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I. Introduction

Last Rev, LLC ("Company") values your privacy and is committed to maintaining your trust. We provide this Privacy Policy to inform you of our policies and procedures regarding the collection, use, and disclosure of personally identifiable information received from users of this website located at www.lastrev.com (the "Website") and in connection with all of the Company's web and application development, content management system integrations, SAAS integrations, and optimization and experimentation services (the "Services").

II. General Data Protection Regulation

This Company is headquartered in California. As a California-based company, we do not knowingly advertise in the European Union (EU), or market our Services to residents of the EU. However, our Website does not restrict visitors from the EU; we do not have in place any protections to prevent EU residents from accessing our Website. As a result, we provide the foregoing disclosure to EU data subjects.

The Company's processing of the Personal Information, such as the name, address, email address, or telephone number of an EU data subject (hereinafter, "Personal Information" or "Personal Data") that is voluntarily supplied by the individual, or supplied by an authorized third party, shall always be in line with the General Data Protection Regulation ("GDPR"), and in accordance with the country-specific data protection regulations applicable to the Company.

By means of this Privacy Policy, our Company would like to inform you of the nature, scope, and purpose of the Personal Information we collect, use and process, as defined herein. Specifically, if you are an EU data subject visiting our Website or downloading our App, you are hereby informed, by means of this section of our Privacy Policy, of the rights to which you are entitled, and the recourse you may seek if you have any questions regarding the collection, use, and processing of Personal Information by the Company.

Your Privacy Rights under the GDPR

The GDPR includes the following rights for you, as an EU data subject, if you provide Personal Information to the Company in connection with accessing the Services or visiting our Website:

  • The right to be informed about how we store, use, or share your data
  • The right to access your data
  • The right to rectify your data
  • The right to have us erase your data
  • The right to prevent us from processing your data
  • The right to request copies of your data from us in a commonly-used and machine-readable format, free of charge, for the purposes of transfer to a third party, where technically feasible
  • The right to object to use or sharing of your data
  • The right not to be subject to automated decision-making, including profiling

Legitimate Business Interest under the GDPR

Our use of your Personal Information is based on the legitimate business grounds that:

  • The use is necessary in order to fulfill our commitments to you under our Terms of Service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our Website on your device or charge you for our Services
  • The use is necessary for compliance with a legal obligation
  • The use is necessary in order to protect your vital interests or those of another person or entity
  • We have a legitimate interest in using your information — for example, to provide and update our Website or Services, to improve our Website or Services so that we can offer you an even better user experience, to safeguard our Website or Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience
  • You have given us your consent

Data Retention/Erasure

We will retain your Personal Information for as long as needed to provide the applicable Services, or for a minimum period of four (4) years. If, at any time after agreeing to this Privacy Policy, you: (1) change your mind about receiving information from us; (2) wish to revoke permission for us to retain and use your Personal Information; (3) wish to object to the processing of your Personal Information; or (4) wish for us to erase a copy of your data, please make a request to the Company at privacy@lastrev.com. If you request erasure of your data, we may retain some of your Personal Information only for legitimate business interests, such as fraud detection, prevention, and enhancing the safety of our Website; and to comply with our legal obligations, specifically our tax, legal reporting, and auditing obligations.

Our Response to Your Requests

If you make any requests regarding your Personal Information, we will not charge you for compliance with the request. The Company will respond and comply within one month. The Company reserves the right to refuse or charge for requests that are manifestly unfounded or excessive. If we refuse your request, we will tell you why we are refusing your request. You have the right to complain to the relevant supervisory authority and to a judicial remedy, but you must do so within one month of our refusal.

Data Controller

With the exception of processing payments, for which a separate entity may be the Payments Data Controller; the Company is the "data controller," as defined under the GDPR, or the legal entity which determines the purposes and means of the processing of Personal Information of the customers of the Company and visitors to its Website. The Company is responsible for collecting your consent, managing consent-revoking, enabling right to access, etc. If you wish to revoke consent for us to store, use, or share your Personal Information, you may contact us at privacy@lastrev.com.

