Last Updated: March 13, 2023

California Privacy (See Section 16 below)

European Privacy (See Section 15 below)

Active Media Services, Inc. d/b/a Active International (and its affiliates, collectively referred to herein as  “Active,“ “we“ or “our“ or “us”) recognizes the importance of data privacy and respects your data privacy rights. This Privacy Statement applies to our public facing website: https://www.amsgrowthpartner.top/ and unless stated otherwise any other website that we own, license, or operate and that links this Privacy Statement (each of the foregoing collectively referred to as a “Site”).

This Privacy Statement describes the types of personal information that we collect via the Site as a “data controller” (which means we determine the purpose and means of processing such personal information), the purposes for which we use it, the types of third parties with whom we share it, and any rights and responsibilities you may have with respect to such personal information.

For purposes of this Privacy Statement, the Site and all goods and services offered, sold and/or furnished by us pursuant to our business through the Site are referred to collectively as the “Services.”

PLEASE READ THIS PRIVACY STATEMENT CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. BY ACCESSING OR USING THE SERVICES OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TERMS OF THIS PRIVACY STATEMENT, OUR TERMS & CONDITIONS AND OUR COOKIE DECLARATION.

You must be at least eighteen (18) years of age to access the Services. Active is headquartered in the United States, and the personal information you provide to Active may be processed and stored in the United States and other jurisdictions. For more information on our data transfer practices, please see Section 9 (Data Retention and Localization).

1.   What Constitutes Personal Information

The term “personal information” (which may from time to time be referred to herein as “personal data” depending upon the applicable privacy law(s)) means any information that, alone or in conjunction with other information, identifies or is linked to a particular individual or household and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation.  The term “personal information” (and “personal data”) does not include anonymized or de-identified data that is not attributable to a particular individual or household and that is not otherwise subject to a data protection law, statute, or regulation. We commit not to re-identify data that has so been de-identified.  We may also anonymize or de-identify personal information, and such information is not subject to this Privacy Statement, and we may use such data for any purpose.

The terms “sensitive” personal information (or “sensitive” personal data) refers to the various categories of personal information identified by applicable data privacy laws as requiring special treatment, including in some circumstance the need to obtain explicit consent from you.  These categories include your (a) government and/or state identifiers, e.g. Social Security, passport and driver license; (b) account or debit or credit card numbers combined with passwords or codes to enable access; (c) exact geolocation information, e.g. street, city/state and zip code; (d) racial or ethnic origin, religious or philosophical beliefs, information about sex life or sexual orientation, union membership, or political opinions; (e) contents of mail, email, or text messages, unless we are the intended recipient of the communication; (f) genetic data and biometric information; and/or (g) health information. 

We do not generally seek to collect “sensitive” personal information through this Site or provision of Services.  In the limited cases where we do seek to collect sensitive information, we will do this in accordance with applicable data privacy laws and/or ask for your consent.

2.  The Types and Categories of Personal information We Collect

Active collects personal information in order to provide our Services, comply with our legal obligations, promote our business interests, and for the other reasons set forth in this Privacy Statement. When you do not provide personal information to us, we may not be able to provide you the Services or to complete a transaction you requested.  Generally, we collect the following types and categories of personal information during our business operations:

Personal information
Category	Description/Examples
Personal Identifiers	Identifiers, such as your name, pronoun, alias, shipping address, email address, account name, telephone number, customer identification number, when necessary for specific purposes gender, date of birth, age, place of birth.
Registration Data	Information provided by you by filling in forms on Site, including when you register for an account to use the Site, subscribing for Services, registering to receive a white paper, or newsletter or other marketing materials, including usernames and passwords.
Online Identifiers (For more information, see “Technical Data” below)	Persistent identifiers that can be used to recognize you or your device over time and across different services, including a device identifier, an Internet Protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifiers, and similar technology.
Commercial Information	Records of the Services you purchased, obtained, or considered, or your other purchasing histories or tendencies with respect to our Services.  Correspondence between you and us when it is sent to a dedicated mailbox for the purpose of processing account receivable payments and commercial follow-up
Business Contact Data	Information related to employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct, or possibly conduct, business activities.
Internet and Electronic Network Data	Data pertaining to your access or use of the Site, including browsing history, search history, and information regarding your interaction with the Site, and information derived from any device that connects to our WiFi services.
Your Feedback	Information you provide about our Services, which may include data gathered from any of our surveys or reviews submitted by you.
Video and Images	In some circumstances, you may provide us images (e.g., your attendance at one of our events) or we may record you via a video camera (e.g., on-premises security systems) or through video teleconferencing.
Geolocation Data	Information about the general city, state, or region in which a user of the Site is located. Please see Section 3 (Technical Data) for more details regarding our use of cookies.
Professional or Employment Data. For more information, see Section 22 below (Employment Applications and Talent Management)	If you apply for a job with us, we collect information set forth in a resumé, curriculum vitae, cover letter, and similar documentation, including contact details, employment history, skills, or qualifications, education-level, job compensation and benefit preferences, criminal record, credit history and similar data, and information provided about or by your references.
Sensitive Personal information
Professional or Employment Data. For more information, see Section 22 below (Employment Applications and Talent Management)	If you apply for a job with us we collect information about your race and ethnicity, proof of citizenship, e.g. driver’s license or passport, details of residency or work permit, and health/medical information. We use this information to comply with our internal policies, our legal obligations and judicial, regulatory, administrative, or other corporate requirements, including laws relating to antidiscrimination, immigration and providing  reasonable accommodations for any individuals with special needs or disabilities.

