Last revised: January 1, 2024

This Privacy Policy describes the information Karma Ventures, LLC and our affiliates (collectively, “Karma Ventures”, “Web Karma”, “Karma”, “we,” and “us”) collect when a person or business (“you,” “your”) applies or signs up for an account, accesses or uses in any manner any application, product, service, feature, technology, content, or website owned or controlled by us (“Services”); or otherwise contacts or interacts with us.

Scope and Consent

By using our Services, or applying or signing up for an account, including through a computer or mobile device (“device”), you accept the terms of this Privacy Policy and consent to our collection, use, disclosure and retention of your information as described herein (including to contact you), and for all other purposes permitted under applicable personal information privacy statutes, credit bureau reporting rules, anti-spam legislation, and consumer protection laws.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications (“Third Party Services”) that you elect to access through the Service or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

Except as we explicitly stated at the time we request information, as provided for in this Privacy Policy, or as provided for in your Subscription Services Agreement with Karma Ventures, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.

Amendment

We may amend this Privacy Policy from time to time by posting a revised version and updating the “Last updated” date above. The revised version will be effective at the time we post it. We will provide you with reasonable prior notice of substantial changes in how we use your information, including by email at the email address you provide. Where these changes would cause material detriment to you, you may of course cancel your account at any time. We encourage you to review this Privacy Policy whenever you access or use in any manner any Karma application, product, service, feature, technology, content, or website (collectively, “Services”) to stay informed about our information practices and the choices available to you and to contact us if you have any questions about these changes. Your continued use of our Services constitutes your acceptance of any amendment of this Privacy Policy.

Collection and Use of Information

On webkarma.com or app.webkarma.com (the “Site”) you can do many things which may involve your personally identifiable information (“Personal Information”); for example, you can request information, collect reviews, manage contacts, marketing or support materials. Karma will collect and use Personal Information from you to provide, personalize, improve and continue to operate the Karma Service as well as for these purposes.

Some of your activity on and through the Service is public by default, such as reviews. This may include, but is not limited to, content you have posted publicly on the Site or otherwise through the Service.

Registered users may have some of this information associated with their Account. Unregistered users will not have this association, but information concerning their use of the Service (such as what pages they have visited) may be tracked anonymously through the use of cookies and stored by us.

Please also remember that if you choose to provide Personal Information using certain public features of the Service, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Service.

When you create an Account, you will provide information that could be Personal Information, such as your name, company name, mailing address, phone number, and e-mail address, and, if applicable, financial qualification and billing information, such as billing name and address, and credit card number. We may also ask for additional Personal Information, such as title, department name, fax number, or additional company information. You acknowledge that this information may be personal to you, and by creating an Account on the Service and providing Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous. You can update Personal Information at any time by contacting [email protected] or through your Account if you have one.

Karma uses the Personal Information that we collect from you to set up and provide the Service for you and your organizations. We may also use the information you provide to contact you to further discuss your interest in Karma, the Service that we provide, and to send information regarding our company or partners, such as promotions and events. Your email addresses and any Personal Information may be shared with our partners involved in providing the Service, as well as in connection with providing value-added services and marketing and promotional opportunities, but will not be distributed or shared with unaffiliated third parties. You can opt out of being contacted by us, or receiving such information from us, at any time by sending an email to [email protected]. Separately, you will also be asked to provide an email address when registering an Account for the Service, in order to receive a username and password. We may also email information regarding updates to the Service or Karma. You can opt out of receiving any communication from Karma by clicking “unsubscribe” within the communication at the time it is distributed, or at the time you register for the Service, although we, regardless, reserve the right to contact you when we believe it is necessary, such as for account recovery purposes.

Some features of the Service allow you to provide content to the Service, such as written comments and conversations. All content submitted by you to the Service may be retained by us indefinitely, even after you deactivate your account. We may continue to disclose such content to third parties in a manner that does not reveal Personal Information, as described in this Privacy Policy.

If you communicate with Karma via email or via some other form of communication, including interacting with us via the Site, we may retain such correspondence and the information contained therein and use such information to respond to your inquiry. We may also receive information about you from other sources, such as our agents, partners and service providers, and from publicly available sources.

We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share Personal Information with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Agents.

The financial and billing information that we collect through the Site is used solely to check the qualifications of prospective customers and to bill for the Service. Karma uses third-party intermediaries (“Payment Processors”) to manage billing and credit card processing related to invoices paid by credit card. The Payment Processors may be permitted to store, retain, or use the financial information provided, for the sole purpose of providing billing and credit card processing services to Karma. Use and storage of financial and billing information is governed by the Payment Processor’s applicable terms of service and privacy policy. However, we may from time to time request and receive some of your financial information from our Payment Processor for the purposes of completing transactions you have initiated through the Service, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identify possible fraudulent transactions, and otherwise as needed to manage our business.

Some users may access the Site using their credentials from third party services via single sign-on. If you choose to log in to the Service using a third party single sign on provider, such third party will authenticate your identity and may share with us certain information associated with your profile on such third party’s account, some of which may include your Personal Information. As with all Third Party Services, your use of a single sign on provider shall be governed by the terms of service and privacy statement of such provider.

You may use the Site to host data and information (“Data”). Karma will not review, share, distribute, print, or reference any such Data except as described in this Privacy Policy, in your Subscription Services Agreement with Karma, or as may be required by law. Individual records may at times be viewed or accessed only for the purpose of resolving a problem, support issue, or suspected violation of the Subscription Services Agreement, or as may be required by law.