Data Processor

The Company is the "data processor," as defined under the GDPR, or the legal entity which processes your Personal Information. The Company has not retained any third-party service provider to process your Personal Information. Any processing of Personal Information shall be done solely by the Company. The Company maintains records of any processing activities it performs, and is able to show how the Company complies with the data protection principles under the GDPR. It has effective policies and procedures in place. If you have questions regarding the processing of your Personal Data, you may contact us at privacy@lastrev.com.

Data Protection Officer

The Company is not formally required to designate a Data Protection Officer ("DPO") because it is not: (1) a public authority; (2) an organization that carries out regular and systematic monitoring of individuals on a large scale; or (3) an organization that carries out large scale processing of special categories of data, such as health information or information about criminal convictions. If you have questions regarding data protection compliance and your Personal Data, you may contact us at privacy@lastrev.com.

Breach

The Company has reasonable internal policies and procedures in place to effectively detect, report, and investigate a data breach. The GDPR defines a Personal Information breach as "a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Information." Pursuant to the GDPR, the Company will notify you of a Personal Information breach where the Personal Information breaches are likely to present a risk to data subjects to data protection authorities ("DPAs") without undue delay, and within 72 hours if feasible, after becoming aware of the breach; and communicate high-risk breaches to affected data subjects without undue delay. In the unfortunate event of breach, the Company shall provide you with: (i) contact details of the DPO or other contact person for the Company, (ii) a description of the nature of the breach, (iii) likely consequences of the breach, (iv) measures the Company has taken or proposes to take to address the breach, and (v) advice on steps data subjects can take to protect themselves.

Data Protection Impact Assessment (DPIA)

The Company is not required to undergo a DPIA because the Company's data processing is not likely to result in a high risk to data subjects, such as in cases where: (1) new technology is being deployed; (2) profiling operations may significantly affect individuals; or (3) processing is on a large scale and involves special categories of data. If you have any questions regarding DPIA compliance by the Company, please contact the Company's Data Protection Officer.

Complaints

Without prejudice to any other administrative or judicial remedy, every EU data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of Personal Information relating to him or her infringes this Regulation.

III. Use, Processing, and Sharing of Personal Information

The following information applies to anyone who shares with us his, her, or a third-party's Personal Information. We may use, process, and/or share your Personal Information (and we have done so in the past 12 months):

  • To respond to your inquiries and your requests regarding our Website or Services
  • To send you information regarding our services and changes to our terms, conditions, and policies
  • To complete your Website registration, process your payments, and communicate with you regarding your purchase of our Services
  • To send you marketing communication and newsletters about our Services
  • To personalize your experience on our Website
  • To inform you and allow you to participate in our Company's events
  • To facilitate social sharing functionality
  • To collaborate with business affiliates, partners, vendors, or service providers to provide you with our Services
  • In connection with our business purposes, including but not limited to data analysis, audits, fraud monitoring and prevention, developing or enhancing new and existing products and/or services, expanding our business activities, etc.

We will not use and/or share your Personal Information with anyone except for our Company's authorized service providers, business affiliates, and business partners, and strictly for business purposes; or unless we specifically inform you, and give you an opportunity to opt out of our sharing your Personal Information.

However, we reserve the right to disclose Personal Information that we believe, in our sole discretion, to be necessary or appropriate in the following circumstances:

  • As required by law, such as to comply with a subpoena, or similar legal process
  • When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request
  • To enforce our Terms and Conditions
  • To allow us to pursue available remedies or limit the damages that we may sustain

IV. Collection of Other Information

Passively Collected Information

Your visit to our Website may allow us to obtain certain additional, personally non-identifiable information that is collected passively using various technologies. This information includes but is not limited to, for example, IP addresses, browser types, date and time of page views, location information associated with your IP address, domain names, your interactions to an ad delivered by us or our ad technology partners and other anonymous statistical data involving your use of the Website and/or our services. This information cannot presently be used to specifically identify you.

