Effective Date: 04/01/2022

ThreeSixty Group and/or its affiliated companies (“ThreeSixty Group,” the “Company,” “we”, or “us”) is committed to respecting the privacy of the Personal Information we process. Please read this Privacy Policy (“Privacy Policy”) carefully to understand how we collect, use, and process Personal Information.

By visiting, accessing, or using our Services, you acknowledge and agree that you have received and read this Privacy Policy. The Company is the data controller with respect to all Personal Information processed subject to this Privacy Policy. We may update this Privacy Policy from time to time as described in the “Changes to this Privacy Policy” section below. If you have any questions, comments, or concerns please contact us at Privacy@thethreesixtyGroup.com.

If you are a California resident, please see the “California Privacy Notice” section below for information about your rights under the California Consumer Privacy Act of 2018 (“CCPA”).If you are a Nevada resident, please see the “Nevada Privacy Notice” section below for information about your rights under the Nevada Senate Bill 220.

TABLE OF CONTENTS:

1. SCOPE
2. WHAT PERSONAL INFORMATION WE COLLECT AND HOW
3. HOW WE USE PERSONAL INFORMATION
4. HOW WE SHARE PERSONAL INFORMATION
5. MARKETING PREFERENCES
6. YOUR CHOICES
7. COOKIES AND TRACKING TECHNOLOGIES
8. DO NOT TRACK PREFERENCES
9. THIRD PARTY SOCIAL PLUGINS
10. INTERNATIONAL DATA AND TRANSFERS
11. HOW WE PROTECT PERSONAL INFORMATION
12. HOW LONG DO WE KEEP PERSONAL INFORMATION
13. THIRD PARTY LINKS
14. CHILDREN’S PRIVACY
15. CALIFORNIA PRIVACY NOTICE
16. NEVADA PRIVACY NOTICE
17. CHANGES TO THIS PRIVACY POLICY
18. CONTACT US

1. SCOPE

This Privacy Policy applies to Personal Information that the Company collects, uses, shares, and otherwise processes when you:

• Access or use our website available at TheThreeSixtyGroup.com or any other website or online service operated or made available by the Company where this Privacy Policy is posted (collectively, the “Website”); or
• Communicate with us through any written, electronic, or oral communications, including by email, phone, or text message.

For the purposes of this Privacy Policy, we refer to our Website, and any other online product or service we provide that is covered by this Privacy Policy as the “Services.”

2. WHAT PERSONAL INFORMATION WE COLLECT AND HOW

As used in this Privacy Policy, “Personal Information” means any information that identifies or could be used to identify an individual person, which may include name, email address, and phone number. It also includes other non-public information that we associate with such identifying information. Personal Information does not include aggregated or anonymized information. We collect information, including Personal Information, directly from you and indirectly, as described below.

• Information You Provide to Us

We collect information that you provide directly to us when you access or use the Services or when you interact with us. We collect information that you provide to us in the following ways:

• Accessing or Using the Services: When you access or use the Services, such as browsing our Website, we collect information about your browsing activity, such as pages and items you view. We also collect certain information automatically when you access or use the Services, as described in the “Information We Collect Automatically” section below.
• Customer support requests and inquiries, forms, and questionnaires: If you contact us, such as by sending us an email using the email address provided on the Website or by calling us, we may collect your name, email address, phone number, and any other information you choose to provide with your request or inquiry. We may also collect information you provide if you complete surveys or questionnaires that we make available.
• Product reviews and feedback: If you submit a product review or feedback, we collect your name, email address, and any product rating and review information or any feedback you choose to provide.
• Marketing communications and newsletters: If you sign up to receive newsletters and marketing communication from us, we will collect your name and contact information, such as your email address.
• Interactions through social media: If you interact with us through any of our pages or feeds on any social media sites or platforms, such as Facebook or Instagram, we may collect information such as your name, username, demographic information, contact information such as email address, location, interests, and publicly posted data such as your social media activity.

You may choose not to provide information directly to us or to not use the Services. However, some Personal Information is necessary so that we can provide you with the Services you have requested. Failure to provide this information may prevent us from providing you with access to our Services.

