PRIVACY POLICY

Last Updated: November 15, 2023

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INTRODUCTION

Herwood Creative [https://www.herwoodcreative.com] ("our" "we" or

"us") respect the privacy and are committed to protect the personal

information of our Users ("user," "you," your" or "yours") when you

visit or use Herwood Creative [https://www.herwoodcreative.com] (the

"App"). We provide our App and Services (hereinafter collectively,

either "App" or "Services") to you as under the following privacy

policy (the "Policy").

PERSONAL INFORMATION WE COLLECT

In order to keep the App functional, we must process information about

you to operate, improve, modify, customize, support and market our

services.

The type of information that we collect depends on how you use our App

and Services. We require certain information to deliver to you, our

services, and without this, we will not be able to provide such

services to you. Our Services have optional features, which, if used

by you, require us to collect additional information to provide such

features. You will be notified of such collection, as appropriate. If

you choose not to provide the information needed to use a feature, you

will be unable to use the feature. Please carefully read the following

to understand what information we may collect:

* When you use the App or register to the App, we may ask you to

provide certain information, including DEBIT/CREDIT CARD NUMBERS,

BILLING ADDRESSES, PHONEBOOK AND CONTACT LIST, CONTACT OR

AUTHENTICATION DATA, CONTACT PREFERENCES, JOB TITLE, ADDRESS, PERSONAL

NUMBER, PASSWORD, USERNAME, PHONE, SURNAME, NAME OR EMAIL. We will

also collect or otherwise ask you to provide additional information

that you provide us, such as your profile details, pictures and/or any

other texts, images, videos or information that you may upload on the

App and/or provide to the App.

* Geo-Location Data. We may use and store information about your

location, if you give us permission to do so. If you are accessing a

page or service from a computer or a mobile device, you may be asked

to share your precise (GPS level) geo-location information with us so

we can customize your experience on our services or on other services

when we work with a marketing partner such as a third party service

provider, advertiser, advertising network and platform, advertising

agency, and a data broker or aggregator. If you agree to the

collection of location data, in most cases, you will be able to turn

off such data collection at any time by accessing the privacy settings

of your mobile device

* We also collect information while you access, browse, view or

otherwise use the App. In other words, when you access the App we are

aware of your usage of the App, and gather, collect and record the

information relating to such usage, including geo-location

information, IP address, device and connection information, browser

information and web-log information, phone book and contacts, and all

communications recorded by Users through the App. We use that

information to enhance user experience, personalize your browsing

experience as well as monitor the App for preventing fraud and

inappropriate content or behavior. We collect texts, information,

pictures, videos and/or any data that you may upload on the app. We

also collect supplemental information obtained from third parties such

as demographic and navigation data, if applicable. We combine your

personal information with information we collect automatically or

obtain from other companies and use it to improve and personalize our

services, content and advertising and/or to prevent fraud.

All of the preceding is collected, as permitted by applicable laws

relevant to your jurisdiction.

HOW DO WE COLLECT PERSONAL INFORMATION?

INFORMATION PROVIDED BY YOU. You directly provide us with most of the

information we collect. You do this by filling out the registration

details on the App, linking accounts of other social networks to your

Herwood Creative [https://www.herwoodcreative.com] account, completing

application forms, as well as by posting and sharing additional

information voluntarily.

INFORMATION WE COLLECT WHEN YOU USE THE APP. We collect technical

information indirectly and automatically through our systems. This

information includes logging your operating system, software

configuration, Internet Protocol (IP) address and use of cookies

(cookies are small files sent from us to your computer and sometimes

back). Cookies ultimately help us improve your navigation and ease of

use of our App.

Should you require additional information about how we may use Cookies

to improve the services we provide, please visit our COOKIE POLICY.

INFORMATION WE COLLECT FROM OTHER SOURCES. We may receive information

from third party vendors and/or other commercially available sources,

such as:

* Third party vendors who provide us data to supplement the

information we collect about you, in accordance with applicable laws.

For example, we receive information from advertising and marketing

partners in order to manage and measure our campaigns as well as from

enrichment service providers to enhance, modify and personalize your

experience of the App.

* For more information, please see the following sections of this

Policy: ANALYTICS, COOKIES and MARKETING AND BEHAVIORAL REMARKETING

HOW WE USE COLLECTED PERSONAL INFORMATION?

