Data Controller Contact Information

C/O ExtraHourz, Inc.
1395 Brickell Ave., Suite 2706
Miami, FL 33131
Tel: 1-855-999-7171


Avenu is a software platform owned by ExtraHourz, Inc. (“ExtraHourz”), which provides recruiting products and services (the “Services) to businesses and their representatives. Avenu and ExtraHourz are collectively referred herein as the “Company”.

This privacy notice (this “Policy”) applies to the information that the Company (“ExtraHourz”, “Avenu”, “we”, “us, or “our”) collect from you, whether in-person or on-line through our web pages,, our mobile application (collectively, “Platform”), and through all products, services, communications, and offerings provided (“Services”).

Our privacy notice tells you and other people (the “Users”) what personal data and nonpersonal data we may collect from you, how we collect them, how we protect them, how we share them, how you can access and change them, and how you can limit our sharing of them. Our Privacy Policy also explains certain legal rights that you have with respect to your personal data. Any capitalized terms not defined herein will have the same meaning as where they are defined elsewhere on our Platform.


Our websites, products and services are designed for businesses and their representatives. We do not offer products or services for use by individuals for their personal, family or household purposes. Accordingly, we treat all Personal Data we collect as pertaining to individuals in their capacities as business representatives and not as individual consumers. Our customers are the controllers of the Personal Data they collect through our Services to manage their own recruiting and onboarding processes (i.e., names, contact information, and other data collected as part of job applications), and each customer manages that Personal Data in accordance with its own privacy policies.

The Company processes Personal Data relating to our customers’ employees and job applicants within our Services only according to our customers’ instructions (as defined in our customer agreements), and we have to direct relationship with the individual whose Personal Data we process in connection with our customers’ use of our Services. For example, if you apply to a job posted to a career page of our customer, the Company on behalf of that customer will automatically process your Personal Data. However, the company you applied to is the data controller (or business, as that term is defined in the CCPA) with respect to your Personal Data, and you should contact that entity directly with any questions you may have regarding its private policies or data processing practices, or if you wish to modify or access your Personal Data, restrict its processing, or delete it from our Services. Our customers’ contracts require us to redirect any inquiries relating to the Personal Data we process on behalf of a customer back that customer without taking any action on the request. We are not responsible for the privacy of data security practices of our customers, which may differ from those set forth in this Policy.

However, ExtraHourz is the controller of Personal Data we collect directly from visitors to all domains owned by the Company including, and (collectively, the “Company Website”); from our own job applicants; and from our customers and vendors to help us manage our business relationships with them. This Policy describes the type of Personal Data that the Company collects; Greenhouse’s policies around the use, disclosure, and retention of that Personal Data; and the choices available to you regarding your rights in relation to your Personal Data generally.

The Company Website and Services (as defined above) may contain links to other websites, applications and services maintained by third parties. The privacy and data protection practices of such third parties are governed by the private policies of those organizations. Please review the privacy policies of those organizations to better understand their private policies.

If you are a California resident, see Section 14 for information provided pursuant to the California Consumer Privacy Act


NONPERSONAL DATA (NPD) is information that is in no way personally identifiable.

PERSONAL DATA (PD) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified directly or indirectly by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. PD is in many ways the same as Personally Identifiable Information (PII). However, PD is broader in scope and covers more data. (GDPR) means General Data Protection Regulation.

When you access or use the Platform or the Services, you acknowledge that you have read and understand this Privacy Policy, and that you consent to the processing of your personal information as described herein. Your access and use of the Services or the Platform is subject to the Terms of Use (hyperlink) (the “Terms of Use”)

Topics Covered Under the Privacy Policy



You have the right to request that we do not sell any of your personal information. Personal information for this section means a natural person’s first name or first initial and last name in combination with any one or more of the following data elements when the name and data elements are not encrypted: social security number, driver’s license number, driver authorization card number, or identification card number. Account number, credit card number, or debit card number, in combination with any required security code, access code, or password that would permit access to the person’s financial account. A medical identification number or a health insurance identification number. A username, unique identifier, or electronic mail address in combination with a password, access code, or security question and answer that would permit access to an online account. If you wish to make this request, please email us at: telling us that you do not want to have any of your personal information sold. Please include enough personal information so that we can reasonably verify your identification. We will respond to your request within 60 days after receiving it. See Section 14 regarding your rights under GDPR and Section 15 for your rights under the CAPA


Generally, you control the amount and type of information that you provide to us when using our Platform and the Services. For us to identify and serve you with the most relevant tools, content, and connections, we and our service providers collect and receive several categories of PD based on the nature of your interactions with us.

a. Information We Collect from The Platform and The Services.