Karma may also automatically collect, record and use certain information from your web browser when you interact with the Service and the Site, such as IP addresses, the number of visits, along with information on what pages are viewed and which links you have clicked on. This statistical information is not Personal Information and cannot be tied back to you, your Account or your web browser. IP address information is not made public; we do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy. This information is logged to help diagnose technical problems, and to administer our Site in order to constantly improve the quality of the Service. We may also track and analyze non-identifying and aggregate usage and volume statistical information about you and provide such information to partners, service providers and other third parties with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use our Service and their websites or services, which facilitates improving both their services and how our Service interfaces with them. In addition, these third parties may share with us non-private, aggregated or otherwise non Personal Information about you that they have independently developed or acquired.

Legal Process; Investigations

We reserve the right to access, read, preserve and disclose any information we reasonably believe is necessary to (i) comply with any applicable law, regulation, governmental request or legal process, (ii) to exercise our legal rights, enforce this Privacy Policy and the Subscription Services Agreement, including investigation of potential violations thereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) defend and protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Cookies

When you interact with the Site we strive to make that experience easy and meaningful. When you come to the Site, our web server may send a cookie to your computer through your web browser. Cookies are files that web browsers place on a computer’s hard drive and are used to enable our services to recognize your web browser and tell us how often and when you have visited the Site previously and otherwise use the Service throughout the Internet.

Standing alone, cookies do not identify you personally and we do not combine the general information collected through cookies with other Personal Information to tell us who you are. They merely recognize your browser. Unless you choose to identify yourself to Karma, for example by responding to a promotional offer, or opening an Account, you remain anonymous to Karma. Cookies come in two flavors: session and persistent-based. Session cookies exist only during an online session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. They include such information as a unique identifier for your browser.

Karma uses session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in to the Site to use the Service. This information allows Karma to process your online transactions and requests. Session cookies help us make sure you are who you say you are after you’ve logged in to your Account, and are required in order to use the Service. Karma takes precautions in its use of persistent cookies. For example, we do not store account numbers or passwords in persistent cookies.

Many browsers contain features that allow you to block or delete cookies from your system. We strongly recommend that you leave cookies active, because they enable you to take advantage of the most attractive features of the Service. To learn more about your ability to manage cookies and web beacons, please consult the privacy features in your particular web browser.

Third Party Cookies

We may from time to time engage third parties to track and analyze non-personally identifiable usage and volume statistical information from you to help us administer the Site and the Service and improve its quality and usability. Such third parties may use cookies and other technology to help track visitor behavior. Third party cookies will not be used by Karma to associate you with any personally identifiable information you may provide to Karma. All data collected by such third parties on behalf of Karma is used only to provide Karma with information on site usage, performance monitoring and the like, and is not shared with any other third parties. This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.

Third-Party Sites

The Site may contain links to third party web sites and services, including social media sites such as Facebook, LinkedIn, Twitter and others. Karma is not responsible for the privacy practices or the content of these other web sites. If you choose to share any information from the Site through or otherwise access these third party web sites and services, you are responsible for checking and reading the policy statements of such third party web sites and services to understand their policies. This Privacy Policy only governs information collected on the Service. If you access a linked third party web site or service, such third party web site or service may receive your Personal Information. It is your responsibility to keep Personal Information you share in this manner private and confidential.

Opt-Out Policy

Karma offers you a means to choose how we may use information provided by you. If, at any time after registering an Account with Karma, or otherwise providing Personal Information to Karma, you change your mind about receiving information from us or about sharing your information with third parties, you can update your Account yourself or you can send us a request specifying your new choice by emailing [email protected]. Please note that if you are a customer with an Account, Karma must retain certain basic information about you in order to continue to provide the Service. Please also note that, if you choose to deactivate your Account, we reserve the right to retain an anonymized history of activity associated with your Account prior to deactivation.

Correcting & Updating Your Information

If you need to update or change Account registration information you may do so by logging in to your Account and making the necessary changes yourself or by requesting Karma to edit the user or organization record. To update information, if you have an Account you can update information yourself through your Account. To discontinue the Service and to have your Data deleted, email [email protected]. Karma will respond to your correction or update request within 30 days from the date of your request.

Additional Information, How to Contact Karma

Questions regarding this Privacy Policy or the privacy related practices of the Site or Services should be directed by sending an email to [email protected].

Business Changes

Should we undergo any sort of corporate reorganization, merger or acquisition in the future, we may provide or otherwise transfer your information to the resulting or acquiring entity as part of the transfer or disposition of assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this Privacy Policy.

Information Security

If you have an Account, your Account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account.

We seek to protect Account information to ensure that it is kept private, as further described in our Security Policy; however, we cannot guarantee the security of any Account information.

We otherwise store all of your information, including your IP address information, using industry-standard techniques as further described in our Security Policy. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Information or otherwise.

Access to Information

If you are a registered user, you can access information associated with your Account by logging into the Service. Registered and unregistered users can access and delete cookies through their web browser settings.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: ATTN: Legal Department, 22 Cortlandt Street, 18th Floor, New York, NY 10007.

Account Deactivation

Should you ever decide to deactivate your Account, you may do so within your Account center or by emailing [email protected]. If you deactivate your Account, any association between your Account and information we store will no longer be accessible to you through your Account. However, given the nature of sharing on the Service, any public activity on your Account prior to deactivation will remain stored on our servers and will remain accessible to the public.

Effective Date: January 1, 2024.