  our practices regarding the sale of Personal Information. [We do not sell your Personal Information. If  at any time we begin selling Personal Information, we will update this Privacy Policy.]  

California Civil Code Section § 1798.83 permits users of our Electronic Platforms that are  California residents to request certain information regarding our disclosure of Personal Information to  third parties for their direct marketing purposes. To make such a request, please send an email to  privacy@possibilitycompany.com. 

11. Data Security. 

We have implemented measures designed to secure your Personal Information from accidental loss  and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored  on our secure servers behind firewalls.  

The safety and security of your information also depends on you. Where we have given you (or  where you have chosen) a password for access to certain parts of our Electronic Platforms, you are  responsible for keeping this password confidential. We ask you not to share your password with anyone. In  addition, we urge you to be careful about giving out information in public areas of the Electronic Platforms like message boards. The information you share in public areas may be viewed by any user of the Electronic  Platforms. 

Unfortunately, the transmission of information via the Internet is not completely secure and can  potentially be intercepted or incorrectly routed. Although we do our best to protect your Personal  Information, we cannot guarantee the security of your Personal Information transmitted to our Electronic  Platforms. Any transmission of Personal Information is at your own risk. We are not responsible for  circumvention of any privacy settings or security measures contained on any Electronic Platform. Please  consider this before submitting any information to us or through the Electronic Platforms.

 

12. Social Media. 

Any information, communications, or material of any type or nature that you submit to us through  a third party website including, but not limited to, any of our Electronic Platforms or accounts contained on  a social media platform or website such as Facebook, Instagram, LinkedIn, or Twitter, whether by e-mail,  posting, messaging, uploading, downloading, or otherwise (collectively, a “Submission”), is done at your  own risk and without any expectation of privacy. By visiting any of our social media accounts, you are  representing and warranting to us that you have reviewed the applicable social media platform’s or  website’s privacy policy and terms of use and that you will abide by all such provisions contained therein.  We cannot control the actions of the providers or the other users of any social media platform and we are  therefore not responsible for any content or Submissions contained on such platforms. We do not guarantee  the privacy and safety of these areas. We encourage you to be wary of providing any of your personal  information in such public forums. The information you submit can be collected and used by people you  do not know. Again, your use of these features and your Submissions are fully at your own risk. 

13. Monitoring and Enforcement. 

We have implemented various measures to monitor compliance with and enforce the elements in  this Privacy Policy, however, we expressly disclaim the obligation to monitor such compliance. If you  have a privacy related inquiry, complaint or dispute, please contact us at the postal address, telephone  number, or e-mail listed in Section Error! Reference source not found.

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