All processing of your personal information will always be justified

by a "lawful ground" for processing, where relevant under applicable

laws. In the majority of cases, processing will be justified on the

basis that:

* you, or in the case you are below the age of 16 or the age of

legal adulthood if different in your country, your parent or guardian

has provided consent for us to use your personal information for a

specific purpose;

* the use of your personal information is necessary to perform a

contract or take reasonable steps to enter into a contract with you

(E.G. TO PROVIDE YOU WITH AGREEMENTS OR SERVICES WHICH YOU HAVE

PURCHASED);

* the processing is necessary to comply with a relevant legal

obligation or regulatory obligation that you and/or we have (e.g.

fraud prevention); or

* the processing is necessary to support our legitimate interests as

a business (e.g. to improve our services to you), subject to your

interests and fundamental rights and provided it is conducted at all

times in a way that is proportionate.

We will use your personal information for the following purposes:

* Our processing of your personal information for marketing purposes

is based on our legitimate interest, or on your consent, or as

otherwise permitted according to applicable laws. You have a right to

prevent direct marketing of any form at any time - this can be

exercised by following the opt-out link attached to each communication

or by sending an email to EM@HERWOODCREATIVE.COM.

* We take steps to limit direct marketing to a reasonable and

proportionate level, and to send you communications which we believe

may be of interest or relevance to you, based on the information we

have about you.

* To provide support.

HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?

We retain personal information only for as long as is required to

fulfil the purpose for which it was collected and unless otherwise

stated for a period of: AS LONG AS THE USER HAS AN ACCOUNT WITH US.

Please note that some circumstances, we will retain your personal

information for longer periods of time. We will retain personal

information for the following purposes:

* as long as it is necessary and relevant for our operations, e.g.

as long as is necessary to provide services, etc.; and

* in relation to personal information to comply with applicable

laws, prevent fraud, troubleshoot problems, assist with any

investigation, enforce our App terms and take other actions as

permitted by law.

CHILDREN UNDER THE LEGAL AGE OF ADULTHOOD

Our services are not directed to children under the age of thirteen,

or any as such age relevant to Applicable Laws in your jurisdiction,

and we do not knowingly collect personal information from children

under the age of thirteen, or sixteen, through our Services. We

encourage parents and legal guardians to help enforce our Privacy

Notice by instructing children under the age of thirteen not to

download or use our online services.

Should we learn we have collected or received personal information

from a child under 13 or any such age relevant to Applicable Laws in

your jurisdiction, we shall delete that personal information

immediately and if we shall have a reasonable doubt that the consent

given is not truthful regarding the age of the user, we reserve

ourselves the right to immediately suspend the access to the App

giving notice of the reasons. If you believe we might have any

information from or about a child under 13 or 16, or if you are a

parent or guardian concerned that we may have collected information of

your child, please contact us immediately at EM@HERWOODCREATIVE.COM.

SHARING PERSONAL INFORMATION WITH THIRD PARTIES

We do not sell or rent your personal information to third parties for

their marketing purposes without your explicit consent.

We share your personal information with third parties as under:

* We share personal information with service providers that provide

us with services for the purpose of operating the App and opening and

operating your account. Consistent with applicable legal requirements,

we take commercially reasonable steps to require third parties to

adequately safeguard your personal information and only process it in

accordance with our instructions;

* We share personal information to law enforcement agencies, public

authorities or other parties, if we believe we are required to do so

by law, or that doing so is reasonably necessary to comply with our

legal obligations;

* We share personal information with payment processors, fraud

detection agencies and similar third parties for the purpose of

facilitating payments done via the App and securing the App and

protecting it against fraud or other liabilities;

* We also may share limited personal information with such social

media platforms and marketing partners, such as Facebook, Twitter and

Google, to promote our services. Such features and third party

services collect certain information about you and may set a cookie to

enable their functionality. Such third party features are governed by

their privacy policies and under their terms and conditions.

* Personal information will also be disclosed if we go through a

business transition such as a merger, sale, transfer of all or a

portion of Herwood Creative [https://www.herwoodcreative.com] 's

assets, acquisition, bankruptcy or similar event. In the event that we

sell any business or assets, we will disclose your data to the

prospective buyer. If we or substantially all of our assets are

acquired by a third party, information held by us about our users will

be one of the transferred assets.

Please note, when you publish your information and/or share your data

with other Users, we try to maintain the standards of all users, but

we do not take responsibility over the actions of other users.

WHERE WE STORE YOUR PERSONAL INFORMATION

We may store your data manually or electronically. Any data stored

electronically will be stored in secure servers, and any data stored

manually will be stored in our premises within the UNITED STATES.

