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1. Introduction

(Toggle Network, we, us, or our) operates the Toggle web extension, dashboard application, desktop application, mobile application, and related hardware, including as made available through our website (the Website, and together with our web extension, dashboard, desktop application, the Toggle Network) that permit users to participate in gaining rewards by contributing in building Toggle Network Ecosystem that facilitates access to and use of web data (the Toggle Network).

The purpose of this Privacy Policy is to help you understand what types of personal information we collect, use, and disclose in connection with your access to and use of the Toggle Services and participation in the Toggle Network.

2. What is personal information?

Personal information is any information about, relating to, or that identifies a specific individual. Under certain laws that may apply to you, personal information may also include information that identifies a specific household or device.

3. Personal information that we collect

We may collect personal information from you based on the Toggle Network that you elect to access and use. The personal information that we collect from you in connection with your use of the each of the Toggle Network includes the following:

  • Contact and identification information, such as your email address, username, password, and any referral codes that you have been provided by us in connection with your use of the Toggle Services.
  • Your location information.
  • Any other personal information that you choose to provide to us when you contact us for support, provide us with feedback, or otherwise communicate with us.

4. Other information that we collect

In addition to the personal information that we collect from you, we collect information about your use of the Toggle Network and participation in the Toggle Network, the operating system of your device, application IDs, the type and version of your browser, crash data and analytics, other device identifiers, and other information relating to the manner in which you access or use the Toggle Network or participate in the Toggle Network.

5. Use of your personal information

We use the personal information that we collect to communicate about the functionality, features, products that we are building on and through the Toggle Network and to enable us to manage, maintain, and develop our operations. For example, we may use your personal information for the following purposes:

  • Establish, maintain, and manage our relationship with you, including by assisting you to create an account, communicate with us, and provide you with the services that you request.
  • Support the Toggle Network by permitting our users and customers to leverage the Toggle Network to facilitate their access to and use of web data.
  • Allow you to participate in, subscribe to, and receive information, news, updates, and promotional materials from us and third parties.
  • Comply with your requests and preferences regarding your use of the Toggle Network and how we communicate with you.
  • Understand your preferences and values so that we can build and offer better services and communications to you.
  • Protect us against error, fraud, theft, and damage to our Services, business, and property.
  • Conduct research, analysis, evaluation, and development activities to understand the way the Toggle Network are used and to improve the Toggle Network, Toggle Network, and our general operations, including with respect to the development of new products, services, and opportunities.
  • Enable us to comply with applicable laws and regulatory purposes.
  • Any other reasonable purpose to which we may notify you of, or to which you consent.

Unless you are based in the EEA or UK, by consenting to our collection, use, and disclosure of your personal information on and through the Toggle Network you allow us to fulfill the purposes for which we collect and use your personal information as described above. For more information about how we use your personal information if you are based in the EEA or UK, including the legal bases we may rely on to process your personal information as an alternative to obtaining your consent, please see the EEA and UK section of this Privacy Policy.

6. Promotional and transactional communications

We will collect your consent prior to sending you promotional emails and other electronic messages (e.g., texts, direct messages), unless an exception to obtaining your consent applies under applicable laws. You will have an opportunity to opt-out or unsubscribe from receiving promotional messages from us at any time. Promotional messages include, but are not limited to, our newsletter and updates about our and our partners' businesses, products, and services.

By using the Toggle Network, you agree to receive transactional communications about your account and activities. For example, when you create an account or reset your password, you may receive an email confirming the details of such activity. You may not opt-out of receiving these transactional communications.

7. Disclosure of personal information

We may disclose your personal information and other information in the manner and for the purposes that are described in the sections below.

  • Opportunity to receive rewards. We offer rewards based on points accumulated based on your usage of Toggle Network.

8. Retention of personal information

We do not keep your personal information forever. We will retain your personal information such as email ID to communicate alerts, marketing emails, and messages for as long as is reasonably necessary for us to complete our dealings with you, or as may be required by law, whichever is longer.

10. Security and protection of personal information

We endeavor to maintain commercially reasonable physical, technological, and procedural safeguards that are appropriate based on the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal, or destruction.

Please reach us through foundation@metoggle.ai immediately of any incident involving the loss of or unauthorized access to or disclosure of your personal information that is relevant to your use of the Toggle Network.

11. Access to personal information

You can ask to access the personal information that we have about you. If you want to review, verify, delete or correct your personal information, please contact us at foundation@metoggle.ai. We may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you.

If you require assistance in preparing your request, please contact us at foundation@metoggle.ai. Your right to access the personal information that we hold about you is not absolute. There are situations where applicable law allows or requires us to refuse to provide some or all of the personal information that we hold about you. In addition, your personal information may have been destroyed, erased, or made anonymous in accordance with our record retention practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions. If you are based in the EEA or the UK, you have other rights with respect to your access to and correction of the personal information we hold about you. Please see below for our policy on how we process your personal data.

12. Consent; withdrawal of consent

Unless you are based in the EEA or UK or you advise us otherwise, through the access and use of our website and Services, you have consented to the collection, use, and disclosure of your personal information as explained in this Privacy Policy.

For further information about how we process your personal information if you are based in the EEA or UK, including the legal bases we may rely on to process your personal information as an alternative to obtaining your consent, please see the EEA and UK section of this Privacy Policy.

13. Cookies

We use cookies and tracking technologies that are similar to cookies. A cookie is a small file of letters and numbers that we may set on your device to store and sometimes track information about you. Cookies and similar technologies we use are designed for analytics. This allows us to distinguish you from other users of our Website. This also helps us to provide you with a good experience when you use our Website.

