GrowthZone and ChamberMaster/MemberZone Privacy Policy

Last updated: January 2023

1. Introduction

1.1 This is the privacy policy that applies to our Sites, Software and our Services. GrowthZone has a strong commitment to safeguarding the privacy of our website visitors and customers’ personal information. Personal information is information about an identifiable individual. Publicly available information, such as a public directory listing of your name, address, telephone number, or electronic address, is not considered to be personal information.

Additional Notice to California Residents. California law permits residents of California to request certain details about how their personal information is shared with third parties or affiliated companies for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at: gzsupport@growthzone.com and include “My California Privacy Rights” in the subject line. Please note that if you opt out of receiving marketing communications from us, we may still send communications to you about your transactions and any accounts you have with us.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of [our website visitors and service users]; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 In this policy, "we", "us" and "our" refer to Micronet, Inc., DBA as GrowthZone and ChamberMaster.

2. Credit

2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).

3. How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;

(b) the purposes for which we may process personal data; and

(c) the legal bases of the processing.

3.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

3.3 We may process your account data ("account data"). The account data may include your name, organization and email address. The source of the account data is you, your employer, or an organization that is providing a service to you and using our software for the management of that service. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.4 We may process your information included in your personal profile on our website or within our software ("profile data"). The profile data may include your name, address, telephone number, email address, profile pictures, professional bio, IP address. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely to provide our products and services, for billing, for identification and authentication, for the general operation and improvement of our service, and to respond to inquiries, and is not used, shared with or sold to other organizations, except: to our service providers, as required to operate the Site and provide the products or services you’ve requested; to the applicable customer of the account in respect of which contact information is submitted to us; for collection purposes; to law enforcement agencies, in emergencies, for internal security matters, or where required by court order or search warrant; or when we have your permission. We do not contact our customers’ contacts except as related to operating the Site (for example: event notifications and reminders, membership renewals, security and other notifications). We may also disclose personal information in connection with the transfer to the acquirer upon the change of control.

3.5 We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website and business.

3.6 We may process information contained in any inquiry you submit to us regarding goods and/or services ("inquiry data"). The inquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent. Additionally, we access other lists generated from advertising, email inquiries, trade shows and conferences.

3.7 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website or software ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business. We may also record your computer’s IP address with your order to help us identify fraudulent credit card use. We may share this information with the financial institution that issued the credit card with which an order was placed or with law enforcement authorities if we determine, or are notified, that the use of the credit card was fraudulent.

3.8 We may process information that you provide to us for the purpose of subscribing to email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.9 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

3.10 We may process any of your personal data identified in this policy where necessary for [the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.11 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.12 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

4. Providing your personal data to others

4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. By accepting this privacy policy, you give consent for your data to be shared with these parties.

4.2 Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. By accepting this privacy policy, you give consent for the transaction data described above to be shared.

4.3 In addition to the financial transaction data listed in 4.2, we support optional integrations with 3rd party sub-processors. All integrations are opt-in integrations where no personal data is forwarded unless enabled and configured by you, the customer. Below is a list of available integrations (including those aforementioned in section 4.2) where personal data is forwarded to a data sub-processor if enabled by you. Only the most basic of information necessary for the intended function of each integration is shared with sub-processors and integrations can be independently enabled or disabled at any time. Our list of sub-processors may change at any time based on business need and will be reflected by an update to this section of our privacy policy.

4.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.5 We do not disclose your data to other third-party sources beyond what is outlined in section 4 without your expressed consent. In the context of an onward transfer of data under the aforementioned criteria, we acknowledge responsibility for the processing of personal information we receive under the Privacy Shield and subsequently transfer to a third party acting as an agent, including proper usage and protection under the principles of the Privacy Shield except in cases where Micronet has proven to not be responsible for processing inconsistent with Privacy Shied Principles and therefore is held harmless.

4.6 If you object to or have questions regarding the conditions laid out in section 4 dealing with the sharing of your data with 3^rd parties, you may contact us in writing at gzsupport@growthzone.com or support@chambermaster.com or at the address in section 13 to exercise your rights as described in section 8.

5. International transfers of your personal data

5.1 We have offices and facilities in the United States.

5.2 The hosting facilities for our website and software are located in the United States. The European Commission has made an "adequacy decision" with respect to the data protection laws of this country herein called the Privacy Shield Framework.