Aggregated Personal Data

The Company may analyze your Personal Information provided through the Website or in connection with rendering the Services, in aggregate form. This aggregate information does not identify you personally. We may share this aggregate data with our partners, affiliates, agents, or service providers for business purposes. We may also disclose aggregated statistics to explain our Services to current and prospective business partners, and to other third parties for other lawful, business-related purposes.

V. Website Tracking

We may, either directly or through third party companies and individuals we engage to provide services to us, also:

  • Track your use of our Website and the Services for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, etc.
  • Track your behavior on our own Website and use of the Services to market and advertise our services to you on our Website platform and third party websites. You may opt out of receiving advertisements by visiting the Network Advertising Initiative and/or the Digital Advertising Alliance.

VI. Tracking Technologies on our Website

Cookies

When you visit our Website or otherwise interact with the Service, we may send one or more "cookies" to your computer or other devices. Cookies are alphanumeric identifiers stored on your computer through your web browser and are used by most websites to help personalize your web experience. Some cookies may facilitate additional site features for enhanced performance and functionality such as remembering preferences, allowing social interactions, analyzing usage for site optimization, providing custom content, allowing third parties to provide social sharing tools, and serving images or videos from third party websites. Some features on this site will not function if you do not allow cookies. We may link the information we store in cookies to any Personal Information that you submit while visiting our Website.

We may use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. Persistent cookies enable us to track and target the interests of our users to enhance the experience on our site.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to allaboutcookies.org. If you reject cookies, you may still use our site, but some features on the site will not function properly.

Web Beacons

Web beacons are electronic files that signal when a webpage, advertisement, video, other content, an email or newsletter has been viewed. We may use web beacons alone or in conjunction with cookies to compile information about our Service.

Log Files

A Log File is a file that records either events that occur in an operating system or other software runs, or messages between different users of a communication software. We and our third party tracking-utility partners may use log files on our Service to gather automatically gather and store information including, but not limited to, internet protocol ("IP") addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data, for business purposes. We may use Google Analytics, which uses cookies and other similar technologies to collect and analyze information about the use of the Service. You can learn about Google's practices at google.com/policies/privacy/partners, and opt out by downloading the Google Analytics opt-out browser add-on.

Embedded Scripts

An embedded script is a programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.

Browser Fingerprinting

Collection and analysis of information from your Device, such as, without limitation, your operating system, plugins, system fonts and other data, for purposes of identification.

ETag

ETag, or entity tag, is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash and/or HTML5 cookies.

VII. Children

The Children's Online Privacy Protection Act of 1998 (COPPA) and its accompanying FTC regulation protects the privacy of American children aged 13 and under, who are using the Internet. The GDPR sets the age at which an EU child can give their own consent in order to process their Personal Data at 16 years of age.

The Website and our related Services are not intended for anyone under 16, and we do not knowingly collect information from anyone under the age of 16. Anyone aged 16 or under should not submit any Personal Information without the permission of their parents or guardians. By using the Website and our related Services, you are representing that you are at least 16 years old.

VIII. Links to Other Websites

This Privacy Policy does not address, and we are not responsible for the privacy, information or other practices of any third parties. This Privacy Policy applies only to this Website and the Company's Services. It does not apply to any third-party sites, and the inclusion of a link does not imply endorsement of the linked site or service by us or by our affiliates.

IX. Security

We maintain reasonable and appropriate, although not infallible, security precautions. However, we cannot guarantee that hackers or unauthorized personnel will not gain access to your Personal Information, despite our reasonable efforts. You should note that in using the Website, app, and/or our related Services, your information will travel through third-party infrastructures which are not under our control. Please feel free to raise any questions, concerns or specific directions you may have regarding the privacy and security of your information to privacy@lastrev.com.

X. Data Retention

We will retain your Personal Information for four (4) years, or as long as needed to provide the applicable Services. Our data retention period may change in the future if a longer retention period is required or permitted by law.