Active may also collect, but does not store, credit card information when you place an order.

3.  Technical Data

When you access the Site, we collect certain data automatically using technical means and tools. This data relates to your device, as well as your experience on the Site and other websites, including the following:

Usage and Device Data. When you access and use the Site, we automatically collect details of your access to and use of the Site, including traffic data, usage logs and other communication data, and the resources that you access and use on or through the Site (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. The Site may collect “diagnostic” data related to your use of the Site, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.

Cookies and Tracking Data. We use “cookies” and other tracking technologies within the Site. A cookie is a small file placed on your smartphone or other device. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting, some parts of the Site may become inaccessible or not function properly. In addition, the Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on your use of the Site (e.g., recording the popularity of certain content and verifying system and server integrity). The Site may collect data about the advertisements you have seen or engaged. For more information, see our Cookie Declaration.

Site Monitoring. Please be aware that we use cookies and other tracking technologies within the Site to monitor and record any and all activities and communications to, from, and on, the Site in order to safeguard, improve, and analyze usage of, the Site, and for the other purposes listed in this Privacy Statement. For the avoidance of doubt, you hereby acknowledge, agree, and consent to, such monitoring and recording. 

4.   Sources of Data

We collect the personal information identified herein directly from you when you use our Services, through automated means when you are using the Site, and from third parties. More specifically, we collect personal information from the following sources:

First Party / Direct Collection. We collect personal information directly from you when you use our Services (e.g., registering accounts, completing transactions, signing up for newsletters, or participation in our contests or sweepstakes), or whenever you directly engage with us, such as when you visit our offices or premises or otherwise contact us.

Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use the Site (see “Technical Data” above).

Third-Party Sources. We collect personal information from third parties, such as publicly available databases, social networking providers, advertising companies, our service providers, and third-party references.

5.  How We Use Your Data / Purpose of Collection

We may use the personal information We collect about you in order to perform our Services, comply with our legal obligations, and promote our business interests.

How Your Personal information Is Used

Provide, operate, maintain, improve, promote and customize our Services, including sharing of your personal information with trusted third parties for such purposes. This is necessary to enable us to pursue our legitimate interests in understanding how our Services are being used, create efficiencies and to explore ways to develop and grow our business.

Enable you to access and use our Services.

Process and complete transactions and perform our obligations under our contracts with you, or to provide goods and services as requested by you, and send you related information, including purchase confirmations and invoices. Active may make a customer’s shipping address and payment information directly available to a vendor of products or services the customer wishes to obtain. By making a purchase (example: a hotel reservation), you are directing us to share your personal information in this way. Please see our Travel Site Privacy Policy for information about how we used your personal information when you access and use, or make travel requests, reservations, or bookings  at our website www.travel.activeinternational.com.

Respond to lawful requests by public authorities, to protect, establish or exercise our legal rights or defend against legal claims or to prevent, investigate or take action regarding suspected fraud or violations of our policies. In these cases, our use of your personal information may be necessary for the purposes of our or a third party’s legitimate interest in keeping our Services secure, preventing harm or crime, enforcing or defending legal rights or preventing damage.

Send you messages and communications related to our Services (e.g., responses to your comments, questions, and requests, customer services).

Furnish technical notices, updates, security alerts, and support and administrative messages to you about our Services.