Unfortunately, the transmission of information via the internet is not

completely secure. Although we will do our best to protect your

personal data, we cannot guarantee the security of data transmitted to

us and any transmission is at your own risk.

COOKIES

We use cookies and similar technologies (such as web beacons, pixels,

tags, and scripts) to improve and personalize your experience, provide

our services, analyze performance and for marketing purposes.

Some of the services we use such as GOOGLE ANALYTICS

[https://policies.google.com/privacy] set cookies to allow us to

gather anonymous data about your usage of our website.

A cookie is a text file sent by a web server to a web browser and

stored in the browser. The file is then sent back to the server each

time the browser requests a page form the server. This enables the web

server to identify and track the web browser.

We may send a cookie which may be stored by your browser on your

computer’s hard drive. The information we obtain from the cookie

could be used to improve the website’s usability and for marketing

purposes. We may also use that information to recognize your computer

when you use our App and to personalize our App for you.

Browsers usually will allow you to refuse cookies but this could have

a negative impact on the usability of many websites.

To learn more about how we and our third party service providers use

cookies and your control over these Cookies, please see our Cookie

Policy.

DO NOT TRACK

Do Not Track (DNT) is a privacy preference that users can set in some

web browsers, allowing users to opt out of tracking by the web and

online services. We do not honor browser requests not to be tracked

online (known as "Do Not Track"), but our Cookie Policy describes how

you can opt out of receiving cookies. To learn more about cookies,

including how to view which cookies have been set and how to manage

and delete them, please visit: www.allaboutcookies.org

[https://allaboutcookies.org]. At this time, our App do not respond to

Do Not Track beacons sent by browser plugins.

ANALYTICS:

We use GOOGLE ANALYTICS [https://policies.google.com/privacy] to

collect the following information when users access or interact with

our App: This information may include, among other information, the

browser and operating system you are using, the URL or advertisement

that referred you to our Website, the search terms you entered into a

search engine that led you to our Website, areas within our Website

that you visited, and other information commonly shared when browsers

communicate with websites. This information may also include x/y

coordinates of mouse events, unique ID tracking cookie, Internet

Protocol ("IP") address (anonymized for residents of the European

Economic Area), unique device identifier ("Device Identifier") for any

device (computer, mobile phone, tablet, etc.). A Device Identifier is

a number that is automatically assigned or connected to the device you

use to access the Service, and our servers identify your device by its

Device Identifier. Some mobile service providers may also provide us

or our third party service providers with information regarding the

physical location of the device used to access the Service.

We use the information from GOOGLE ANALYTICS

[https://policies.google.com/privacy] in order to assemble statistics

regarding usage of our App as well as to help us understand how users

engage with our App on an individual and aggregate basis in order to

improve it; to help with customer service needs (such as

troubleshooting issues that users report to us); and for research and

analytical purposes such as service performance; customer behavior and

common navigation through the App.

We do not share our App traffic data with any third party for any

purpose unless required for legal reasons such as meeting applicable

laws, regulations, legal processes, or enforceable governmental

requests and/or unless you have given an explicit consent to allow us

to do so; enforcing applicable terms of service; detecting,

preventing, or otherwise addressing fraud, security, or technical

issues; protecting against harm to the rights, property or safety of

our Company, our Customers, or the public as required or permitted by

law.

If you'd like to opt-out or If you'd like to obtain a copy of your

data, make a correction, or have it erased, please contact us in any

way convenient for you in the CONTACT US section.

DISCLAIMERS:

ADS AND EXTERNAL LINKS

Please note that the App may contains links to third party Apps and

advertisements, and if you link to a third party App from the App, any

data you provide to that App and any use of that data by the third

party are not under the control of Herwood Creative

[https://www.herwoodcreative.com] and are not subject to this Policy.

You should consult the privacy policies of each App you visit. This

Policy applies solely to personal information collected by our App. If

you upload content, including personal information, to a social

network and then tag the App, your submission will be subject to that

social network's terms of use and privacy policy, even where you post

on an official Herwood Creative [https://www.herwoodcreative.com] page

on the social network. We do not have control over these terms of use

and privacy policies and have not reviewed their adequacy. You should

therefore review these before submitting any personal information.

INCORRECT CONTENTS

We take reasonable steps to ensure the accuracy of the information

provide on the App and on the external link in this policy listed.

However, the information is provided "as is" without any warranty of

guarantee of any kind. Under no circumstance should you rely on the

accuracy of information given on the App.