When you register as a user, member, or when buying our products or services, we may collect some or all of the following information: your first and last name, email address, work availability, locations, phone number, physical address, job experience, gender, ethnicity, age, legal status in the United States, payment information, profile URL, phone number, username, password, and other information listed.

b. Commercial and Preference Information

We may collect your order history, such as what purchase you make on our Platform, or what events you express an interest in. We also collect comments you submit and surveys or profiles you complete.

c. Employment-Related Information

You may choose to provide information on your profile on the Platform, such as your work experience, employment history, education background, honors, training, the URL to your own profile page, salary expectations and other information.

d. Calendar Availability

A User may connect their calendar with Avenu. Our calendar integration only checks the duration and free/busy status of the events in your calendar so that we don’t book you when you’re busy. We never store details about the appointments in your connected calendar, such as who you are meeting with, their email address, or the meeting title. Although connecting your calendar to our services makes the scheduling process much more efficient, you are not required to connect your calendar to use our services. Avenu's use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.


a. Automatic Information

We automatically receive information from your web browser or mobile device. This information may include the name of the website from which you entered our Platform and the Services, if any, as well as the name of the website you’ll visit when you leave our Platform. This information may also include the IP address of your computer/the proxy server you use to access the Internet, your Internet service provider’s name, your web browser type, the type of mobile device, your computer operating system, and data about your browsing activity when using our Platform. We use all this information to analyze trends among our users to help improve our Platform.

b. Our Use of Cookies

Our Platform uses cookies. When you enter and use our Platform and agree to accept cookies, some of these coolies may contain your PD. A cookie is a small piece of data or a text file that is downloaded to your computer or mobile device when you access certain websites. Cookies may 4 contain text that can be read by the web server that delivered the cookie to you. The text contained in the cookie generally consists of a sequence of letters and numbers that uniquely identifies your computer or mobile device; it may contain other information as well.

By agreeing to accept our use of cookies you are giving us and the third parties with which we partner permission to place, store, and access some or all the cookies described below on your computer.

• Strictly Necessary Cookies - These cookies are necessary for proper functioning of the Platform, such as displaying content, logging in, validating your session, responding to your request for services, and other functions. Most web browsers can be set to disable the use of cookies. If you disable these cookies, you may not be able to access features on our Platform correctly or at all.

• Performance Cookies - These cookies collect information about the use of the Platform, such as pages visited, traffic sources, users’ interests, content management, and other measurements.

• Functional Cookies - These cookies enable the Platform to remember users’ choices, such as their language, usernames, and other choices while using the Platform. They can also be used to deliver services, such as letting a user create a blog post, listen to audios, or watch videos on the Platform.

• Media Cookies - These cookies can be used to improve a Platforms performance and provide special features and content. They can be placed by us or third parties who provide services to us.

• Advertising or Targeting Cookies - These cookies are usually placed and used by advertising companies to develop a profile of your browsing interests and serve advertisements on other websites that are related to your interests. You will see less advertising if you disable these cookies.

• Session Cookies - These cookies allow a Platform to link the actions of a user during a browser session. They may be used for a variety of purposes, such as remembering what a user has put in their shopping cart as they browse a Platform. Session cookies also permit users to be recognized as they navigate a Platform so that any item or page changes that they make are remembered from page to page. Session cookies expire after a browser session; they are not stored long term.

• Persistent Cookies - These cookies are stored on a user’s device between browser sessions, which allows the user’s preferences or actions across a website or across different websites to be remembered. Persistent cookies may be used for several purposes, including remembering users’ choices and preferences when using a Platform or to target advertising to them.

We may also use cookies for:

• identifying the areas of our Platform that you have visited

• personalizing content that you see on our Platform

• our Platform analytics

• remarketing our products or services to you

• remembering your preferences, settings, and login details

• targeted advertising and serving ads relevant to your interests

• affiliate marketing

• allowing you to post comments

• allowing you to share content with social networks

Most web browsers can be set to disable the use of cookies by going to the preference, tools, or options menu of your browser. Selections you make are device-specific and browser-specific, meaning that you may need to make your selections on each browser and on each device with which you use to access the Platform. If you use social media or other online accounts operated by third parties, you may need to adjust your setting son those accounts to prevent information about your activities on the Platform from being transferred to those third parties. However, if you disable cookies, you may not be able to access features on our Platform correctly or at all.

c. Web Beacons

We may also use a technology called web beacons to collect general information about your use of our Platform and your use of special promotions or newsletters. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails. Web beacons also help us to understand the behavior of our customers and users.