Provide you promotional and marketing communications (e.g., information about our Services, features, surveys, newsletters, offers, promotions, contests, and events).

Like most companies, we use customer relationship management (CRM) database technology to manage and track our marketing efforts. Our CRM databases include personal information  of clients and prospects used for business purposes, such as: contact data, publicly available information, responses to targeted emails, e.g. unsubscribes, and other business information included by Active professionals based on their personal interactions with you.

Process and deliver Reward Program (as defined in Section 21 below) entries and rewards, including confirming eligibility and providing any Services.

Web analytics and statistics to monitor and analyze trends, usage, and activities in connection with our Services to promote our business interests.

For security purposes to enhance protection, investigate and prevent misuse and/or fraudulent transactions, unauthorized access to or use of our Services, and other illegal activities.

Personalize our Services, including providing features that match your interests and preferences.

For recruitment/employment purposes in order to comply with legal obligations and internal policies, see  Section 22 below “Employment Applications and Talent Management”.

We may collect and use your personal information for any other purpose for which we obtain your consent.

We also may derive inferences about you based on the information described above and also collect other information about you as described in this Privacy Statement. If you provide us with personal information of another person (for instance, a potential employee/referral), you are responsible for ensuring that such person is made aware of the information contained in this Privacy Statement and that the person has given you his/her consent for sharing the information with Active.

6.   Sharing Information / Third-Party Disclosures

We may share your personal information with certain organizations and third parties in accordance with applicable law, including as set out below. However, we do not share personal information with third parties that we have reason to believe use such information for their own direct marketing purposes.

Category of Recipient	Purpose of Disclosure
Transaction Partners	We may share your personal information with third party businesses and organizations with whom we facilitate a transaction at your request or fulfill our contractual obligations to you under a contract.
Service Providers	We may share your personal information with companies that provide services on our behalf, such as hosting and analyzing the Site, conducting surveys and marketing on our behalf, processing transactions, providing research and analytics, and security and customer management software to help us operate, provide and market our Services.
Payment Card Transactions	All payments for purchases made through the Site are completed using a third-party vendor’s online payment system.  We do not have access to your credit card information and do not store or disclose your full credit card information. Any personal or financial information you provide to our online payment system is subject to the third party’s privacy policy and terms of use, and we recommend you review these policies before providing any personal or financial information.
Vendors of Services, Business Partners	We may share your personal information with third parties that provide Services you have purchased from us and to comply with our contractual obligations to such third parties.
Business Transfers	Circumstances may arise where, for strategic or other business reasons, we decide to sell, buy, divest, merge or otherwise reorganize our businesses. We may share your personal information and other information with third parties in connection with a sale, merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by us about users of the Services is among the assets transferred.
Legal; Compliance; Legitimate Interests	We may disclose personal information and other information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to comply with our contractual obligations; (d) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (e) to enforce contractual obligations and our terms and conditions Terms and Conditions; (f) to protect our operations or those of any of our affiliates; (g) to defend or protect our legal, regulatory, business interests, rights, privacy, safety or property, and/or that of our affiliates, you, or others; (h) in urgent circumstances to protect the health and personal safety of any individual, and (i) to allow us to pursue available remedies or limit the damages that we may sustain.
Consent.	In addition to the reasons for disclosure set forth herein, we may also disclose your personal information upon your consent.

In the event that you enter into a contract with us, or facilitate a transaction with us, or request information from or otherwise engage with us, and such activities require us to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct us to intentionally disclose your personal information to the service provider or third party.

7.         Social Media

We may engage with you on various social media platforms (e.g., Facebook, Twitter, LinkedIn, Pinterest, Instagram). If you contact us on a social media platform for customer support or for other reasons, we may contact you via the social media’s direct message tools. Certain social media platforms may also automatically provide us with your personal information, the information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. The Site includes social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini-programs that run on the Site. These features may collect your IP address and which Site page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.

8.         Links to Other Websites; Your Direct Third-Party Disclosures

As a resource to you, the Site may include links to third-party websites or provide you the opportunity to disclose information directly to third parties (e.g., credit card processors). Our Privacy Statement does not apply to such third-party websites or organizations. You assume all privacy, security, and other risks associated with providing any data, including personal information, to third parties via the Services. For a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.

