Privacy Policy

GENERAL

Cultivate Belonging (“Company” or “we” or “us” or “our”) respects the privacy of its users (“user” or “you”)
that use our website located at https://cultivatebelonging.com/, including other media forms, media
channels, mobile website or mobile application related or connected thereto (collectively, the “Website”).
The following Company privacy policy (“Privacy Policy”) is designed to inform you, as a user of the
Website, about the types of information that Company may gather about or collect from you in connection
with your use of the Website. It also is intended to explain the conditions under which Company uses and
discloses that information, and your rights in relation to that information. Changes to this Privacy Policy
are discussed at the end of this document. Each time you use the Website, however, the current version
of this Privacy Policy will apply. Accordingly, each time you use the Website you should check the date of
this Privacy Policy (which appears at the beginning of this document) and review any changes since the
last time you used the Website.

The Website is hosted in the United States of America and is subject to U.S. state and federal law. If you
are accessing our Website from other jurisdictions, please be advised that you are transferring your
personal information to us in the United States, and by using our Website, you consent to that transfer
and use of your personal information in accordance with this Privacy Policy. You also agree to abide by
the applicable laws of applicable states and U.S. federal law concerning your use of the Website and your
agreements with us. Any persons accessing our Website from any jurisdiction with laws or regulations
governing the use of the Internet, including personal data collection, use and disclosure, different from
those of the jurisdictions mentioned above may only use the Website in a manner lawful in their
jurisdiction. If your use of the Website would be unlawful in your jurisdiction, please do not use the
Website.

BY USING OR ACCESSING THE WEBSITE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN
THIS PRIVACY POLICY.

GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION

Users of the Website Generally
“Non-Personally-Identifying Information” is information that, without the aid of additional information,
cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is
information such as a name or email address that, without more, can be directly associated with a specific
person. Like most website operators, Company gathers from users of the Website Non-Personally Identifying Information of the sort that Web browsers, depending on their settings, may make available.

That information includes the user’s Internet Protocol (IP) address, operating system, browser type and
the locations of the websites the user views right before arriving at, while navigating and immediately after
leaving the Website. Although such information is not Personally-Identifying Information, it may be
possible for Company to determine from an IP address a user’s Internet service provider and the
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geographic location of the visitor’s point of connectivity as well as other statistical usage data. Company
analyzes Non-Personally-Identifying Information gathered from users of the Website to help Company
better understand how the Website is being used. By identifying patterns and trends in usage, Company
is able to better design the Website to improve users’ experiences, both in terms of content and ease of
use. From time to time, Company may also release the Non-Personally-Identifying Information gathered
from Website users in the aggregate, such as by publishing a report on trends in the usage of the
Website.

Web Cookies
A “Web Cookie” is a string of information which assigns you a unique identification that a website stores
on a user’s computer, and that the user’s browser provides to the website each time the user submits a
query to the website. We use cookies on the Website to keep track of services you have used, to record
registration information regarding your login name and password, to record your user preferences, to
keep you logged into the Website and to facilitate purchase procedures. Company also uses Web
Cookies to track the pages that users visit during each Website session, both to help Company improve
users’ experiences and to help Company understand how the Website is being used. As with other Non Personally-Identifying Information gathered from users of the Website, Company analyzes and discloses
in aggregated form information gathered using Web Cookies, so as to help Company, its partners and
others better understand how the Website is being used. 

COMPANY USERS WHO DO NOT WISH TO
HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO
REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT
CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF
WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY
FOR ANY RESULTING LOSS OF FUNCTIONALITY.

Third-Party Advertisers
We may use third-party advertising companies to serve ads when you visit the Website. These
companies may use information (not including any Personally-Identifying Information) about your visits to
the Website and other websites that are contained in Web Cookies in order to provide advertisements
about goods and services of interest to you. Using a tool created by the Network Advertising
Initiative, you can opt out of several third-party ad servers’ and networks’ Web Cookies simultaneously. If
you would like more information about this practice and to know your choices about not having this
information used by these companies, please follow the following
links: http://networkadvertising.org/managing/opt_out.asp, http://preferences-mgr.truste.com/,
or http://www.aboutads.info/choices/. 

