Privacy Policy

Effective Date: July 15th, 2023

Introduction

Centigrade, Inc. and its subsidiaries and affiliated companies (“Centigrade”, “we”, “our”, “us”) understand and respect our users’ need for privacy. This Centigrade Privacy Policy (“Privacy Policy”) explains how Centigrade collects, uses, and shares information we collect about you when you use our websites (including our company website www.centigrade.earth, the “Site”), and when you interact with our services.

This Policy applies when you interact with us through our Services. It also applies anywhere it is linked. It does not apply to third-party websites, mobile applications, or services that may link to the Services or be linked to from the Services. Please review the privacy policies on those websites and applications directly to understand their privacy practices.

We may change this Policy from time to time. If we do, we will notify you by posting the updated version.

How We Collect Your Information

Information We Collect From Our Websites and Events:

Information You Provide to Us: We collect information you provide directly to us when you browse our Site, create an online account, post messages to our forums or wikis, provide feedback through surveys, participate in any interactive features, contests, promotions, sweepstakes, activities, or events. The types of information we may collect include: your name, email address, username, password, location and any other information you choose to provide.

Information We Collect Automatically Through the Use of Cookies and Other Tracking Technology: When you visit the Company’s website, we obtain certain information by automated means, such as cookies, web beacons, web server logs, and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to identify the visitor’s browser or to store information or settings in the browser. A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

We may use these automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner may include: your device IP address, identifiers associated with your devices, types of devices connected to our services, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data and dates and times of visits to our Site.

The information we collect through cookies and similar technologies helps us (1) remember your information so you will not have to re-enter it; (2) understand how you use and interact with our website; (3) measure the usability of our website and the effectiveness of our communications; and (4) otherwise manage and enhance our website, and (5) help ensure it is working properly.

Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all the features of our website.

How We Use Your Information

We may use any of the information we collect for the following purposes.

Centigrade Websites and Events:

Centigrade collects this data for various purposes, including to:

• Respond to your comments, questions and requests, and provide customer service;
• Monitor and analyze trends, usage, and activities in order to operate and improve our Site;
• Manage your online account(s) and send you technical notices, updates, security alerts and support and administrative messages;
• Carry out any other purpose for which the information was collected.

How We Share Your Information

Centigrade Websites and Events:

We may share your personal information as follows:

• With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
• In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule, or regulation;
• If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property, and safety of us or any third party;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; and
• With your consent or at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Please see the Appendix C to this Privacy Policy for a list of sub-processors that Centigrade uses to provide its various services.

Security

We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Services. While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

Location of Processing

Centigrade’s headquarters are in the United States, and it has offices around the world. In providing its services, Centigrade may process your personal information on servers outside the country where you live, including to countries that do not have the same data protection laws as your country. Although the data protection laws of various countries may differ from those in your own country, we take appropriate steps to ensure that your personal information is processed as described in this Privacy Policy and under the law.

If you are located in the European Economic Area, please see the “Transfer of Personal Information to Other Countries” section in Appendix B for more information.

How We Protect Your Information

We are committed to protecting your information. We maintain appropriate administrative, technical, and physical safeguards designed to protect the personal information you provide against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

How Long We Retain Your Information

We will retain your personal information on file for as long as necessary for our legitimate business purposes. Please note that in certain cases, legal or regulatory obligations require us to retain specific records for a longer period of time.

Children’s Information

Our Services are not directed to children under the age of 18. If you learn that a child under the age of 18 has provided us with personal information without consent, please contact us.

Your Rights

You have the right to request a copy of your information, to object to our use of your personal information (including for marketing purposes), where applicable, to correct your personal information, to request the deletion or restriction of your personal information, or to request your personal information in a structured, electronic format.

Please note that we may retain certain information as required by law or for legitimate business purposes. If you would like to exercise any of these rights, please contact privacy@centigrade.earth.

Depending on where you are located, you may have certain rights in connection with your personal information that we obtain. These rights vary depending on your jurisdiction. To learn more about your rights, see:

• Appendix A for CCPA rights if you are a California resident.
• Appendix B for GDPR rights if you are located in the EEA or United Kingdom.