9.  Data Retention and Localization

The period during which we retain your personal information varies depending on the purpose for the data processing. For example, we retain personal information needed to provide you with our Services, fulfill our contractual obligations to you under a contract, facilitate transactions you have requested, to comply with our legal obligations (e.g., tax filings, export control laws), to engage in marketing activities, and for as long as is necessary to defend our legal or business interests and/or until such time as our contractual relationship with you ceases or the legal retention periods expire or where you have consented to our use of your personal information, until such time as you withdraw consent. In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Statement.

Active is headquartered in the United States, out Site is hosted in the United States, and the personal information that we collect and process is retained and stored in the United States. Active uses service providers that store personal information on our behalf in the United States and in other third countries. Please be aware that the United States, and these other third countries, may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States or elsewhere, your personal information may be accessible by, or otherwise made available to, local government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations. By continuing to provide us such information, you hereby acknowledge and agree that your personal information will be transferred to, and stored in, the United States and in such other third countries.  If you are accessing our Site from outside the United States, you are transferring your personal information to the United States and you consent to such transfer. If you do not want your personal information transferred to the United States, you should not share your information with us or make use of this Site. Please note that personal information transferred to the United States is subject to access by law enforcement.

10.       Security

We seek to protect the security of your personal information and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE, AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE SITE AND/OR THE SERVICES OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION CAUSED BY A THIRD PARTY. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our Services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately (and in any event within twenty-four (24) hours) if you have reason to believe that your username or password to our Services has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.

11.  No Data Collected from Children

The Site is not directed at, nor intended for use by, children. As a result, if you are under the age of eighteen (18), you are prohibited from accessing or using the Services (including the Site) or with providing us with your personal information.

12.   Your Responsibilities

You are permitted, and hereby agree, to only provide personal information to Active if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO US, YOU EXPRESSLY REPRESENT AND WARRANT TO US THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE US WITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT OUR USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY US AND EACH COMPANY EMPLOYEE, OFFICER, AND AGENT FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO US.

13 .   Updating Your Information

It is important that the personal information that you provide to us is accurate and reliable. In certain circumstances, you may have the ability to directly edit your account to update and change your personal information (e.g., name, telephone number, email, shipping address), and you must do so when such changes are warranted. You may request changes to, or deletion of your account with us by emailing us at privacy@activeinternational.com.

14.   Canada Privacy Rights

Personal data (as the term is defined in the Personal Data Protection and Electronic Documents Act of Canada (“PIPEDA”)) will be collected, stored, used and/or processed by Active in accordance with this Privacy Statement and Active’s obligations under PIPEDA and other applicable Canadian provincial laws. Pursuant to these Canadian laws, you have a right to request access to your personal data and to request that inaccurate personal data be corrected. If you have submitted personal data to us and would like to have access to it, or have it corrected, please contact us in accordance with the “Contact Us” section listed below. When requesting access to, or correction of, your personal data, we will require that you verify our request via email, and we will request specific data from you to enable us to confirm the authenticity of the request and your identity, and to enable us to search our records and databases. We may charge you a fee to access your personal data, provided that we advise you of any such fee in advance. Your right to access personal data is not absolute, and we may not be able to allow you to access certain personal data in certain circumstances (e.g., if the information contains personal data of other persons or it is subject to legal privilege). In the event that we cannot provide you with access to, or the ability to correct, your personal data, we will use reasonable means to inform you of the reasons why, subject to any legal or regulatory restrictions. To delete your name from our electronic contact lists, please contact us in accordance with the “Contact Us” section listed below. If you have concerns with our data processing, you may file a complaint with the Office of the Privacy Commissioner of Canada. For more information about the Office of the Privacy Commissioner of Canada, please access its website.

15. European Union (EU), Switzerland, and United Kingdom (UK)

Data Protection Rights. If you are located in the EU, Switzerland, or the UK, you have the following data protection rights:

• Right to Know. The right to know about what personal data we collect and process about you, including the types and categories of personal data we collect and process, the sources of such personal data, our retention criteria, with whom we share your personal data, cross-border data transfers, and how to file complaints and inquiries. Such information is set forth in this Privacy Statement.
• Automated Decision Making. We do not engage in any activity that subjects our customers, Site users, survey participants, or others to a decision based solely on automated processing, including profiling, which produces legal effects, or similarly significant results, impacting them.
• Access Rights. You may ask us whether we process any of your personal data and, if so, receive access to such personal data. When complying with an access request, we will also provide you with additional information, such as the purposes of the processing, the categories of personal data concerned as well as any other information necessary for you to exercise the essence of this right.
• Rectification. You have the right to have your personal data corrected/rectified in case of inaccuracy or incompleteness. Upon request, we will correct inaccurate personal data about you and, taking into account the purposes of the processing, update any incomplete personal data, which may include the provision of a supplementary statement.
• Erasure. You have the right to have your personal data erased, which means the deletion of your personal data by us and, where possible, any other controller to whom your data has previously been disclosed. However, your right to erasure is subject to statutory limits and prerequisites (e.g., where your personal data is no longer necessary in relation to the initial purposes for which it was processed, your personal data was processed unlawfully).
• Restriction of Processing. You have the right to obtain the restriction of the processing of your personal data, which means that we suspend the processing of your personal data for a certain period of time. Circumstances which may give rise to this right include situations where the accuracy of your personal data is contested, but we need time to verify the inaccuracy (if any) of your personal data.
• Data Portability. You have the right to request us to provide you with your personal data in a structured, commonly used and machine-readable format and to have such data transmitted directly to another controller, where technically feasible.
• Right to Object. You have the right to object to the processing of your personal data, which means you may request us to no longer process your personal data. This only applies in case the “legitimate interests” ground (including profiling) constitutes the legal basis for processing (see below “Legal Basis for Processing”). However, at any time (and free of charge) you can object to having your personal data processed for direct marketing purposes.
• Withdrawing Consent. You also may withdraw your consent at any time if we are solely relying on your consent for the processing of your personal data. However, this will not impact our legal basis to process such personal data prior to the withdrawal of your consent.

To exercise any of these data privacy rights, please contact us, or have your designated agent contact us, in accordance with the “Contact Us” section listed below. To the extent permitted by law, we will need to verify your identity (or the identity of your agent) and ensure the authenticity of your request.

Legal Basis for Processing. We process your personal data in accordance with the legal bases set forth in law. For example, our processing of personal data (as described herein) is justified based on the following legal grounds:

• Consent. Processing is based on your consent (e.g., you register to receive our marketing materials, you voluntarily contact us).
• Legitimate Interests. Processing is necessary for our legitimate interests as set out herein (e.g., monitoring your use of the Site and your compliance with the terms and conditions governing the same, improving our Services).
• Contract Undertaking. Processing is necessary for the performance of a contract to which you are a party (e.g., you purchase or consider purchasing our Services).
• Legal Compliance. Processing is required to comply with a legal or statutory obligation (e.g., tax disclosures).

Complaints. In the event you have concerns about our data processing, you have the right to file a complaint with your data protection authority. For data protection authorities in the EU, please see here: https://edpb.europa.eu/about-edpb/about-edpb/members_en. For the data protection authority in Switzerland, please contact the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home.html). For the data protection authority in the UK, please contact the Information Commissioner’s Office (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach a data protection authority with a complaint, and invite you to contact us in the first instance.

16 . California Privacy Rights

Data Privacy Rights. Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), California residents are entitled to certain data privacy rights:

• (Specific Pieces of Personal Information). You have the right to know the specific pieces of your personal information that we have collected about you.
• (Categories of Personal Information). You have the right to know (i) the categories of personal information we have collected from you; (ii) the categories of sources from which the personal information is collected; (iii) the categories of your personal information we have sold or disclosed for a business purpose; (iv) the categories of third parties to whom your personal information was sold or disclosed for a business purpose; and (v) the business or commercial purpose for collecting or selling your personal information.
• You have the right to request that we delete your personal information that we have collected and retain.
• You have the right to request that we correct inaccurate personal information that we have collected and retain.
• You have the right not to be subject to discrimination for asserting your rights under the CCPA.

Submit a Privacy Request. To submit a privacy request, you may contact us using any of the following means: (email) privacy@activeinternational.com, (mail) Active Media Services, Inc., ATTN: Data Privacy, One Blue Hill Plaza, Pearl River, NY 10965, or (interactive webform) Webform. An authorized agent must be registered with the California Secretary of State to conduct business in California.

Privacy Request Verification Process. If you (or your authorized agent) make any request related to your personal information, we will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, we will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email, request certain contact information or government identifiers, and we will match at least two pieces of such personal information with data that we have previously collected from you before granting you access to, erasing, or correcting, specific pieces or categories of personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein, unless you have provided the authorized agent with power of attorney pursuant to California Probate Code §§ 4121 to 4130. None of the CCPA’s rights are absolute, and such rights are subject to legal and regulatory exceptions and exemptions. For more information about the CCPA, please see: https://oag.ca.gov/privacy/ccpa.