• Information We Collect Automatically

When you access or use our Services, we or our third-party agents or service providers automatically collect information about the device you use to access the Services and your activity when you use the Services. Depending on your activity, the information may include:

• Device and Usage Information: We collect certain information about your device and how you interact with the Services each time you access or use them.
  • Device information may include your Internet Protocol (“IP”) address, browser type, unique device identifiers, information about your approximate location (as determined through your IP address), mobile, computer or device hardware information (e.g., operating system version, hardware model, IMEI number and other unique device identifiers, MAC address, and device settings), device event information, log information, and crash data.
  • Usage information may include referring / exit pages and URLs, how you interact with links on the Website, landing pages, pages viewed, features that you use, access dates and times, and other clickstream data.
• Cookies and Other Tracking Technologies: We and our third-party service providers or agents may collect information using one or more Cookies or similar technologies (collectively “Cookies”). Please refer to the “Cookies and Tracking Technologies” section below for more information about our use of Cookies and your choices related to Cookies.
• Information Collected from Third Parties

In some instances, we process Personal Information we receive from our service providers or agents who perform business services for the Company, such as Website information from third parties that assist us in operating our Website.

3. HOW WE USE PERSONAL INFORMATION

We use the information we collect in the following ways:

• To provide and operate our Services, including our Website;
• To update, improve, and/or enhance the Services, and develop new features, functionality, and products;
• To provide technical support for, secure, and protect the Services, including to detect and prevent fraud, abuse, or security risks, and to track outages and troubleshoot;
• To conduct analytics related to the Services;
• To market our Services and/or products that may be of interest to you;
• To manage contests and promotions ;
• To respond to your inquiries and requests, or otherwise communicate with you, and to provide you with assistance related to the Services;
• To provide updates about our Services and send you newsletters;
• To enforce our Terms and Conditions, resolve disputes or otherwise to carry out our obligations and enforce our rights, and to protect our business interest and rights of third parties;
• For our business transfers;
• To comply with legal and contractual obligations and requirements;
• To keep you updated about changes to policies relating to our Services (including this Privacy Policy); and
• For any other purpose with your consent.

We may combine any of the information that we collect from you with other information, including information that we obtain from third parties, or with information derived from any other products or services we provide. We will use this information for the purposes described in this Privacy Policy.

We process Personal Information for the legal bases listed below. The applicable legal basis depends on the Services you use and how you use them.

• To provide you the Services you’ve signed up for or requested and to perform our obligations under the applicable terms of use and service.
• Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests. For example, when we carry out fraud screening, improve or enhance the Services, or to market and promote the Services.
• Where we need to comply with a legal or regulatory obligation.
• If we have obtained your prior consent. Please note that for this specific legal basis, you have the right to withdraw your consent at any time, but this will not affect any processing that has already taken place.

4. HOW WE SHARE PERSONAL INFORMATION

We transmit, share, grant access, make available and provide Personal Information to or with the following types of third parties:

• Service Providers: We share Personal Information with our third-party vendors, consultants, agents, contractors, and service providers that help us provide our Services or with any of the purposes described in this Privacy Policy.
• Business Transfers: We may share Personal Information with third parties we choose to acquire or with buyers, successors, or others in connection with a merger, divestiture, restructuring, reorganization, financing due diligence, dissolution or other sale or transfer of some or all of our assets or transition of service to another provider, whether as a going concern or as part of bankruptcy, receivership, liquidation or similar proceeding, as permitted by law and/or contract.
• Compliance and Regulatory Purposes: We may share Personal Information if we believe that it is necessary to:
  • comply with a law, regulation, legal process, or legitimate governmental request;
  • protect the safety or security of the Services, users of the Services, or any person;
  • investigate, prevent, or take action regarding illegal or suspected illegal activities;
  • prevent spam, abuse, fraud, or other malicious activity of actors using or accessing the Services; or
  • protect our rights or property or the rights or property of those who use the Services.

Non-public information about our users will not be released to law enforcement except in response to an appropriate legal process such as a subpoena, court order, or other valid legal process that has been reviewed by the Company. However, if we receive information that provides us with a good faith belief that there is an exigent emergency, we may provide information to law enforcement trying to prevent or mitigate the danger (if we have it), to be determined on a case-by-case basis.

• With Your Consent: There may be situations where you are asked to consent to share Personal Information with third parties for additional reasons not included in this Privacy Policy.