d. Collecting Information About Your Physical Location

When you use our Platform, we may collect and process information about your actual physical location. We use several technologies such as GPS and IP tracking to determine your location. These technologies may also give us information about nearby cell towers, Wi-Fi access points, and other devices.

e. Cross Device Tracking

We use a service that tracks your behavior from device to device. This technology can track your responses from your desktop computer to your laptop, smartphone, and tablet, in any order when using these devices. We use the information we get from this technology to analyze traffic behavior, improve our marketing and advertising.

f. Chat Software and Contact Forms That Sync with Our Platform and Services

Our Platform contains chat software or contact forms that enable visitors to communicate with us live online or offline by email. In some cases visitors can communicate with us without buying our products and services. When you use our chat software or contact forms, we may 6 collect some or all the following information: your email address, first name, last name, location, and any other information you willingly choose to give us. You should limit the information you give to us to one that is necessary to answer your questions.

g. Google Ad and Content Network

Third-party vendors, including Google, use cookies to serve ads based on a user's past visits to our Platform. Google's use of cookies enables it and its partners to serve ads to our users based on their visits to our Platform and/or other websites on the Internet. Users may opt out of the use of Google’s cookies for interest-based advertising by visiting For European users visit

h. Google Analytics

Our Platform uses Google Analytics to collect information about the use of our Platform. Google Analytics collects information from users such as age, gender, interests, demographics, how often they visit our Platform, what pages they visit, and what other websites they have used before coming to our Platform. We use the information we get from Google Analytics to analyze traffic, improve our marketing, advertising, and Platform. Google Analytics collects only the IP address assigned to you on the date you visit our Platform, not your name or other identifying information. We do not combine the information collected using Google Analytics with PD. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you use our Platform, the cookie cannot be used by anyone but Google. Google also uses specific identifiers to help collect information about the use of our Platform.

• For more information on how Google collects and processes your data visit:

• You can prevent Google Analytics from using your information by opting out at this link:

i. Analytics

We use analytics and crash reporting services from companies other than Google to collect information about the use of our Platform. Analytics collects information such as how often users visit our Platform, what pages they visit, when they do so, what other websites they used before coming to our Platform, and their IP addresses. We use the information we get from analytics to improve our services.

j. Google Remarketing

Our Platform uses a remarketing advertising service. Our remarketing service is provided by Google and other companies that show our ads on websites across the Internet. With remarketing you may see ads for our products you have previously looked at. As an example, 7 suppose you visit a website that sells computers, but you do not buy a computer on your first visit. The website’s owner might like to encourage you to revisit his/her website and buy a computer by showing you his/her ads again on other websites that you visit. We use remarketing for similar purposes. For this to happen Google will read a cookie that is already in your browser or place a cookie in your browser when you visit our Platform or other websites using remarketing. You can opt out of Google’s use of cookies and remarketing at this link: or you can opt out using the Network Advertising Initiative opt out page at:!/

k. Facebook or other Social Media Remarketing

Third parties, including Facebook, may use first-party cookies, third-party cookies, web beacons, and other storage technologies to collect or receive information from our Platform and elsewhere on the Internet, and use that information to provide measurement services and target ads. With Facebook remarketing you may see our ads on Facebook after you have used our services. For this to happen Facebook uses unique cookies that are activated and placed in a visitor’s browser when they land on a webpage. Facebook lookalike audience targeting allows us to show ads on Facebook to people who are like those who have already visited or made a purchase from our services. To opt out of Facebook’s collection and use of information for ad targeting visit:

l. What Happens If You Don’t Give Us Your Personal Data

If you do not provide us with enough PD, we may not be able to provide you all our products and services. However, you can access and use some parts of our Platform without giving us your PD.


We may use the information that we collect about you and from you, including PD, for the following purposes.

a. Purpose of the Use of the information

• Provide our products and services you have requested or purchased from us.

• Personalize and customize our content.

• Process and fulfill transactions and services requested by you.

• Make improvements to our Platform and Services.

• To tailor the content and information that we may send or display to you and to personalize your experiences while using the Website.

• Measure the performance of jobs and ads served by our Platform and through a variety of ad network and exchanges.

• Aggregate or anonymize data collected through our Website and Services to create statistics that may be used for any purpose, provided that such statistics to not identify any customers or individuals or contain any PD.

• Process your job application. As a potential applicant for employment, the types of PD you may choose to provide to us include, without limitation: your full name, email address, job title, company information, mailing address, IP address, general location, telephone number, professional and educational information, background information included in a CV/resume, device and usage information, unique identifiers, and cookie data or any other PD that the Company requests or you provide.

