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1. Introduction. Togetherwork is the parent company of Pennington & Company (“Pennngton”) and Pennington’s activities and policies are governed by Togetherwork. At Pennington and Togetherwork, the privacy and the security of Your data is a top priority. We want to make Your experience with us satisfying and safe. This Privacy Policy is meant to help you understand what information Togetherwork, its Affiliates and its family of global brands ("Togetherwork," "us," "our," or "we") collect, why we collect it and what we do with it. For purposes of this Privacy Policy, our Affiliate is any company that controls, is controlled by or under common control with Togetherwork. We have prepared this Privacy Policy to describe to You, or if You represent an entity or other organization, that entity or organization, (in either case, “You” ) our practices regarding the personal information that we collect, use, share and secure from and on behalf of end users (“Users” ) through our website located at www.togetherwork.com or other Affiliate websites (each, a "Site" ), whether accessing the Site directly or indirectly through a mobile application provided by us (an “Application” ), or when accessing certain services provided through the Site (the “Services” and together with the Site and/or Application, the “Platform” ). Please take a moment to familiarize Yourself with our privacy practices and let us know if You have any questions.

2. Eligibility & Operations within the United States of America.

a. We do not knowingly collect, use or share information that could reasonably be used to identify children under age 13 without prior parental consent or consistent with applicable law. With parental permission, a child under age 13 might have an account with us. We recommend that children ask a parent for permission before sending any personal information anywhere using the Internet.

 b. The Site is controlled and operated from within the United States of America. Any information that we obtain as a result of Your use of the Site may be processed and transferred to the United States and be subject to United States law. The privacy and data collection laws in the United States may not be equivalent to such laws in Your country of residence. Those who choose to access the Site from outside the United States do so on their own volition and are fully responsible for compliance with applicable laws. c. European Union citizens choosing to provide information to Togetherwork are consenting to the processing of personal data for one or more specific purposes to include the performance of a contract and/or service provided by Togetherwork.

3. Terms of Use. For more details on Your rights and obligations when using the Services, please refer to the Terms of Use and other notices, agreements and disclosures regarding the Services.

4. Consent. If You use our Services, You consent to the collection, use and sharing of Your personal information under this Privacy Policy.

5. Links To Other Sites. Our Sites, products, Applications, Platforms and Services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties. Information collected by third parties, which may include such things as location data or contact Page | 2 details, is governed by their privacy practices. We encourage You to learn about the privacy practices of those third parties before transmitting personal information.

6. Changes to this Policy. We may update this Privacy Policy from time to time by posting a new version online. You should check this page occasionally to review any changes. If we make any material changes, we will notify you by posting the revised Privacy Policy on our Site or through our Services, or by other means, to provide You with the opportunity to review changes. Your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means You are consenting to the updated Privacy Policy. You can always visit this page or togetherwork.com to review the most recent version of this Privacy Policy. We will note the effective date of the latest version of our Privacy Policy at the beginning of the Privacy Policy.

7. Personally Identifiable Information We Collect. Personally identifiable information ("PII) refers to information that identifies you personally and may include things like Your name, email address, company name, mailing address, telephone numbers and other information about Yourself or Your business. PII may also include information about transactions, both free and paid, that You enter into on the Site, and information about You that is available on the internet or publicly available information we acquire from service providers. We may collect and combine the following personally identifiable information ("PII") when You interact with our Services and Platform:

a. Information You Provide To Us. We may collect information you provide to us, such as:

i. When You create an account, register for an event or make a payment to or with us. (Please note, when You use our Services, we may recognize You or Your devices even if You are not signed in to our Services.) We may use device IDs, cookies and other signals, including information obtained from third parties, to associate accounts and/or devices with You.

ii. When You use our Services or Platform for any reason, including when you view or click on content, perform a search, install one of our mobile apps, communicate with others, post, upload or store content (such as comments, photos, voice inputs, videos, emails, survey responses, messaging services and attachments).

iii. When you register for an event, including relevant information necessary to conduct the event. Such registration information may include the following information about You and any other individuals You may be registering on the Site: age, camp or event location, parent's names and contact information, health history, medical information, waiver and financial information.