Please contact us if you would like to know the identity of the thirdparty advertising companies we are currently using to serve ads.

We may allow advertisers to choose the characteristics of users who will see their advertisements, and
we may use any of the Non-Personally Identifying Information we have collected (including information
you may have decided not to show to other users, such as your birth year or other sensitive personal
information or preferences) to select the appropriate audience for those advertisements. We do not
identify you to the advertiser.

Web Beacons
A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user
and allows website operators to check whether a user has viewed a particular web page or an email.
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Company may use Web Beacons on the Website and in emails to count users who have visited particular
pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users’
Personally-Identifying Information. They are a technique Company may use to compile aggregated
statistics about Website usage. Web Beacons collect only a limited set of information, including a Web
Cookie number, time and date of a page or email view and a description of the page or email on which
the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective
by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is
tendered, permitting you to accept or decline Web Cookies on an individual basis.

Analytics
We may use third-party vendors, including Google, who use first-party cookies (such as the Google
Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize
and serve ads based on your past activity on the Website, including Google Analytics for Display
Advertising. The information collected may be used to, among other things, analyze and track data,
determine the popularity of certain content and better understand online activity. 

If you do not want any
information to be collected and used by Google Analytics, you can install an opt-out in your web browser
(https://tools.google.com/dlpage/gaoptout/) and/or opt out from Google Analytics for Display Advertising
or the Google Display Network by using Google’s Ads Settings (www.google.com/settings/ads).

Aggregated and Non-Personally-Identifying Information
We may share aggregated and Non-Personally Identifying Information we collect under any of the above
circumstances. We may also share it with third parties and our affiliate companies to develop and deliver
targeted advertising on the Website and on websites of third parties. We may combine Non-Personally
Identifying Information we collect with additional Non-Personally Identifying Information collected from
other sources. We also may share aggregated information with third parties, including advisors,
advertisers and investors, for the purpose of conducting general business analysis. For example, we may
tell our advertisers the number of visitors to the Website and the most popular features or services
accessed. This information does not contain any Personally-Identifying Information and may be used to
develop website content and services that we hope you and other users will find of interest and to target
content and advertising.

SOCIAL MEDIA

We may use hyperlinks on the Website which will redirect you to a social network if you click on the
respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s
“tweet” button or the Google+, that particular social network’s plugin will be activated and your browser
will directly connect to that provider’s servers. If you do not use these buttons, none of your data will be
sent to the respective social network’s plugin provider. So for example, when you click on the Facebook’s
“Like” button on the Website, Facebook will receive your IP address, the browser version and screen
resolution, and the operating system of the device you have used to access the Website. Settings
regarding privacy protection can be found on the websites of these social networks and are not within our
control.

COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION

Website Registration
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As defined above, Personally-Identifying Information is information that can be directly associated with a
specific person. Company may collect a range of Personally-Identifying Information from and about
Website users. Much of the Personally-Identifying Information collected by Company about users is
information provided by users themselves when (1) registering for our service, (2) logging in with social
network credentials, (3) participating in polls, contests, surveys or other features of our service, or
responding to offers or advertisements, (4) communicating with us, (5) creating a public profile or (6)
signing up to receive newsletters. That information may include each user’s name, address, email
address and telephone number, and, if you transact business with us, financial information such as your
payment method (valid credit card number, type, expiration date or other financial information). We also
may request information about your interests and activities, your gender, age, date of birth, username,
hometown and other demographic or relevant information as determined by Company from time to time.
Users of the Website are under no obligation to provide Company with Personally-Identifying Information
of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website
features.

BY REGISTERING WITH OR USING THE WEBSITE, YOU CONSENT TO THE USE AND
DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS
“COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.