• Recruiting, Hiring, and Evaluating Applicants: to review, assess, recruit, consider or otherwise manage applicants, candidates and job applications, including:

o scheduling and conducting interviews;

o identifying candidates, including by working with external recruiters;

o reviewing, assessing and verifying information provided, and otherwise screening or evaluating applicants’ qualifications, suitability and relevant characteristics;

o extending offers, negotiating the terms of offers, and assessing salary and compensation matters;

o satisfying legal and regulatory obligations;

o communicating with applicants regarding their applications and about other similar position(s) for which they may be interested;

o maintaining applicant PD for future consideration; and

o in support of our equal opportunity employment policy and practices.

• Contact you with updates to our Platform, products, and services including potential positions; to identify other positions for which an applicant may be suited or interested, and to contact applicants about such positions. (If you do not wish to be contacted about potential positions, please let us know using the contact information above.)

• Resolve problems and disputes.

• Protect the security of our Platform and Services, and our Users, and prevent, detect, mitigate, and investigate fraud, security breaches, and potentially prohibited or illegal activities.

• Enforce the Privacy Policy, our Terms of Use, and our other policies.

• Verify requests made pursuant to the Privacy Policy. The verification steps and the pieces of personal information that we request may vary depending on the sensitivity and the nature of your request.

• For marketing, advertising and promotional purposes, for example, we may use your PD, such as your email address, to send you news and newsletters, special offers, events, surveys, and promotions, or to otherwise contact you about services or information we think may interest you. We also use the PD that we learn about you to assist us in advertising our Services on third-party websites and social media and to assist us in evaluating the success of our advertising campaigns on various platforms.

• To comply with legal obligations, as part of our general business operations, and for other business, compliance and administration purposes.

• For health and safety purposes, such as contact tracing or including conducting appropriate screenings of applicants and visitors prior to entering or accessing certain locations or premises.

• For other purposes we may notify you of or that you consent to from time to time.

• As otherwise permitted or required by law.

b. Communications and Emails

When we communicate with you, we will use the email address you provided when you registered as a user or customer. We may also send you emails with promotional information about our Platform or offers from us or our affiliates unless you have opted out of receiving such information. You can change your contact preferences at any time through your account or by contacting us using the contact information at the top of this privacy notice.

c. Sharing Information with Affiliates and Other Third Parties

We do not sell or rent your PD to third parties for marketing purposes. However, for data aggregation purposes we may use your NPD, which might be sold to other parties at our discretion. Any such data aggregation would not contain any of your PD. We may give your PD to third-party service providers whom we hire to provide services to us. These third-party service providers may include but are not limited to payment processors, web analytics companies, advertising networks, call centers, data management services, help desk providers, accountants, law firms, auditors, shopping cart and email service providers, and shipping companies.

d. Sharing Your PD With Other

Users Some of your user personal information, including your location, first and last name, business type, LinkedIn and Facebook profiles, current place of work, job position, business name, business address, profile picture, email address, friend connections, spoken languages, business phone number, mobile number, business URL, username, and any image or video content that you have uploaded to our Platform may be displayed to other users to help user interaction within our Platform or address your request for our services. Your privacy settings in your account may let you limit which users can see your PD in your user profile and what information in your profile is visible to others. You understand that any content you upload to your public user profile, including PD, or content that you disclose online in a way that other users can see, including discussion boards, messaging, or other communication mechanisms becomes publicly accessible and can be used by anyone. We do not filter or monitor what is posted on discussion boards. If you post on these discussion boards or other communication devices, you should use care when exposing any PD, as such information is not protected by our privacy notice nor are we liable if you disclose your PD 9 through such postings. If you sign into our Platform through a third-party social networking service or website, your “friends” list from that service or website might be automatically imported to our Platform. We do not have any control over the privacy notices and business practices of other third-party services or websites.

e. Sharing Your PD for Lookalike or Similar Audience Marketing

We may share your PD with third parties for similar audience marketing purposes. Similar audience marketing is also called lookalike audience marketing. The third parties we share your PD with for this type of marketing include Facebook and/or Google. Using your PD for similar audience marketing or lookalike audience marketing helps us find new audiences (users and customers) based on similar interests to yours. This helps us improve our marketing services. Your PD is only shared with Facebook and Google for this type of marketing. By using our Platform and agreeing to our privacy notice you are giving consent for your PD to be used for the marketing purposes described within this section.