iv. When you call our office via telephone, visit our Sites, send us an email, send us a text message, send us a letter and communicate with us through another messaging service or platform

v. We analyze and store all communications content, including email and text message content from incoming and outgoing mail. This allows us to deliver, personalize and develop relevant features, content, advertising and Services. 

b. Financial Information. We collect and retain financial-related information to facilitate financial transactions for You. The financial information we collect varies depending on the Services You use and may include:

i. Name, date of birth, Social Security number, address, email address, telephone number, and other information we can use to contact You and verify Your identity;

ii. Information that may help us manage our risks, such as information maintained by identity verification services, consumer reporting agencies and credit bureaus;

iii. Individual billing history, membership records and membership payment records;

iv. Vendor names for bills that You would like to view and/or pay online, contact information for those vendors, billing account information and billing account numbers;

v. Bank account information, including account numbers, for accounts that You designate for making or receiving payments, fees, debits and credits for the Services;

vi. Credit card account information, including credit card number, expiration date and billing address, if You submit payments through the Services;

vii. Payment and other transaction information You authorize through the Services;

viii. Payroll information and history maintained through the Platform, including hours worked, pay rates, payroll taxes, personal employee information and other miscellaneous payroll reports; and

ix. Tax information and history, including federal, state, and local income tax returns if You use our Services to file a tax return.

c. Device Information. We may collect information from your devices (computers, mobile phones, tablets, etc.) including information about how You interact with our Services and those of our third-party partners and information that allows us to recognize and associate Your activity across devices and Services. This information includes device specific identifiers and information such as IP address, cookie information, mobile device and advertising identifiers, browser version, operating system type and version, mobile network information, device settings and software data. We may recognize Your devices to provide You with personalized experiences and advertising across the devices You use.

d. Location Information. We may collect location information from a variety of sources including:

i. Pinpointed Physical Location. If You provide permission through your device, browser, or with us directly, we may obtain pinpointed physical location information from technologies like GPS, Wi-Fi, Bluetooth, or cell tower proximity.

ii. Content You provide. We may collect location information from content You provide including attachments, photos, videos and other information

iii. Locations You Entered. We may collect locations You searched for in certain Sites, Applications, advertising services, Platforms and Services. You may be asked to provide a location such as postal code.  We may use this information to provide a starting point for locationaware Services.

iv. IP Address. We may use your IP address to derive information about where Your device is generally located.

v. We may receive location data from third parties that You have linked your account with.

e. User Generated Content. Some of our Site features enable users to submit their own content to access, post original content or comment on blogs, contests, videos, message boards and other functions (“User-Generated Content”). Please remember that any information You disclose in this capacity becomes public information and is visible to other users. Personally identifiable information You submit to one of these forums can be read, collected or used by other individuals for any purpose. We are not responsible for the personally identifiable information You choose to submit as UserGenerated Content. Any User-Generated Content, comments or materials You post to a website or send to us including feedback data, questions, comments, suggestions, or the like regarding the content of any such documents (collectively “Feedback”), shall be deemed to be non-confidential. We shall have no obligation of any kind with respect to such Feedback and shall be free to reproduce, use, disclose, exhibit, display, transform, create derivative works and distribute the Feedback to others without limitation. Further, we shall be free to use any ideas, concepts, know-how or techniques contained in such Feedback for any purpose whatsoever, including but not limited to developing, manufacturing and marketing products incorporating such Feedback.

8. Non-Personal Information We Collect. We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The nonpersonal information we collect includes:

a. Cookies. "Cookies" are small bits of information that the Site places on the hard drive of Your computer when you access content, advertising, Sites, interactive widgets, Applications, our Platform and other technologies. Cookies remember information about Your activities on the Site to make Your visits to the Site more enjoyable and valuable to You by providing a customized experience and recognizing Your preferences when You visit the Site. If You've chosen to disable cookies on Your browser, some of the functionality of the Site may be lost. Certain web pages or services provided by us, require that cookies be enabled in Your browser and cannot be used when You have disabled cookies in Your browser.

b. Flash Cookies. (also called Local Shared Objects or “LSOs”). Flash cookies are data files similar to cookies, except that they can store more complex data. Flash cookies are used to remember settings, preferences, and usage, particularly for video, interactive gaming, and other similar services.