Opt-Out Rights / Do Not Sell My Personal Information. California residents have the right to opt out of the “sale” of their personal information. However, we do not sell your personal information to third parties for profit or monetary or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).

Opt-Out Rights / Do Not Share My Personal Information. California residents have the right to opt out of the “sharing” of their personal information. The Company uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners, and such features, tools and marketing relationships involve the disclosure of your personal information to third parties and may constitute the “sharing” of your personal information for CCPA purposes. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Privacy Choices” or a “Do Not Sell/Share My Personal Information” link on the footer of the Site) to set your cookie preferences. You, or your authorized agent, may also contact us in accordance with the “Contact Us” section listed below.

Children. The Site is not directed at, and should not be used by, minors under the age of sixteen (16), and therefore we do not knowingly sell or share the personal information of minors under sixteen (16) years of age.

Limit Use of Sensitive Personal Information. The Company does not use or disclose sensitive personal information for reasons other than those set forth in the CCPA, and therefore we do not provide individuals with the ability to limit how we use or disclose such sensitive personal information.

17.  Virginia Privacy Rights

Data Privacy Rights. Pursuant to the Virginia Consumer Data Protection Act, Virginia residents are entitled to certain data privacy rights:

Submit a Privacy Request. To submit a privacy request, you may contact us using any of the following means: (email) privacy@activeinternational.com, (mail) Active Media Services, Inc., ATTN: Data Privacy, One Blue Hill Plaza, Pearl River, NY 10965, or (interactive webform) Webform.

Privacy Request Verification Process. If you make any request related to your personal information, we will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, we will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email, request certain contact information or government identifiers, and we will match at least two pieces of such personal information with data that we have previously collected from you before granting you access to, erasing, or correcting, specific pieces or categories of personal information, or otherwise responding to your request. None of Virginia’s privacy rights are absolute, and such rights are subject to legal and regulatory exceptions and exemptions. For more information regarding the Virginia Consumer Data Protection Act, please see: https://lis.virginia.gov/cgi-bin/legp604.exe?211+ful+SB1392ES1.

Privacy Requests Appeals Process. If you would like to appeal a decision we have made with respect to your privacy request, please email privacy@activeinternational.com with the subject line “PRIVACY REQUEST: APPEALS” and describe the nature of your request, and the reason requesting an appellate review.

Opt-Out Rights / The Sale of Personal Information. Virginia residents have the right to opt out of the “sale” of their personal information. However, we do not sell your personal information to third parties for or monetary consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).

Opt-Out Rights / Targeted Advertising. Virginia residents have the right to opt out of having their personal information used for targeted advertising purposes. The Company uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Privacy Choices” or a “Do Not Sell/Share My Personal Information” link on the footer of the Site) to set your cookie preferences.

Opt-Out Rights / Profiling. Virginia residents have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, we do not engage in such activities.

18.  Nevada Privacy Rights

The Company does not currently conduct “sales” of personal information for purposes of Nevada law. Notwithstanding the foregoing, Nevada residents may submit a request directing us to not sell personal information we maintain about them to third parties who will sell or license their information to others. If you would like to exercise this right, please contact us in accordance with the “Contact Us” section listed below.

19.  Do-Not-Track Signals

Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.

20.  Persons with Disabilities

Active strives to ensure that every person has access to information related to our Services, including this Privacy Statement. In case you have special accessibility needs and would like this Privacy Statement provided in an alternative format, please contact us at privacy@activeinternational and we will seek to meet your needs.

21        Sweepstakes; Contests; Rewards; Donation Programs and Financial Incentives

We collect and use personal information, including personal information provided by a third party (e.g., refer-a-friend program), to administer and maintain any of our sweepstake, contests, rewards, donation, give-aways and/or financial incentive programs (collectively “Rewards Programs”). We use the personal information you provide in these programs to verify your identity, offer unique rewards, track your program status, and facilitate the provision of reward and/or Services, promotional materials, marketing and business offerings, and other items. If you consent to participate in any of our Rewards Programs, you may withdraw that consent at any time by contacting us in accordance with the “Contact Us” section listed below or in accordance with the instructions set forth in the applicable Rewards Program’s terms and conditions. We may use personal information gathered from, or related to, participants in our Rewards Programs for any other purpose or in any other manner set forth in this Privacy Statement.