5. MARKETING PREFERENCES

From time to time, we may use Personal Information to send you details of new products or services, updates, and other information that may be of interest to you . If you no longer want to receive marketing emails from us, you may opt-out by using the unsubscribe link that we include in our marketing emails. You can also manage your marketing preferences by emailing us at privacy@ThreeSixtyGroup.com with “unsubscribe” in the subject line together with the name of the publication you wish to unsubscribe from. We will complete your opt-out request as required under applicable law.

6. YOUR CHOICES

Depending upon the requirements of your local data protection and privacy laws, you may have the right to make the following requests to the Company:

• Access your Personal Information;
• Correct your Personal Information;
• Erase or transfer your Personal Information;
• Restrict processing of your Personal Information;
• Object to the processing of your Personal Information; and
• Withdraw your consent for processing of Personal Information.

We will respond in accordance with and as required under applicable data protection and privacy laws. To submit a request, please contact us using the information described below, and we will consider your request in accordance with applicable laws.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to help ensure that Personal Information is not disclosed to any person who has no right to receive it.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us.

7. COOKIES AND TRACKING TECHNOLOGIES

As described above in this Privacy Policy, we collect and may permit third parties to collect information using cookies and other technologies.

What Are Cookies?

Cookies are small data files that are placed on your device that are set by us or by third parties when you visit a website or other online service. The Company uses Cookies for purposes such as to provide content or features on our Services, help us remember you and your preferences, and improve your user experience by making our Services more efficient and relevant to you. You can find more information about cookies at: www.allaboutcookies.org.

In addition to Cookies, we use other technologies that are similar in function, such as pixel tags, also called web beacons or single-pixel tags/gifs, local or web storage, and other similar technologies.

• Web Beacons: Web beacons, or “clear gifs,” and single-pixel tags/gifs, or web tags, are tiny graphics with a unique identifier placed on a website or in an email that gather information about your interaction with that website or email. Because of their small size, they are not visible.
• Local or Web Storage: Local or web storage refers to a file that is stored locally on your device and is specifically used with video. It includes both your own device storage and browser cache.

We use the term “Cookie” throughout this Privacy Policy to cover all these technologies.

1. Types of Cookies

Cookies are often described by who created and placed them and how long they last. Types of Cookies generally include the following:

• Persistent Cookies and Session Cookies
  • Persistent Cookies: A persistent Cookie stays in your browser and will be read by us when you return. A persistent Cookie helps us recognize you as an existing user, so it is easier for you to return and interact with our Services.
  • Session Cookies: A session Cookie enables you to move from page to page on our Services and allows information that you enter to be remembered. A session Cookie is temporary and is deleted when you close your browser or after a short time.
• First-Party Cookies and Third-Party Cookies
  • First-party Cookies: These are Cookies set by the publisher of the website or online service you are visiting. First-party Cookies may be set either by us or by a service provider at our request.
  • Third-party Cookies: These are Cookies that are set by a party other than the publisher of the website you are visiting.

2. What Types of Information Do Cookies Collect?

Cookies collect different types of information depending on the type of Cookie and its purpose. Some examples of information that may be collected by Cookies when you use our Services include:

• The pages you visit within our Services;
• The buttons you click on our Services;
• The date and time you visit our Services;
• The amount of time you spend on our Services;
• The Internet Protocol (“IP”) address used to connect your computer/mobile phone to the internet; and
• Your device (such as computer, mobile phone) and connection information such as your browser type and version and operating system.

3. How Do We Use Cookies?

We, our service providers, and/or agents acting on our behalf, use the following types of persistent and session Cookies (which may be first-party or third-party Cookies) on our Services:

• Strictly Necessary Cookies: These Cookies are essential because they enable our Services to work properly, and they cannot be disabled. Without these Cookies, some of our Services cannot be provided. These Cookies do not gather information about you for marketing purposes. For example, these Cookies are used to:
  • Remember the information that you fill in when performing certain activities on our Services;
  • Pass information from one page to the next;
  • Read your browser and device settings to optimize the display of our Services;
  • Locate and identify misuse of our Services;
  • Load our Services uniformly to maintain accessibility; and
  • Authenticate users and prevent fraud.

4. How to Manage or Delete Cookies

You may alter the Cookie settings in your browser settings at any time. You may accept all or only certain Cookies. If you disable Cookies in your browser settings, however, you may find that certain sections of our Services will not work.