c. Web beacons or clear pixels. Web beacons are small graphic images on a Web page or in an email that can be used for such things as recording the pages and advertisements that You select, or tracking the performance of email marketing campaigns.

d. Web server logs. Web server logs are records of activity created by the computer that delivers the webpages You request to Your browser. For example, a web server log may record the search term You entered or the link You clicked to bring You the webpage. The Web server log also may record information about Your browser, such as Your IP address and the cookies set on Your browser by the server.

e. Other. Other non-personal information such as IP Address, referrer URL, browser type, time-zone, computer platform, location, language, date and time, that are provided by browsers and enable us to monitor Your navigation through the Site and understand usage patterns.

9. Information From Others. We collect information about You when we receive it from other Users, third-parties and Affiliates, such as:

a. From third-party services after you connect Your account to third-party services or sign-in using a third-party partner (like Facebook or Google+).

b. From third-party services after You initiate transactions with the third-party service or provide information to them.

c. From publicly-available sources

d. From advertisers about your experiences or interactions with their offerings

e. From third-parties that use our Services. This may include Your activity on other sites and apps as well as information those third-parties provide to You or us.

f. From Your Specialized Group that has hired us to perform a service for them. One of our primary services is to collect, maintain and manage individually identifiable information about individuals who belong to or engage with one or more membership organization, camp, nonprofit, college/university, school, fraternal organization, church, synagogue, sports league, daycare, pet care facility, athletic gym/organization, union and other specialized group ("Your Specialized Group"). As a result, we maintain contact information, giving and payment information, birth dates, graduation dates, gender and information about Your transactions and involvement with us and Your Specialized Group.

10. How We Use Your Information. We are able to deliver, personalize and improve our Services by combining the information we have about You (including information we receive on and off our Services) to understand how You use and interact with our Services and the people or things You are connected to and interested in. We also may use the information we have about You for the following purposes:

a. Authenticate You and authorize access to our Services and Platform.

b. Provide, maintain, improve and develop relevant features, content and Services.

c. Analyze your content and other information (including emails, instant messages, text messages, posts, photos, attachments and other communications).

d. Fulfill your requests, respond to and resolve customer support issues, billing questions, system issues, or other questions related to Your use of the Platform and Your interactions with Your Specialized Group. We will always verify Your identity before providing any personnel identifiable information over the phone.

e. Contact You through the U.S. post office and other physical mail services, email, text message, push notification, messaging services, notices posted in Page | 6 our Sites, phone and other ways through our Services. We will send messages about how to use the Services, network updates, reminders and other information from Your Specialized Group. You may not be able to opt out of some of the service messages including security and legal notices.

f. Promote membership, affinity and to increase Your engagement in Your Specialized Group

g. Help advertisers and Your Specialized Group connect to offer relevant advertising in their apps and websites

h. Match and serve targeted advertising (across devices and both on and off of our Services) and provided targeted advertising based on your device activity, inferred interests and location information.

i. Associate your activity across our Services and Your different devices as well as associate any accounts You may use across other Togetherwork Affiliate Services together. We may associate activity and accounts under a single user ID.

j. Conduct research and support innovation.

k. Produce aggregate insights that do not personally identify You.

l. Provide location-based Services, advertising, search results and other content consistent with your location settings.

m. Detect, investigate and defend against fraud, abusive or unlawful activity and if we think it’s necessary to investigate possible violations of our User Agreement or this Privacy Policy.

11. How We Share Information. We share information we have about You for the purposes described in this Privacy Policy, including to provide Services You have requested (including when You connect with third-party apps and widgets). We do not rent, license, sell or provide any personally identifiable information about You to other people, organizations or non-affiliated companies outside of Togetherwork unless one of the following circumstances applies:

a. With Your Consent. We will share information with companies, organization or individuals outside of Togetherwork when we have Your consent.

b. With Togetherwork Affiliates. We may share information with Togetherwork Affiliates. Togetherwork Affiliates may use the information in a manner consistent with their privacy policies.