Changes To This Privacy Policy

We periodically review and update this Privacy Policy to describe new services or changes to our practices. You can determine when this Privacy Policy was last revised by referring to the “Updated” date at the top of this document. We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our privacy practices and the ways that you can help protect your privacy.

Appeals

Residents of Colorado, Connecticut, and Virginia have the right to appeal a denial of their request by contacting us as described in the notice of denial.

Third-Party Services, Applications, and Websites

Certain third-party services, websites, or applications you use, or navigate to from our Services may have separate user terms and privacy policies that are independent of this Policy. This includes, for example, websites owned and operated by our customers or partners. We are not responsible for the privacy practices of these third-party services or applications. We recommend carefully reviewing the user terms and privacy statement of each third-party service, website, and/or application prior to use.

Contacting Us

To submit questions regarding this Privacy Policy, you can contact Centigrade by emailing us at privacy@centigrade.earth or at our mailing address at:

Centigrade, Inc.
Attention: General Counsel
315 Montgomery Street, 2nd Floor
San Francisco, CA 94104
U.S.A.

Appendix A: California Consumer Privacy Act Addendum

Additional provisions applicable to processing personal information of California residents.

Scope and Applicability

This Appendix A to the Privacy Policy (“Appendix A”) applies to California residents and outlines individuals’ rights and choices with respect to the processing of your personal information under the California Consumer Privacy Act (“CCPA”). This Appendix A controls to the extent it conflicts with any provision in the main body of the Privacy Policy.

Data Collection, Use and Sharing

The CCPA requires that we inform individuals whether we collect any categories of personal information as classified under the CCPA, and whether we share this information with selected recipients for specific purposes.

Categories of Information

We collect the following categories of information as classified under CCPA:

• Personal identifiers – We collect name, IP address, email address, and username.
• Internet or other network activity information – We collect IP address, device information, clickstream data, and dates and times of visits to our Site.
• Geolocation – We collect geolocation information directly from Site visitors and, on a less granular level, automatically on the Centigrade platform through the use of cookies and related technologies.

Please see the “How We Collect Your Information” section in our Privacy Policy to see the full description of the information that we collect.

Publicly Available Information: Personal information does not include publicly available information. For purposes of this paragraph, “publicly available” means information that is lawfully made available from federal, state, or local government records.

Sharing Information

We share the information collected with third-party service providers such as suppliers, vendors, business partners (e.g., advertising partners, consultants) to operate our business. We do not sell personal information.

Using Information

We collect and use personal information to:

• Respond to your requests for information
• Conduct internal research and development;
• Improve the quality and safety of our products and services; AND
• Detect security incidents and prevent fraud.

Please see the “How We Use Your Information” section in the Privacy Policy for a full description of how we use personal information.

Your CCPA Rights

The CCPA grants California consumers certain rights in connection with the personal information we collect, as described below.

• Right to Know: You have the right to know the categories and specific pieces of your personal information we have collected in the previous 12 months.
• Right to Deletion: You have the right to request that we delete any of your personal information we have collected.
• Right to Request Information: You have the right to request information about the collection, sale, and disclosure of your personal information from the previous 12 months.
• Right to Opt-out of the Sale of Information: You have the right to opt-out of the sale of personal information we have collected about you.
• Right to Non-Discrimination: You have the right to not receive discriminatory treatment for exercising any of your CCPA rights. We do not treat individuals differently for exercising any of the rights described above.

Exercising Your Rights

If you wish to exercise any of the above rights, see the “Contact Us” section in this Appendix A. You may also authorize an individual to submit a verifiable consumer request relating to your personal information.

We verify your request using your email address. Government identification may be required. We cannot respond to your request if we cannot verify your identity and/or authority to make the request on behalf of another and confirm the personal information relates to you.