To learn more about Cookies, including how to manage Cookies and opt-out of Cookies being placed on your devices, please visit www.allaboutcookies.org.

8. DO NOT TRACK PREFERENCES

Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, the Website and Services do not currently respond to browser DNT signals.

9. THIRD PARTY SOCIAL PLUGINS

The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button and the Twitter “Follow” button), which let you share actions you take with other media. The use of such features may set a cookie or collect certain information about your device or your interactions with the Services when you interact with them. If you are logged in to your account with the third-party social media provider, the third party may be able to link information about your interactions with the Services to your account with them. You use these social sharing features at your own risk. No security measures, including the privacy settings referenced above, are perfect or impenetrable. We cannot and do not guarantee that the information you share using such features will not be viewed by unauthorized persons. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the third parties that provide these features.

10. INTERNATIONAL DATA AND TRANSFERS

The Services are intended for use only by individuals located in the United States. If you are not located in the United States, please be aware that the Personal Information that we collect or receive may be transferred to and processed in countries located outside of your country of residence to the countries where we or our third-party service providers operate.

11. HOW WE PROTECT PERSONAL INFORMATION

We take our responsibility to protect the security and privacy of Personal Information seriously. We have implemented what we believe to be reasonable and appropriate security measures designed to prevent Personal Information from being lost, used, accessed, altered, or disclosed in an unauthorized or unlawful way. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and we cannot and do not guarantee that Personal Information is completely secure and safe from such risks. By using the Services, you understand and assume the risks associated with your activities on the Internet.

If you have reason to believe that your information is no longer secure, please let us know by contacting us at privacy@ThreeSixtyGroup.com.

12. HOW LONG DO WE KEEP PERSONAL INFORMATION

We retain Personal Information for the purposes stated in this Privacy Policy. To determine how long we keep Personal Information, we consider the amount, nature and sensitivity of Personal Information, the reasons for which we collect and process the information and applicable legal requirements.

13. THIRD PARTY LINKS

We may provide links to other websites or resources with which we do not have a contractual relationship and over which we do not have control (“External Websites”). Such links are not paid advertisements, nor do they constitute an endorsement by the Company of those External Websites and are provided to you only as a convenience. By clicking on links to the External Websites, the operators of the External Websites may collect Personal Information. We are not responsible for the content or data collection practices of those External Websites, and your use of External Websites is subject to their respective terms of use and privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

14. CHILDREN’S PRIVACY

The Company does not knowingly solicit Personal Information from children or send them requests for Personal Information. If you are under sixteen (16), do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received Personal Information from a child under sixteen (16) without verification of parental consent, we will delete that information as required by applicable law.

15. CALIFORNIA PRIVACY NOTICE

This section supplements the information provided in this Privacy Policy and applies only to California residents who are within the scope of this Privacy Policy.

If you have any questions about your California privacy rights or the information provided in this section, please contact us at privacy@ThreeSixtyGroup.com.

• California Privacy Rights

If you are a resident of California, you have the following rights related to your personal information:

• The right to know – You have the right to know (a) the categories of personal information we’ve collected, (b) the categories of the sources from which the personal information is collected, (c) the business or commercial purposes for collecting the personal information, (d) the categories of third parties with whom we’ve shared personal information, and (e) the categories of personal information we’ve disclosed for a business purpose or sold and the third parties to whom we’ve disclosed or sold the personal information;
• The right to access – You have the right to receive a copy of the personal information we have collected;
• The right to delete your personal information – You have the right to request that we delete your personal information, subject to certain exceptions;
• The right to opt-out of sale of your personal information – You have the right to opt out of having your personal information sold; and
• The right against discrimination – You have the right not to be discriminated against because you have exercised your rights under California law.

For information on how to exercise your rights, please see the “Exercising Your California Privacy Rights” section below.

• Personal Information Categories We Collect:

For purposes of this section, “personal information” is used as defined under the California Consumer Privacy Act (“CCPA”) and means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular consumer or household. Personal information does not include:

• information that is lawfully made available from federal, state or local government records;
• anonymous, de-identified or aggregated information; and
• information excluded from the scope of the California Consumer Privacy Act of 2018 (“CCPA”), such as health or medical information covered under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and financial information covered under the Fair Credit Reporting Act (“FCRA”) or Gramm-Leach Bliley Act (“GLBA”).