Online Postings
Certain Personally-Identifying Information collected from users may be disclosed as a matter of course as
a result of your use of the Website. We may provide areas on the Website where you can post reviews
and other information relating to your activities on the Website. Such postings are governed by our Terms
of Use. In addition, such postings may appear on other websites or when searches are executed on the
subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable
web pages, that information will be publicly available and can be collected and used by others. For
example, if you post your email address, you may receive unsolicited messages. We cannot control who
reads your posting or what other users may do with the information you voluntarily post, so we encourage
you to exercise discretion and caution with respect to your personal information. 

USERS ASSUME ALL
RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM THEIR
VOLUNTARY DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION.

Company Communications
We may occasionally use your name and email address to send you notifications regarding new services
offered by the Website that we think you may find valuable. We may also send you service-related
announcements from time to time through the general operation of the service. Generally, you may opt
out of such emails at the time of registration or through your account settings, though we reserve the right
to send you notices about your account, such as service announcements and administrative messages,
even if you opt out of all voluntary email notifications.

Company Disclosures
Company will disclose Personally-Identifying Information under the following circumstances:
• By Law or to Protect Rights. When we believe disclosure is appropriate, we may disclose
Personally-Identifying Information in connection with efforts to investigate, prevent or take other
action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the
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rights, property or safety of Company, our users, our employees or others; to comply with
applicable law or cooperate with law enforcement; to enforce our Terms of Use or other
agreements or policies, in response to a subpoena or similar investigative demand, a court order
or a request for cooperation from a law enforcement or other government agency; to establish or
exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such
cases, we may raise or waive any legal objection or right available to us.
• Marketing Communications. Unless users opt-out from receiving Company marketing materials
upon registration, Company may email users about products and services that Company believes
may be of interest to them. If you wish to opt-out of receiving marketing materials from Company,
you may do so by following the unsubscribe link in the email communications, by going to your
account settings (if applicable) or contacting us using the contact information below.
• Third-Party Service Providers. We may share your Personally-Identifying Information, which
may include your name and contact information (including email address) with our authorized
service providers that perform certain services on our behalf. These services may include fulfilling
orders, providing customer service and marketing assistance, performing business and sales
analysis, supporting the Website’s functionality and supporting contests, sweepstakes, surveys
and other features offered through the Website. We may also share your name, contact
information and credit card information with our authorized service providers who process credit
card payments. These service providers may have access to personal information needed to
perform their functions but are not permitted to share or use such information for any other
purpose.
• Business Transfers; Bankruptcy. Company reserves the right to transfer all Personally Identifying Information in its possession to a successor organization in the event of a merger,
acquisition, bankruptcy or other sale of all or a portion of Company’s assets. Other than to the
extent ordered by a bankruptcy or other court, the use and disclosure of all transferred
Personally-Identifying Information will be subject to this Privacy Policy, or to a new privacy policy
if you are given notice of that new privacy policy and are given an opportunity to affirmatively optout of it. Personally-Identifying Information submitted or collected after a transfer, however, may
be subject to a new privacy policy adopted by the successor organization.

Changing Personally-Identifying Information; Account Termination
You may at any time review or change your Personally-Identifying Information by going to your account
settings (if applicable) or contacting us using the contact information below. Upon your request, we will
deactivate or delete your account and contact information from our active databases. Such information
will be deactivated or deleted as soon as practicable based on your account activity and accordance with
our deactivation policy and applicable law. To make this request, either go to your account settings (if
applicable) or contact us as provided below. We will retain in our files some Personally-Identifying
Information to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce our
Terms of Use and to comply with legal requirements as is permitted by law. Therefore, you should not
expect that all your Personally-Identifying Information will be completely removed from our databases in
response to your requests. Additionally, we keep a history of changed information to investigate
suspected fraud with your account.