We may use the following types of cookies on our Website:

  • Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to remember information you have typed into an online form.
  • Analytical/performance cookies: They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies: These are used to recognize you when you return to our website. This enables us to remember your preferences.
  • Targeting cookies: These cookies record your visit to our website, the pages you have visited, and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

15. Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time. These changes may be made as a result of changes to our legal obligations or the ways in which we collect, use, disclose, or otherwise process your personal information. We will post an updated version of our Privacy Policy on our website when we make changes and may also notify you of the changes we have made if we are required to do so by applicable law. We encourage you to check this Privacy Policy for updates on a regular basis.

You agree that by continuing to use the Toggle Network or participate in the Toggle Network after an update to our Privacy Policy, you agree to accept and consent to the collection, use, and disclosure of your personal information as described in the updated version of the Privacy Policy.

16. Contact information

If you have any questions or concerns regarding this Privacy Policy, you should contact our Privacy Officer at foundation@metoggle.ai. Please be aware that if you choose to communicate with us via email, email is not a 100% secure medium for sending any personal or confidential information to us.

17. Privacy Notice for Users Based in the EEA and UK

This section is applicable to you only if you are based in the EEA or the UK. To the extent there is any inconsistency in this Privacy Policy between any terms of this section and any terms in the rest of the Privacy Policy, the terms of this section will govern if you are based in the EEA or the UK. This section of the Privacy Policy includes information that is specific to how we process the personal information of users who are based in the EEA and the UK.

For the purposes of the General Data Protection Regulation as it applies both in the EEA and the UK (GDPR), Toggle Network is a data controller and can be contacted using the details in section 16 of this Privacy Policy above.

Toggle Network is a 'data controller' subject to the GDPR only insofar as we are offering goods or services to individuals in the EEA / UK or where the Toggle Network may be used to monitor individuals' behavior as far as their behavior takes place in the EEA or UK.

18. Our legal bases for using personal information

Data controllers need a lawful basis to collect and use your personal data under the GDPR. In respect of the data processing undertaken by Toggle Network, the relevant lawful bases on which we rely to process your personal data include:

  • Performing a contract with you: Where the processing of your personal data is necessary to provide you with access to and use of the Toggle Network in accordance with our Terms and Conditions. Some or all of the personal data that you provide to us is necessary to perform our obligations under our Terms and Conditions, and without this personal data, we may not be able to provide you with certain services, products, communications, and opportunities, including access to and use of the Toggle Network and/or participation in the Toggle Network.
  • Our legitimate interests: We process your personal data for the purpose of operating our business responsibly and sustainably. For example, where we send you administrative or transactional information regarding the Toggle Network and changes to our Terms and Conditions, procedures, or policies.
  • Consent: We may process your personal data on the basis of having obtained your consent. For example, if we send you marketing materials by email, this will be because you consented to this.
  • Legal compliance: We may process your personal data in the manner necessary to comply with our legal obligations. For example, where we need to comply with statutory, financial reporting, or other regulatory compliance obligations.

19. How long do we retain your personal data

We will keep your personal data for no longer than is necessary for the purposes for which it is processed. The length of time that personal data will be kept may depend on the reasons for which we are processing the data and on the applicable laws or regulations that the information falls under, such as financial regulations, statutory limitation periods, or any contractual obligation we might have.

If you request to receive no further contact from us, we will keep some basic information about you on our suppression list to avoid sending you unwanted materials in the future.

20. Data transfers outside of the EEA and UK

In the course of providing you with access to and use of the Toggle Network, we may transfer your personal information outside of the EEA or UK, including to the United States. This means that your personal data will not have the automatic protection of data protection laws, including the GDPR, which apply in the EEA and UK.

In these circumstances, to ensure that your personal data continues to have adequate protection when it is transferred outside of the EEA or UK, your personal data will only be transferred on one of the following bases:

  • A European Commission or UK government decision provides that the country or territory to which the transfer is made ensures an adequate level of protection and adopted by the UK following its exit from the European Union.
  • Where the transfer is subject to one or more of the appropriate safeguards for international transfers prescribed by applicable law (e.g., the standard data protection clauses adopted by the European Commission and, in the case of the UK, by the Information Commissioner's Office).
  • There exists another situation where the transfer is permitted by applicable law (for example, where we have your explicit consent).

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA / UK by contacting us using the details set out above.

21. Your rights in relation to your personal data

Under the GDPR, you have the following rights in relation to our processing of your personal information. Please note that these rights are not absolute, and we may be entitled or obliged to refuse requests where exceptions or exemptions apply:

  • To obtain access to, and copies of, the personal data that we hold about you.
  • To require us to correct the personal data we hold about you if it is incorrect.
  • To require us to erase your personal data in certain circumstances.
  • To require us to restrict your data processing activities in certain circumstances.
  • To object, on grounds relating to your particular situation, to any of our particular processing activities where you believe this has a disproportionate impact on you.
  • To receive from us the personal information we hold about you, which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal information to another data controller.
  • Where our processing of your personal data is based on your consent, you may withdraw your consent, without affecting the lawfulness of our processing based on the consent before its withdrawal. If you have given your consent and you wish to withdraw it, please contact us using the contact details set out above. Please note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services.

If you are not satisfied with how we are processing your personal information, you can make a complaint to a data protection supervisory authority in the UK (namely, the Information Commissioner's Office, whose website is here:'https://ico.org.uk) or in the EU, including the data protection regulator in the EU country where you or your organization is located. A list of data protection authorities in the EU is available here: https://www.edpb.europa.eu/edpb_en.