5.3 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

7. Amendments

7.1 We may update this policy from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3 We may notify you of changes to this policy by email or through messaging on our website.

8. Your rights

8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.10 If you consider that our processing of your personal information infringes data protection laws and requests to GrowthZone have not led to resolution, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. This, in some cases and under certain conditions, may include the possibility of invoking binding arbitration. A Dispute Resolution Provider is available at https://www.jamsadr.com/eu-us-privacy-shield.  You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.12 You may exercise any of your rights in relation to your personal data by written notice to us. This can easily be done via sending an email to gzsupport@growthzone.com for GrowthZone customers or support@chambermaster.com for Chambermaster customers. You may also provide notice via the mailing address in section 13.

8.13 Additional Rights and Choices for California Residents. If you are a California resident, the following additional rights may be available to you.

Shine the Light.

Customers who are California residents may request (i) a list of categories of personal information disclosed to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please send us an email or a letter to the addresses in section 13 below and specify you are making a "California Shine the Light” request. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

California Consumer Privacy Act of 2018 (CCPA)

Beginning January 1, 2020, the CCPA provides California residents with additional rights as described below. Please note your right to know and right to delete are subject to certain exceptions under the CCPA.

Notice of Collection. During the past 12 months, we may have collected the following categories of personal information that the CCPA covers (detailed in section 3 above):

• Usage data
• Account data
• Profile data
• Publication data
• Inquiry data
• Transaction data
• Notification data
• Correspondence data

This privacy statement includes additional information about our data practices. For more information on information we collect, including the sources we receive information from, review the "How We Use Your Personal Data" section. We collect and use these categories of personal information for the business purposes described.

Right to Know. You have the right to know certain information about our data practices in the preceding 12 months. You have the right to request the following information from us:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose or sold;
• The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
• The business or commercial purpose for collecting or “selling” the personal information; and
• The specific pieces of personal information we have collected about you.

Right to Delete. You have the right to request the deletion of personal information that we collect or maintain about you and your account.

Right to Opt Out of “Sale”. Micronet does not sell information as the term "sell" is traditionally understood. However, Micronet may disclose certain information about you when you use services for purposes that may be considered a “sale” under the CCPA. For example, we may disclose information to advertising partners, advertising technology companies, and companies that perform advertising-related services in order to provide you with more relevant advertising tailored to your interests. This information may include identifiers such as your IP address, advertising identifiers, commercial information, your internet or other electronic network information such as your interaction with an ad, geolocation data and inferences. To the extent Micronet sells your personal information as the term "sell" is defined under the CCPA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by emailing us at support@growthzone.com or call our toll-free number at 800-825-9171. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

Please note that if you opt out of receiving marketing communications from us, we may still send communications to you about your transactions and any accounts you have with us. If you wish to exercise any of the rights set above, please contact us. We will need you to provide specific information to help us confirm your identify. This is a security measure to help ensure that your personal information is not disclosed to someone that does not have the right to receive it.

9. About cookies

9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10. Cookies that we use

10.1 We use cookies for the following purposes:

(a) authentication - we use cookies to identify you when you visit our website and as you navigate our website;

(b) status - we use cookies to help us to determine if you are logged into our website;

(c) analysis - we use cookies to help us to analyze the use and performance of our website and services.

11. Cookies used by our service providers

11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.

12. Managing cookies

12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version.

12.2 Blocking all cookies will have a negative impact upon the usability of many websites.

12.3 If you block cookies, you will not be able to use all the features on our website.

13. Our details

13.1 This website is owned and operated by Micronet, Inc., DBA GrowthZone and/or ChamberMaster.

13.2 Our principal place of business is at 4837 County Road 77, Nisswa, MN 56468, USA.

13.3 You can contact us:

(a) by mail, to the postal address given above;

(b) using our website contact form;

(c) by the contact number published on our website from time to time; or

(d) by email, using the email address published on our website from time to time.

13.4 Micronet, Inc. is subject to the investigatory & enforcement powers of the Federal Trade Commission (FTC)

14. Data protection officer

14.1 Our data protection officer's contact details are: Jason Mueller via the contact means given above.