When we talk about a “sale” of personal information or information being “sold,” we are also using that term as it is defined in the CCPA.

Below is a summary of the personal information categories, as defined by the CCPA, that we have collected in the last twelve (12) months, the business or commercial purposes for which we’ve used them, and the third parties to which we’ve disclosed them. Some of the information in several of the categories may overlap.

“Service Providers” means our third-party vendors, consultants, agents, contractors, and other service providers that perform services for us or on our behalf.

Categories of Personal Information	Sources of Personal Information	Purposes	Third Parties We Share it with
Identifiers (such as name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address)	Directly from youWe generate internallyFrom our Service Providers	To provide our Website and ServicesTo provide customer supportTo communicate with youTo improve and enhance our products and offerings and develop new onesFor our marketing purposesFor our security, anti-fraud, and legal and compliance purposesFor our internal analytics purposes	Service Providers
Personal Information under California Civil Code section 1798.80  (such as name, signature, Social Security number, physical characteristics or description, address, telephone number, employment history, credit card number, debit card number, or any other financial information)	Directly from youFrom our Service Providers	To provide our Website and ServicesTo provide customer supportTo communicate with youTo improve and enhance our products and offerings and develop new onesFor our marketing purposesFor our security, anti-fraud, and legal and compliance purposesFor our internal analytics purposes	Service Providers
Electronic network activity (such as browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement)	Directly from youWe generate internallyFrom our Service Providers	To provide our Website and ServicesTo provide customer supportTo communicate with youTo improve and enhance our products and offerings and develop new onesFor our security, anti-fraud, and legal and compliance purposesFor our internal analytics purposes	Service Providers
Audio, electronic, visual, thermal, olfactory, or similar information	Directly from youFrom our Service Providers	To provide our Website and ServicesTo provide customer supportTo communicate with youTo improve and enhance our products and offerings and develop new onesFor our security, anti-fraud, and legal and compliance purposesTo understand how our users interact with our Website and services	Service Providers
Inferences drawn from other personal information	Directly from youWe generate internallyFrom our Service Providers	To provide our Website and ServicesTo provide customer supportTo improve and enhance our products and offerings and develop new onesFor our marketing purposesFor our security, anti-fraud, and legal and compliance purposesFor our internal analytics purposes	Service Providers

For more information about the purposes for which we use personal information and the third parties with whom we share personal information, please see “How We Use Personal Information” and “How We Share Personal Information” in our Privacy Policy above.

• No Sale of Personal Information

The CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe that we engage in such activity. For clarity, we do not sell personal information of minors under sixteen (16) years of age.

EXERCISING YOUR CALIFORNIA PRIVACY RIGHTS

To exercise any of the rights described above, you or your authorized agent acting on your behalf may submit a request by:

• Submitting a request through our webform here; or
• Email at privacy@ThreeSixtyGroup.com.

To verify your identity, we may ask you to confirm personal information we already have on file for you. If we cannot verify your identity from the information we have on file, we may request additional information, which we will only use to verify your identity and for security or fraud-prevention purposes.

If you use an authorized agent to make a request on your behalf, we may require proof from you that they have been authorized directly by you to act on your behalf.

We will respond to your rights request as required under the CCPA.

We reserve the right to deny your request subject to applicable law, such as if we cannot verify your identity or the authority to receive the personal information related to you.

• California “Shine the Light” disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information with third parties for their direct marketing purposes. We do not currently share personal information with third parties for their own direct marketing purposes.

16. NEVADA PRIVACY NOTICE

Residents of Nevada have the right to opt-out of the sale of certain Personal Information to third parties in certain circumstances. Please note that we do not currently sell your Personal Information, as “sell” is defined under the Nevada law.

17. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. When we update this Privacy Policy, we will revise the “Effective Date” at the top of this Privacy Policy and post a link to the updated Privacy Policy on our Website. Changes to this Privacy Policy are effective when they are posted on this page. If we make any material changes, we will provide you with notice as required under applicable law. You are advised to review this Privacy Policy periodically to ensure you are aware of any such changes.

18. CONTACT US

The Company welcomes your comments regarding this Privacy Policy. If you have any questions about this Privacy Policy or our privacy practices or if you believe that we have not adhered to the Privacy Policy, please contact us by email at privacy@ThreeSixtyGroup.com.