f. Sharing Your Information When You Login Using Social Media Websites

We may share your information with third parties such as,,,, and If you decide to login to our Platform using these third parties or other social media websites, you are agreeing to let us use and store your profile information from those websites to make better use of any social media features on our Platform. This sharing of information helps us provide you a better experience when using our Platform and services. It also provides us with useful information such as visitor traffic. If you use any of the social sharing icons on our Platform to share our information, you may also be sharing your personal information through social media websites.

g. Sharing Information With Business Partners

We may share your PD with our business partners. The business partners include general business partners, affiliates, and joint venture partners. We share this information with them so that they can send you information about our products and services as well as their products and services. When you choose to take part in our services and/or offerings, you are authorizing us to provide your email address and other PD to our business partners. Please understand that when we share your PD with our business partners, your PD becomes subject to our business partners’ as well as our privacy notice.

h. Text Messaging and Push Notifications

If you provide a mobile telephone number to us, you are giving your consent and authorize us or a third party to send you text messages and push notifications. You are not required to 10 give us your consent for these text messages and push notifications. However, withholding your consent may interfere or prevent us from providing some or all of our services to you. You can stop receiving text messages and push notifications at any time by contacting us.

i. Legally Required Releases of Information

We may be legally required to disclose your PD if such disclosure is (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or governmental enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our terms and conditions; (d) necessary to protect us from legal action or claims from third parties, including you and/or other users; or (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, users, employees, and affiliates.

j. Disclosures to Successors

If our business is sold or merges in whole or in part with another business that would become responsible for providing our Platform to you, we retain the right to transfer your PD to the new business. The new business would retain the right to use your PD according to the terms of this privacy notice as well as to any changes to this privacy notice as instituted by the new business. We also retain the right to transfer your PD if our company files for bankruptcy and some or all of our assets are sold to another individual or business.

k. Community Discussion Boards, Blogs, or Other Mechanisms

Our Platform may offer the ability for users to communicate through online community discussion boards, blogs, or other mechanisms. We do not filter or monitor what is posted on such discussion mechanisms. If you choose to post on these discussion mechanisms, you should use care when exposing any PD, as such information is not protected by our privacy notice nor are we liable if you disclose your PD through such postings. Also, PD which you post on our Platform for publication may be available worldwide by means of the Internet. We cannot prevent the use or misuse of such information by others.


We retain information that we collect from you (including your PD) only for as long as we need it for legal, business, or tax purposes. Your information may be retained in electronic, paper, or a combination of both forms. When your information is no longer needed, we will destroy, delete, or erase it.


You can update your PD using services found on our Platform. If no such services exist, you can contact us using the contact information found at the top of this privacy notice and we will help 11 you. However, we may keep your PD as needed to enforce our agreements and to comply with any legal obligations.


You have the right to revoke your consent for us to use your PD at any time. Such opt out will not affect disclosures otherwise permitted by law including but not limited to: (i) disclosures to affiliates and business partners, (ii) disclosures to third-party service providers that provide certain services for our business, such as payment processors, web analytics companies, advertising networks, call centers, data management services, help desk providers, accountants, law firms, auditors, shopping cart and email service providers, and shipping companies, (iii) disclosures to third parties as necessary to fulfill your requests, (iv) disclosures to governmental agencies or law enforcement departments, or as otherwise required to be made under applicable law, (v) previously completed disclosures to third parties, or (vi) disclosures to third parties in connection with subsequent contests or promotions you may choose to enter, or third-party offers you may choose to accept. If you want to revoke your consent for us to use your PD, please contact us through the contact information at the top of this privacy notice.


If any postings you make on our Platform contain information about third parties, you agree to make sure that you have permission to include that information. While we are not legally liable for the actions of our users, we will remove any postings about which we are notified, if such postings violate the privacy rights of others.


Some web browsers have settings that enable you to request that we do not track your movement within our Platform. Our Platform does not obey such settings when transmitted to and detected by our Platform. You can turn off tracking features and other security settings in your browser by referring to your browser’s user manual.


Our Platform may contain links to other websites. These websites are not under our control and are not subject to our privacy notice. These websites will likely have their own privacy notices. We have no responsibility for these websites, and we provide links to these websites solely for your convenience. You acknowledge that your use of and access to these websites are solely at your risk. It is your responsibility to check the privacy notices of these websites to see how they treat your PD.


12 Even though our Platform is not designed for use by anyone under the age of 16, we realize that a child under the age of 16 may attempt to access our Platform. We do not knowingly collect PD from children under the age of 16. If you are a parent or guardian and believe that your child is using our Platform, please contact us. Before we remove any information, we may ask for proof of identification to prevent malicious removal of account information. If we discover that a child is accessing our Platform, we will delete his/her information within a reasonable period. You acknowledge that we do not verify the age of our users nor have any liability to do so.