California Rewards Program Rights. Pursuant to the CCPA, you may be entitled to be informed as to why financial incentive programs, or price or service differences, are permitted under the law, including (i) a good-faith estimate of the value of your personal information that forms the basis for offering the financial incentive or price or service difference, and (ii) a description of the method we used to calculate the value of your personal information. Generally, we do not assign monetary or other value to personal information. However, in the event we are required by law to assign such value in the context of Rewards Programs, or price or service differences, we have valued the personal information collected and used as being equal to the value of the discount or financial incentive provided, and the calculation of the value is based upon a practical and good-faith effort often involving (i) the categories of personal information collected (e.g., names, email addresses), (ii) the transferability of such personal information for us and our Rewards Programs, (iii) the discounted price offered, (iv) the volume of consumers enrolled in our Rewards Programs, and (v) the product or service to which the Rewards Programs, or price or service differences, apply. The disclosure of the value described herein is not intended to waive, nor should it be interpreted as a waiver to, our proprietary or business confidential information, including trade secrets, and does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards.

22.   Employment Applications and Talent Management

As part of our recruitment and talent management process, we collect personal information with respect to individuals who are interested in working for us. In this context, we collect employment and application data, such as the following: contact information (e.g., name, title, residential or postal address, telephone number, and personal email address); information in a curriculum vitae, resumé, cover letter, or similar documentation; details regarding the type of employment sought, willingness to relocate, job compensation and benefit preferences; health data (e.g., medical conditions); information related to your background, education, criminal record, credit history and similar data; information provided about or by your references or other third parties related to your employment history, skills, qualifications, or education; and information related to previous applications to us or previous employment history with us. When permitted by law, we may collect sensitive personal information about your race and ethnicity, proof of citizenship, details of residency or work permit, and health/medical information. We use this information for the following purposes: to identify and evaluate job applicants; to verify your information; to complete employment, education, background and reference checks; to communicate with you about the recruitment process and your application; to comply with our internal policies and our legal, obligations and judicial, regulatory, administrative, or other corporate requirements, including relating to antidiscrimination, immigration and providing reasonable accommodations for any individuals with special needs or disabilities; to analyze and improve our application and recruitment process; and to protect the rights, interests, and property of our business, other job applicants, employees, or the public, as required, or permitted, by law. We share this personal information with third parties (see Section 6 (Sharing Information / Third-Party Disclosures), and we may also use this employment and application data for any other purpose set forth in this Privacy Statement.

23.  Events and Video Teleconferencing

We host and use video teleconferencing platforms to facilitate conferences, meetings, training events, and other programs. We often use online platforms that are owned and administered by a third-party service provider (e.g., Microsoft Teams, Google, Zoom, WebEx, Skype for Business). Please be aware that our video teleconferencing may record the content, conversations, and discussions thereon, and such records may be stored or retained by our third-party service providers. By participating in our events and video teleconferencing, you hereby consent to the collection and retention of any information provided therein, and you hereby consent to the recording of such activities.

24.  Your Choices

If you do not wish to receive promotional or marketing emails from us, you can unsubscribe by using the unsubscribe link included in each such email or newsletter. In some cases we may provide an unsubscribe link within an operational email (e.g., surveys).

25.  Changes to this Privacy Statement

We reserve the right to amend this Privacy Statement at any time. We will notify you if this Privacy Statement is amended by updating the “Last Updated” section listed above. It is your responsibility to periodically review the Privacy Statement to determine whether any amendments have been made hereto. Your use of the Services, and continued use of the Services after any amendments are made to this Privacy Statement, signifies your consent to this Privacy Statement and any amendments hereto. We may, in our sole discretion, provide you communications, including via email or text messages, about changes to our Privacy Statement; however, such communications do not abrogate or otherwise limit your responsibility to periodically review the Privacy Statement to determine whether any amendments have been made hereto. Your continued use of the Services after the effective date of the revised Privacy Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your personal information in a manner materially different from what was stated at the time your personal information was collected.

26. Contact Us

If you have questions regarding this Privacy Statement or our handling of your personal information, would like to request more information from us, or would like to exercise a data privacy right, please contact us at the following: (email) privacy@activeinternational.com, (mail) Active Media Services, Inc., ATTN: General Counsel/Data Privacy, One Blue Hill Plaza, Suite 900, Pearl River, NY 10965, or (interactive webform) Webform.