We take no responsibility or liability for the accuracy, content,

completeness, reliability or legality of the information and contents

contained on this App.

SPECIFIC PROVISIONS FOR CALIFORNIA RESIDENTS

This section of the Policy applies to you, if you are a California

resident.

We have collected the following categories of personal information

from Users:

* Information that you chose to upload or otherwise provided by you

which may include: (i) Identifiers and personal information, such as

name, postal addresses, online identifiers, email addresses, and

location.

* Information we collect when you use the App, including (i)

Identifiers and personal information, such as online identifiers,

internet protocol (IP) addresses, access device and connection

information such as browser type, version, and time zone setting and

browser plug-in types and versions; (ii) commercial information,

including products or services purchased, obtained, or considered, or

other purchasing or consuming histories or tendencies; (iii) Internet

or other electronic network activity information, including, but not

limited to log-in and log-out time, the duration of sessions, the

content uploaded and downloaded, viewed web-pages or specific content

on web-pages, activity measures; (iv) Location information, based on

your IP address and GPS, (iv) phonebook based on your contact lists;

(v) pictures based on your camera.

* Inferences drawn from any of the information identified above to

create a profile about you.

* We obtain personal information listed above from third party

sources, as detailed in this Policy.

We use the personal information that we collect or receive for the

business purposes as described above under the Section titled "HOW DO

WE USE THE INFORMATION COLLECTED?".

We disclose personal information to third parties for business

purposes as described above under the Section titled "Sharing Personal

Information with Third Parties" in the Policy. In the preceding twelve

(12) months, we have disclosed all the categories of personal

information detailed above for business purposes.

As previously mentioned in this Policy, we do not sell (as such term

is defined in the CCPA) personal information and will not sell it

without providing Users with a right to opt out.

You are entitled to the following specific rights under the CCPA in

relation to personal information related to you:

* You have a right to request that we will disclose certain

information to you about our collection and use of personal

information related to you over the past 12 months. After verifying

your request, we will disclose to you: (i) the categories of personal

information that we collect about you; (ii) the categories of sources

from which the personal information is collected; (iii) the purposes

for collecting, using, or selling that personal information; (iv) the

categories of personal information that we disclosed for a business

purpose or sold, and the categories of third parties to whom we

disclosed or sold that particular category of personal information;

(v) the specific pieces of personal information that we have collected

about you; (vi) if we disclosed your personal information for a

business purpose, the categories of personal information we have

disclosed; (vii) if we sold your personal information, the categories

of personal information we have sold.

* You have a right to request that we delete personal information

related to you that we collected from you under certain circumstances

and exceptions.

* You also have a right not to be discriminated against for

exercising your rights under the CCPA.

To make such requests, we kindly ask that you contact us at

EM@HERWOODCREATIVE.COM.

We will verify your request using the information associated with your

account, including email address. Government identification may also

be required.

A request for access can be made by you only twice within a 12-months

period. Any disclosures that we provide will only cover the 12-months

period preceding receipt of your request. We do not charge a fee to

process or respond to your verifiable User request unless it is

excessive, repetitive, or manifestly unfounded. If we determine that

the request warrants a fee, we will inform you of the reasons for such

decision and provide you with a cost estimate before processing

further your request.

UPDATING PERSONAL INFORMATION

We take steps to ensure that the personal information we collect is

accurate and up to date, and we provide you with the opportunity to

update your information through your account profile settings. In the

event that you believe your information is in any way incorrect or

inaccurate, please let us know immediately. We will make sure we

investigate the matter and correct any inaccuracies as quickly as

possible where necessary or give you ways to update it quickly or to

delete it - unless we have to keep that information for legitimate

business or legal purposes. When updating your personal information,

we will ask you to verify your identity before we can act on your

request. If for any reason you have a problem with deleting your

personal information, please contact us at EM@HERWOODCREATIVE.COM and

we will make reasonable efforts to delete any such information

pursuant to any applicable privacy laws.

CONTACT US

To exercise any of your rights in connection with your personal

information, we kindly ask that you please contact us at

EM@HERWOODCREATIVE.COM .

If you have any questions (or comments) concerning this Policy, please

email our team at EM@HERWOODCREATIVE.COM, and we will make an effort

to reply within a reasonable timeframe.

CONTACT US

For any questions or queries regarding this Privacy Policy, please

feel free to contact us:

EM@HERWOODCREATIVE.COM