You can always opt out of receiving email correspondence from us or our affiliates. We will not sell, rent, or trade your email address to any unaffiliated third party without your permission except in the sale or transfer of our business, or if our company files for bankruptcy.


You can opt out of receiving text messages from us, text “STOP” in response to any text message or send an email to with “SMS unsubscribe” in the subject line.


We have built our Platform using industry-standard security measures and authentication tools to protect the security of your PD. We and the third parties who provide services to us also maintain technical and physical safeguards to protect your PD. Unfortunately, we cannot guarantee prevention of loss or misuse of your PD or secure data transmission over the Internet because of its nature. We strongly urge you to protect any password you may have for our Platform and not share it with anyone.


You may have to provide a credit card to buy products and services from our Platform. We use third-party billing services and have no control over them. We use commercially reasonable efforts to ensure that your credit card number is kept strictly confidential by using only third-party billing services that use industry-standard encryption technology to protect your credit card number from unauthorized use. However, you understand and agree that we are in no way responsible for any misuse of your credit card number.


PD that we collect from you may be stored, processed, and transferred among any countries in which we operate. The European Union has not found the United States and some other countries to have an adequate level of protection of PD under Article 45 of the GDPR. Our company relies on derogations for specific situations as defined in Article 49 of the GDPR. If you are a European Union customer or user, with your consent your PD may be transferred to the United States or other countries outside the European Union when you request information 13 from us. When you buy goods or services from us, we will use your PD for the performance of a contract or to take steps to enter into a contract. Wherever we transfer, process, or store your PD, we will take reasonable steps to protect it. We will use the information we collect from you in accordance with our privacy notice. By using our Platform, services, or products you agree to the transfers of your PD described within this section.


When using our Platform and submitting PD to us, you may have certain rights under the GDPR if you reside or are in any of the countries of the European Union. Depending on the legal basis for processing your PD you may have some or all of the following rights:

• The Right to Be Informed - You have the right to be informed about the PD that we collect from you and how we process them.

• The Right of Access - You have the right to get confirmation that your PD are being processed and you have the ability to access your PD.

• The Right to Rectification - You have the right to have your PD corrected if they are inaccurate or incomplete.

• The Right to Erasure (Right to Be Forgotten) - You have the right to request the removal or deletion of your PD if there is no compelling reason for us to continue processing them.

• The Right to Restrict Processing - You have the right to ‘block’ or restrict the processing of your PD. When your PD are restricted, we are permitted to store your data, but not to process them further.

• The Right to Data Portability - You have the right to request your PD that you provided to us and use them for your own purposes. We will provide your data to you within 30 days of your request. Contact us using the information at the top of this privacy notice to request your PD.

• The Right to Object - You have the right to object to us processing your PD for the following reasons:

 Processing was based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling)

 Direct marketing (including profiling)

 Processing for purposes of scientific/historical research and statistics

 Rights in relation to automated decision-making and profiling.

• Automated Individual Decision-Making and Profiling - You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects regarding you or similarly significantly affects you.

• Filing a Complaint with Authorities - You have the right to file a complaint with supervisory authorities if your information has not been processed in compliance with the General Data Protection Regulation. If the supervisory 14 authorities fail to address your complaint properly, you may have the right to a judicial remedy.


California Civil Code Section 1789.83, also known as the “Shine the Light” law, permits California residents to request and obtain from businesses a list of what personal information (if any) was disclosed to third parties for direct marketing purposes in the proceeding calendar year and the names and addresses of those third parties. Under Section 1798. 83, we currently do not share your personal information with third parties for direct marketing purposes. This section does not apply to our handling of information that is exempt under the CCPA such as publicly available information, de-identified or aggregated information or information that is covered under another law such as HIPAA or the FCRA. This Policy also does not apply to the Personal Information we collect from our contractors, or our employees, which are subject to different notices. Where we have committed to maintaining and using Personal Data in a deidentified form, we agree not to reidentify deidentified data except as permitted by applicable law.

As a Service Provider under the CCPA, we process or maintain P D on behalf of our customers that provide PD to us in compliance with written contracts that we enter into with our customers directly. Please note that for PD that we process on behalf of a Customer, in our capacity as a processor or service provider, we will provide reasonable assistance to that Customer as necessary to enable them to respond to your requests to exercise your privacy rights.

