Privacy Policy

Effective Date: 28 December, 2024.

1. Introduction.

This Privacy Policy describes our practices regarding information we collect about you and the choices available to you regarding such information. For purposes of this Privacy Policy, unless otherwise stated, “information” or “personal information” means information relating to an identified or identifiable individual.

This Privacy Policy applies to information we collect where we control the purposes and means of processing, specifically information we collect through any of our websites, emails, or other online services that link to this Privacy Policy (the “Service”) or other sources identified below. Please note that your use of the Service is subject to our Terms of Use.

This Privacy Policy does not apply to:

• the practices of third parties we do not control
• information collected in the context of your job application or employment with us
• information that has been anonymized or, to the extent permitted by law, deidentified

For our contact details, see the Contact Us section below.

2. Collection.

This section describes the information we collect and how we collect it.

Information You Provide through the Service.

When you use the Service, you may be asked to provide information to us, such as when you contact us or sign up for emails. The categories of information we collect in this context include:

• Contact Identifiers, including your name, email address, postal address, and phone number.
• Content, including content within any messages you send to us (such as feedback or questions).

Please do not provide any information that we do not request.

Information from Your Browser or Device.

When you use the Service, we and third parties we work with automatically collect information from your browser or device. The categories of information we automatically collect in this context include:

• Device identifiers, including your device’s IP address.
• Device information, including your device’s operating software and browser (e.g., type, version, and configuration), internet service provider, and regional and language settings.
• Internet activity, including information about your browsing history and interactions, such as the features you use, pages you visit, content you view, time of day you browse, and referring and exiting pages.
• Non-precise location data, such as location derived from an IP address or data that indicates a city or postal code level.

This information is automatically collected through cookies and other tracking technologies incorporated into our Service, as described below:

• Cookies. Cookies are browser-based text files which are dropped on your browser when you visit a website, open or click on an email, or interact with an advertisement. There are various types of cookies, including session cookies (which are cookies that expire when you close your browser) and persistent cookies (which are cookies that do not expire until a set expiration date or you manually delete them). Cookies may be first party (which are cookies served directly by us) or third party (which are cookies served by third parties we work with).
• Pixels. Pixels (also known as web beacons) are code embedded in a service. There are various types of pixels, including image pixels (which are one-pixel transparent images) and JavaScript pixels (which contain JavaScript code). Pixels are often used in conjunction with cookies. When you access a service that contains a pixel, the pixel may permit us or a third party to collect information from your browser or device, or to drop or read cookies on your browser.

We use these tracking technologies for a variety of purposes, including to help make our Service work, personalize your browsing experience, prevent fraud and assist with security, perform measurement and analytics, and provide advertising.

Information from Other Sources.

We also collect information from other sources. The categories of other sources from which we collect information include:

• Third party vendors and related parties we work with in connection with receiving analytics, advertising, security, and fraud prevention services.
• Public sources, such as information in the public domain.

3. Purposes for Collection and Use.

Our purposes for collecting and using information include:

• Providing services. We collect and use information to provide services to you, including to operate the Service, and provide support.
• Personalizing your experience. We collect and use information to personalize your experience and show you content we believe you will find interesting.
• Communications. We collect and use information to communicate with you about updates, security alerts, changes to policies, and other transactional messages. We also collect and use information to personalize and deliver marketing communications to you, including by email.
• Analytics. We collect and use information to understand trends, usage, and activities, for example through surveys you respond to and tracking technologies that we incorporate into the Service (such as Google Analytics).
• Promotions. When you voluntarily enter a promotion, we collect and use information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law. By entering a promotion, you agree to the official rules that govern that promotion, and that, except where prohibited by applicable law, we, the sponsor, and related entities may use your name, voice and/or likeness in advertising or marketing materials.
• Improvements. We collect and use information to develop and improve our services.
• Security and enforcement. We collect and use information to prevent, detect, investigate, and address fraud, breach of policies or terms, or threats or harm.
• At your direction or with your consent. We collect and use information for additional purposes where you direct us to use it in a certain way or with notice to you and your consent.
• Non-personal information. Sometimes we anonymize or deidentify information so it is no longer considered personal information under applicable law. Where we deidentify information, we commit to maintain and use the deidentified information in deidentified form and not attempt to reidentify it. We may use non-personal information for any purpose to the extent permitted by applicable law.

To exercise choice around our collection and use, see Your Privacy Choices below.

4. Disclosure.

We disclose the information we collect for the purposes described in this Privacy Policy. The categories of persons to whom we disclose information include:

• Service providers. Many of the third parties we work are service providers that collect and process information on our behalf. Service providers perform services for us such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. To the extent required by law, we contractually prohibit our service providers from processing information they collect on our behalf for purposes other than performing services for us, although we may permit them to use non-personal information for any purpose to the extent permitted by applicable law.
• Affiliates. We disclose information to our affiliates and related entities, including where they act as our service providers subject to this Privacy Policy or use the information in accordance with their own privacy policies.
• Recipients in a merger or acquisition. We disclose information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
• Recipients for security and enforcement. We disclose information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also disclose information to protect the rights, property, life, health, security and safety of us, the Service or anyone else.
• Recipients at your direction or with your consent. We disclose information where you direct us to or with notice to you and your consent.
• Non-personal information. We may disclose non-personal information for any purpose to the extent permitted by applicable law.

To exercise choice around our disclosures, see Your Privacy Choices below.

5. Your Privacy Choices.

This section describes the choices available to you regarding your information.

Emails. To stop receiving marketing emails, follow the unsubscribe instructions near the bottom of such emails, or email us at as set out in the Contact Us section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt out of transactional emails.

Browser and Device Controls.

• Cookies and pixels. You may be able to manage cookies through your browser settings. When you manage cookies, pixels associated with such cookies may also be impacted. Please note that cookie management only applies to our website. If you use multiple browsers, you will need to instruct each browser separately. If you delete or reset your cookies, you will need to reconfigure your settings. Your ability to limit cookies is subject to your browser settings and limitations.
• Preference signals. Your browser or extension may allow you to automatically transmit Do Not Track and other preference signals. Except as required by law, we do not respond to preference signals.

6. Children.

The Service is not directed toward children under 13 years old, and we do not knowingly collect personal information (as that term is defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information from children, please contact us as set out in the Contact Us section below. We will delete the personal information in accordance with COPPA.

7. Security.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Please note that transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

8. Retention.

We retain information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

9. International Transfer.

We are based in the U.S. If you are located outside the U.S., please be aware that your information may be transferred to and processed in the U.S. or another country where we operate. Where required by applicable law, we will provide appropriate safeguards for data transfers.

10. Changes to this Privacy Policy.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide additional notice to you, such as through email or prominent notice on the Service.

11. Contact Us.

The controller under this Privacy Policy is:

It’s About Water, Ld. (“Company,” “we,” “our,” or “us”)

Geoffrey D. Menin

Menin & Associates, 119 Fifth Avenue, 3rd Fl.

New York, New York 10003

gmenin@meninlaw.com

If you have questions about our practices regarding your information or have trouble accessing this Privacy Policy, please contact us at the postal address or email address above. To exercise choice available to you, please use the designated methods listed in this Privacy Policy.