XI. Do Not Track

Your browser setting may allow you to automatically transmit a "Do Not Track" signal to websites and online services you visit. The Company's Website endeavors to respond to "Do Not Track" signals or other mechanisms from a visitor's browser. To find out more about "Do Not Track," please visit allaboutdnt.com.

XII. Advertising / Google AdWords

On this Website, the Company has integrated Google AdWords. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

If a data subject reaches our website via a Google ad, a conversion cookie is filed on the information technology system of the data subject through Google. A conversion cookie loses its validity after 30 days and is not used to identify the data subject.

The data subject may, at any time, prevent the setting of cookies by our website by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. The data subject has a possibility of objecting to the interest based advertisement of Google. Further information and the applicable data protection provisions of Google may be retrieved under google.com/policies/privacy.

XIII. Analytics / Google Analytics

On this Website, the Company has integrated the component of Google Analytics. Google Analytics is a web analytics service for the collection, gathering, and analysis of data about the behavior of visitors to websites. The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

The data subject may prevent the setting of cookies through our Website at any time by means of a corresponding adjustment of the web browser used. In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics by downloading and installing a browser add-on under tools.google.com/dlpage/gaoptout.

Further information and the applicable data protection provisions of Google may be retrieved under google.com/policies/privacy and under google.com/analytics/terms.

XIV. Your California Privacy Rights

California "Shine the Light" Law

Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed Personal Information to any third parties for the third parties' direct marketing purposes.

You may request and obtain from us once a year, free of charge, certain information about the Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to privacy@lastrev.com.

California Consumer Privacy Act

If you are a California resident, the processing of certain personal data about you may be subject to the California Consumer Privacy Act ("CCPA") and other applicable California state privacy laws.

RIGHT TO KNOW REQUEST — Under the CCPA, you may have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and ask that we provide you with the following information:

  • Categories of and specific pieces of personal information we have collected about you
  • Categories of sources from which we collect personal information
  • Purposes for collecting, using, or selling personal information
  • Categories of third parties with which we share personal information
  • Categories of personal information disclosed about you for a business purpose
  • If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold

RIGHT TO DELETE REQUEST — You may also have a right to request that we delete personal information, subject to certain exceptions.

If you are a California resident and would like to make a verifiable request, please submit your request in writing to privacy@lastrev.com.

XV. Referrals

If you choose to use our referral service to tell a friend about our Services by email, we will ask for your friend's email address, and send your friend a one-time email inviting them to visit our Website. We will only store your friend's email address for the sole purpose of sending this one-time message. Your friend may contact us at privacy@lastrev.com to request that we remove this information from our database at any time.

XVI. Testimonials, Ratings and Reviews

If you submit testimonials, ratings, or reviews of the Services to the Company and/or for use on our Website, any Personal Information you include will be displayed on the Website. If you want your testimonial, rating, or review removed from our Website at any time, please contact us at privacy@lastrev.com.

XVII. Changes

This Privacy Policy may be updated from time to time for any reason, at our sole discretion. We will notify you of any material changes to our Privacy Policy by posting the new Privacy Policy on our Website and emailing you. You are advised to consult this Privacy Policy regularly for any changes.

XVIII. Incorporation into Terms of Service

By using or accessing the Website or the Services, you are accepting the practices described in this Privacy Policy, and you are consenting to our processing of your information as set forth in this Privacy Policy and as amended by us. This Privacy Policy is incorporated into, and considered a part of, the Company's Terms of Service.

XIX. Opt-Out Policy

If, at any time after registering, you change your mind about receiving information from us or about the use of information volunteered by you, or if you prefer that we do not share your Personal Information with third parties for marketing purposes, please contact us at privacy@lastrev.com.

XX. Contact Us

If you have any questions or concerns relating to our use of your Personal Information, please email privacy@lastrev.com. Additionally, you may reach us by postal mail at:

Last Rev, LLC
1116 Balboa St
San Francisco, CA 94118