In general, under the CCPA, we are a Business (as defined under the CCPA) when we operate our Platform (websites and applications) and act as an employer (employee notices are available on the intranet). As described in more detail in Section 4., HOW YOUR INFORMATION IS USED, SHARED, RETAINED, AND UPDATED, we collect, use and otherwise process the above personal information in order to provide our Services to you, respond to and fulfill your orders and requests, as otherwise directed or consented to by you, and for the following business or commercial purposes: services and support, analytics and improvement, customization and personalization, marketing and advertising, planning and managing events, research and surveys, security and protection of rights, legal proceedings and obligations, and general business and operational support.

As a Business, we notify and provide California residents with the following rights with respect to their PD, which are subject to certain exception:

• To opt out of the sale of PD, if any. For information on how to opt out of “sales” or “sharing” of Personal Data (as these terms are defined under the CCPA or other applicable US state privacy laws, and as applicable to Avenu, ExtraHourz and the Company), please refer to Section 16, below.

• To limit certain uses or disclosures of sensitive personal information to those uses authorized by the CCPA (as described below).

• To request deletion of their PD that we have collected about them and have such PD deleted (without charge), subject to certain exceptions. For information on how to exercise such right of deletion, please refer to Section 16, below.

• To request the correction of inaccurate PD.

• To confirm whether we are processing your PD and to access such PD and obtain a copy of the PD in a portable and, to the extent technically feasible, readily usable format and with respect to the PD that the Business has collected about them to require disclosure by the Business of the following (up to twice per year and subject to certain exemptions):

o categories of PD collected,

o categories of sources of PD,

o categories of PD that the Business has disclosed or shared with a third party for a business purpose or sold,

o categories of third parties with whom PD has been disclosed or shared,

o the business or commercial purposes for collecting or selling PD,

o a copy of the specific pieces of PD collected

• Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.

For information on how to exercise such rights, please refer to Section 16, below. While our collection, use and disclosure of Personal Data varies based upon our relationship and interactions with you, we describe, generally, the categories of PD we have collected about California residents in the prior twelve (12) months, as well as the categories of third parties to whom we may disclose this Personal Information for a business or commercial purpose. For more information about the business and commercial purposes, for which we may disclose your Personal Information, please see Section 4. HOW YOUR INFORMATION IS USED, SHARED, RETAINED, AND UPDATED, above.

Personal Data Collected, Third Party Disclosure for Business or Commercial Purposes.

Categories Description Identifies includes name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, or similar information.

• advisors and agents

• government entities and law enforcement

• affiliates and subsidiaries

• advertising networks

• data analytics providers

• social networks

• internet service providers

• operating systems and platforms

• business customer/client

• others as required by law

Also includes identifiers such as Social Security number, passport number and drivers’ license or state identification card number.

• advisors and agents

• government entities and law enforcement

• affiliates and subsidiaries

• others as required by law

Categories of Personal Information Described in Cal. Civ. Code § 1798.80 includes records containing Personal Information, such as name, photographs (if you choose to post on our Website), address, telephone

• advisors and agents

• government entities and law enforcement

• affiliates and subsidiaries

• internet service providers

• operating systems and platforms

• business customer/client

• others as required by law

Education Information includes degrees earned, educational institutions attended, transcripts, training records and other information about your educational history or background that is not publicly available personally identifiable information as defined under the Family Educational Rights and Privacy Act.

• advisors and agents

• affiliates and subsidiaries

• government entities

• internet service providers

• operating systems and platforms

• others as required by law

Professional or Employment-related Information includes Such as performance information, professional membership records, references, assessment records, resumes, cover letters and work history, attendance records, conduct information (including disciplinary and grievance records), and termination data.

• advisors and agents

• government entities and law enforcement

• affiliates and subsidiaries

• internet service providers

• government entities

• operating systems and platforms

• others as required by law

Internet or Other Electronic Network Activity Information includes information regarding your use of our browsing history, clickstream data, search history, and information regarding interaction with our Sites, Apps, or advertisements, including access logs and other activity information related to the use of our Services

• advisors and agents

• government entities and law enforcement

• affiliates and subsidiaries

• advertising networks

• data analytics providers

• social networks

• internet service providers

• operating systems and platforms

• business customer/client

• others as required by law

Characteristics of Protected Classifications includes characteristics of protected classification sunder California and federal laws such as date of birth and gender.

• advisors and agents

• affiliates and subsidiaries

• advertising networks

• internet service providers

• operating systems and platforms

• data analytics providers

• government entities

• data brokers

• others as required by law

Profiles and Inferences includes inferences drawn from other Personal Information that we collect to create a profile reflecting an individual’s preferences and purchase tendencies.