c. With Partners. We may share Your information with nonaffiliated companies who are:

i. Your Specialized Group and Constituents. In order to enhance and strengthen Your affiliation with Your Specialized Group to which You belong, have registered, donated or engaged for services, we may share information about You and some information about You (like contact information, registration information, a news item, contribution or event RSVP) will be available to other members of Your Specialized Group and its affiliates. These other individuals associated with Your Specialized Group may use tools like RSS feeds, mobile phone address books or copy and paste functions to capture and export information about You from the Site. Individuals associated with Your Specialized Group agree, as a condition of use, to use the search functions solely for the convenience of the individual so they may establish connections and contact with other individuals associated with Your Specialized  Group for the sole purpose of conducting the business of the organization.

ii. Trusted Authorized Service Providers. We employ other companies and people to provide services to visitors to our Sites, our customers and Users of the Services and may need to share your information with them to provide information, products or services to you. To protect Your confidential information, we only work with companies, vendors and strategic partners that agree to maintain strong confidentiality protections and limit the use of the information we provide. We do not permit these companies to sell to other third parties the information we provide to them. In order to serve Your needs, we may share information with Trusted Authorized Service Providers who perform certain services on our behalf including, but not limited to:

1. Credit card processors and financial institutions when necessary to process payments made by You and to comply with applicable law;

2. Lawyers and collection agents only when instructed and authorized by our customers to fulfill the terms of our agreement with our customers;

3. The U.S. Post Office, overnight delivery couriers, and other printing, mail house and communications specialists in order to communicate with You ;

4. Trusted companies, vendors and strategic partners with whom we or Your Specialized Group has a strategic relationship or that performs work for us or Your Specialized Group to provide products or services to You;

5. Companies that provide products or services You have requested iii. For Legal and Other Purposes. It is possible that we will need to disclose information about You when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with You, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Togetherwork, our Affiliates, our customers, personnel or others. We will attempt to notify You about legal demands for Your personal information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand. iv. New Ownership. We can also share Your personal information as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use Your data, but only in the manner set out in this Privacy Policy. 

12. Your Choices and Obligations.

a. Data Retention. We retain personal information about You as long as we consider it potentially useful in contacting You about the Services or our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements. If You provide information to Your Specialized Group or our customers as part of their use of the Service, our customers decide how long to retain the personal information they collect from You. If a customer terminates its use of the Service, then we will provide the customer with access to all information stored for the customer by the Service, including any PII and other information provided by You, for export by the customer according to our agreement with our customer. After termination, we may, unless legally prohibited, delete all customer information, including Your PII, from the Service.

b. Rights to Access and Control Your Personal Data. Upon request, we will provide You with information about whether we hold any of Your PII. If You provide us with Your PII, You are entitled to (i) review the information that You have supplied to us and (ii) request we correct any errors, outdated information or omissions in information that You have supplied to us. In addition, You may make choices about sharing by editing Your profile in our Site, turning off cookies on Your browser, and opting out of certain email, push notification or text message correspondence. If You have any questions or concerns please direct them to the contact information below.

13. Security.

a. We take appropriate safety measures (including physical, electronic and procedural safeguards) to protect against unauthorized access as well as anticipated and unanticipated hazards to the information that we store about You.

b. We train our employees to protect customer information. Our employees who have access to confidential information must treat it confidentially and may not disclose it to unauthorized parties. Employees who violate this Privacy Policy are subject to a range of disciplinary actions, including termination. Access is granted to personal information on a need to know basis.

14. Other Contractual Relationships. If you enter into a separate contractual relationship with us or an Affiliate which requires, or contemplates collecting, using, sharing or securing information about you in a manner that is different than that which is described in this policy, the terms of that agreement will apply.

15. California Residents. Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with Togetherwork are entitled to ask Togetherwork for a notice describing what categories of personal customer information we share with third parties for their direct marketing purposes. This notice will identify the categories of information shared with and will include a list of the third parties with which it is shared, along with their names and addresses. If You are a California resident and would like a copy of this notice, please submit a written request to Togetherwork at the addresses listed below under the Section titled “Contact Information.”

16. Contact Information. If You have any questions concerning this Privacy Policy, please contact us by mail at: General Counsel, 1242 Sixth Avenue, Columbus, GA 31901; by phone at 888-554-6634; or by email to info@togetherwork.com.