General Use
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Company uses the Personally-Identifying Information in the file we maintain about you, and other
information we obtain from your current and past activities on the Website (1) to deliver the products and
services that you have requested; (2) to manage your account and provide you with customer support; (3)
to communicate with you by email, postal mail, telephone and/or mobile devices about products or
services that may be of interest to you either from us, our affiliate companies or other third parties; (4) to
develop and display content and advertising tailored to your interests on the Website and other sites; (5)
to resolve disputes and troubleshoot problems; (6) to measure consumer interest in our services; (7) to
inform you of updates; (8) to customize your experience; (9) to detect and protect us against error, fraud
and other criminal activity; (10) to enforce our Terms of Use; and (11) to do as otherwise described to you
at the time of collection. At times, we may look across multiple users to identify problems. In particular, we
may examine your Personally-Identifying Information to identify users using multiple user IDs or aliases.
We may compare and review your Personally-Identifying Information for accuracy and to detect errors
and omissions. We may use financial information or payment method to process payment for any
purchases made on the Website, enroll you in the discount, rebate, and other programs in which you
elect to participate, to protect against or identify possible fraudulent transactions and otherwise as needed
to manage our business.

COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY

Company contractually prohibits its contractors, affiliates, vendors and suppliers from disclosing
Personally-Identifying Information received from Company, other than in accordance with this Privacy
Policy. However, third parties are under no obligation to comply with this Privacy Policy with respect to
Personally-Identifying Information that users provide directly to those third parties, or that those third
parties collect for themselves. These third parties include advertisers, providers of games, utilities,
widgets and a variety of other third-party applications accessible through the Website. Company neither
owns nor controls the third-party websites and applications accessible through the Website. Thus, this
Privacy Policy does not apply to information provided to or gathered by the third parties that operate
them. Before visiting a third party, or using a third-party application, whether by means of a link on the
Website, directly through the Website or otherwise, and before providing any Personally-Identifying
Information to any such third party, users should inform themselves of the privacy policies and practices
(if any) of the third party responsible for that website or application, and should take those steps
necessary to, in those users’ discretion, protect their privacy.

SECURITY

We take the security of your Personally-Identifying Information seriously and use reasonable electronic,
personnel and physical measures to protect it from loss, theft, alteration or misuse. However, please be
advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that
only authorized persons will view your information. We are not responsible for third-party circumvention of
any privacy settings or security measures.
We are dedicated to protect all information on the Website as is necessary. However, you are responsible
for maintaining the confidentiality of your Personally-Identifying Information by keeping your password
confidential. You should change your password immediately if you believe someone has gained
unauthorized access to it or your account. If you lose control of your account, you should notify us
immediately.

PRIVACY POLICY CHANGES

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Company may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to
Company’s Privacy Policy will be reflected on this page and the date new versions are posted will be
stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all
information that we have about you and your account. Users should regularly check this page for any
changes to this Privacy Policy. Company will always post new versions of the Privacy Policy on the
Website. However, Company may, as determined in its discretion, decide to notify users of changes
made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain
and update their contact information.

CHILDREN

The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13
years of age. We do not knowingly collect or maintain Personally-Identifying Information from anyone
under the age of 13, unless or except as permitted by law. Any person who provides Personally Identifying Information through the Website represents to us that he or she is 13 years of age or older. If
we learn that Personally-Identifying Information has been collected from a user under 13 years of age on
or through the Website, then we will take the appropriate steps to cause this information to be deleted. If
you are the parent or legal guardian of a child under 13 who has become a member of the Website or has
otherwise transferred Personally-Identifying Information to the Website, please contact Company using
our contact information below to have that child’s account terminated and information deleted.

CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who
are California residents to request and obtain from us, once a year and free of charge, information about
the Personally-Identifying Information (if any) we disclosed to third parties for direct marketing purposes in
the preceding calendar year. If applicable, this information would include a list of the categories of the
Personally-Identifying Information that was shared and the names and addresses of all third parties with
which we shared Personally-Identifying Information in the immediately preceding calendar year. If you are
a California resident and would like to make such a request, please submit your request in writing to our
privacy officer as listed below.

DO-NOT-TRACK POLICY

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or
setting you can activate to signal your privacy preference not to have data about your online browsing
activities monitored and collected. Because there is not yet a common understanding of how to interpret
the DNT signal, the Website currently does not respond to DNT browser signals or mechanisms.

CONTACT

If you have any questions regarding our Privacy Policy, please contact our Victoria Lopez at:

Cultivate Belonging
Email: tori@cultivatebelonging