• advisors and agents

• government entities and law enforcement

• affiliates and subsidiaries

• advertising networks

• data analytics providers

• social networks

• internet service providers

• operating systems and platforms

• business customer/client

• others as required by law

We may collect limited “Sensitive Personal Information” (as defined by the CCPA) including: (a) Social Security number and other government identifiers; (b) driver’s license, state identification card, or passport number; (c) precise geolocation;(d) health and disability information (e.g., as necessary to provide reasonable accommodations).

• advisors and agents

• affiliates and subsidiaries

• advertising networks

• data analytics providers

• government entities

• others as required by law

Sale and Sharing of Personal Information. Additionally, the CCPA defines "sale" as disclosing or making available to a third-party Personal Data in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available Personal Data to a third party for purposes of cross-contextual behavioral advertising. While we do not disclose Personal Data to third parties in exchange for monetary compensation, we may disclose the following categories of Personal Data: identifiers, profiles and inferences, and internet or other electric network activity information to third party advertising networks, data analytics providers, and social networks for purposes of marketing and advertising. We do not sell or share Sensitive Personal Information, nor do we sell or share any Personal Information about individuals who we know are under sixteen (16) years old.

Sensitive Personal Information. Notwithstanding the purposes described above, we do not use or disclose of sensitive personal information beyond the purposes authorized by the CCPA. Accordingly, we only use and disclose sensitive personal information as reasonably necessary: to perform our services requested by you; to help ensure security and integrity, including to prevent, detect, and investigate security incidents; to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct; to verify or maintain the quality and safety of our services; for compliance with our legal obligations; to our service providers who perform services on our behalf; and for purposes other than inferring characteristics about you.

We may collect Personal Data from the sources and in the manner set out in Section 3 including: directly from the individual, advertising networks, data analytics providers, social networks, internet service providers, operating systems and platforms, government entities, and data brokers.


ExtraHourz and its subsidiaries including Avenu currently do not sell your information. For purposes of the Privacy Policy, “sell” means the sale, rental, release, disclose, dissemination, availability, transfer, or other oral, written, or electronic communication of your personal information to an outside party for monetary or other valuable consideration. We will not discriminate against you for exercising any of the above rights. You can exercise your rights by contacting us using the information at the top of this privacy notice. We may deny certain requests, or fulfill request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate consumer requests. We take all reasonable cautions to verify your identity in connection with fulfilling its responsibilities under the CCPA. The verification steps may vary, depending on the right and the nature and sensitivity of PD.

We will process your request based upon the information in our records that is linked or reasonably linkable to the information provided in your request. In some cases, additional information may be requested in order to verify your request or where necessary, to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by following the instructions above. Authorized agents will be required to provide proof of their authorization and/or we may also require that the relevant individual directly verify their identity and the authority of the authorized agent.

• To exercise applicable rights to know/access, correct, or delete, please submit a request by: (i) emailing and/or with the subject line “California Privacy Request”; (ii) contacting us via postal mail at the address listed in the top section of this notice.

Do Not Sell or Share my Personal Information: To opt out of the Company’s sale or sharing of your PD, as applicable, visit the “Your Privacy Choices” link in the footer of the Website or use a Global Privacy Control (“GPC”) enabled browser or plug-in. If our website detects that your browser is transmitting a GPC signal, we will apply that to opt-out that browser on your device from targeting cookies on our Website. If you visit our Website from a different device or browser on the same device, you will need to apply GPC for that browser and/or device as well. To learn more about GPC, please visit

You can also control how participating third-party ad companies use the Personal Data that they collect about your visits to our Websites, and those of third parties, in order to display more relevant targeted advertising to you. If you are in the U.S., you can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at (Digital Advertising Alliance). You may also download the DAA App Choices ( tool in order to help control interest-based advertising on apps on your mobile device). In addition, users in other countries may obtain more information at the following links:

• EU Users: (European Interactive Digital Advertising Alliance)

• Canada Users: (Digital Advertising Alliance of Canada)

• Japan: (Data Driven Advertising Initiative in Japan)


We reserve the right to change this privacy notice at any time. If our company decides to change this privacy notice, we will post those changes on our Platform so that our users and customers are always aware of what information we collect, use, and disclose. If at any time we decide to disclose or use your PD in a method different from that specified at the time it was collected, we will provide advance notice by email sent to the email address on file in your account. Otherwise, we will use and disclose our users’ and customers’ PD in agreement with the privacy notice in effect when the information was collected. In all cases your continued use of our Platform, services, and products after any change to this privacy notice will constitute your acceptance of such change. If you have questions about our privacy notice, please contact us through the information at the top of this privacy notice.