If you wish to use an authorized agent to submit a request to opt-out on your behalf, you must provide the authorized agent written permission signed by you, the consumer. We may deny a request from an authorized agent if the agent cannot provide Centigrade with your signed permission demonstrating that the agent is authorized to act on your behalf.

We fulfil requests within 45 days of receiving your request. Please note that your request may be limited in certain cases, for example if complying with your request would conflict with:

• Federal, state, or local law;
• Regulatory inquiries;
• Subpoenas; or
• Exercising or defending legal claims.

Contact Us

To submit questions regarding this Privacy Policy, you can contact Centigrade by emailing us at privacy@centigrade.earth or at our mailing address at:

Centigrade, Inc.
Attention: General Counsel
315 Montgomery Street, 2nd Floor
San Francisco, CA 94104
U.S.A.

Appendix B: General Data Protection Regulation Addendum

Additional provisions applicable to the processing personal information of individuals based in the European Economic Area (“EEA”) and the United Kingdom (“UK”).

Scope and Applicability

This Appendix B to the Privacy Policy (“Appendix B”) applies to individuals based in the EEA and UK and outlines their rights and choices regarding the processing of their personal information under the General Data Protection Regulation or related regulations (collectively, the “GDPR”). Capitalized terms not defined in this Appendix B are defined in the Privacy Policy above

Data Collection, Use, and Sharing

We collect and process personal information about you only where we have a legal basis for doing so under applicable data protection laws. Our legal bases include processing personal information under:

• Your consent: Where appropriate or legally required, we collect and use information about you subject to your consent. For example, we collect your email address when you sign up for emails and updates on the Centigrade Services.
• Legitimate interests: We collect and use information about you for our legitimate interests to deliver content, optimize your experience, and market the Centigrade Services. For example, we collect your IP address and device information when you use the Centigrade Services to prevent malicious activity.
• Compliance with laws: We may also collect and use information about you:
  • As required by law, such as to comply with a subpoena or similar legal process;
  • When we believe in good faith that disclosure is necessary to protect our rights or property, protect your health and safety or the health and safety of others, investigate fraud, or respond to a government request; or
  • If we participate in a merger, acquisition, or sale of all or a portion of its assets.

Transfer of Personal Information to Other Countries

We transfer your personal information to countries outside the United Kingdom and the European Economic Area (“EEA”), including, but not limited to the United States, where Centigrade Corporate Headquarters is located, and where our IT systems (including email) are located. When required, we may transfer and store personal information to locations in or outside the European Economic Area (“EEA”).

If we transfer your personal information out of the European Economic Area, United Kingdom, or Switzerland and are required to apply additional safeguards to your personal information under European data protection legislation, we will do so. Such safeguards may include applying the European Commission-approved standard contractual data protection clauses or other appropriate legal mechanisms.

Data Subject Rights

You have certain rights related to your personal information when you access the Centigrade website. Some of these rights only apply in certain circumstances, as set out below. We also describe how to exercise these rights in the “Exercising your Rights” section of this Appendix B.

The GDPR provides data subjects with the following rights:

• Right of Access: Data subjects have the right to request access and receive certain information about how we use their personal information and who we share it with.
• Right to Rectification: Data subjects have the right to request correction of personal information we hold about them where it is inaccurate or incomplete.
• Right to Data Portability: Data subjects have the right to request a copy of data we hold about them in a structured, machine-readable format, and to ask us to share this information with another entity.
• Right to Erasure: Data subjects have the right to request deletion of the personal information we hold about them:
  • Where one believes that it is no longer necessary for us to hold their personal information;
  • Where we are processing personal information based on legitimate interests and a data subject objects to such processing, and we cannot demonstrate an overriding legitimate ground for the processing;
  • Where a data subject has provided their personal information to us with consent, and they wish to withdraw their consent and there is no other ground under which we can process their personal information; or
  • Where a data subject believes their personal information is being unlawfully processed by us.
• Right to Restriction of Processing: Data subjects have the right to ask us to restrict (stop any active) processing of their personal information:
  • Where they believe their personal information is inaccurate and while we verify accuracy;
  • Where we want to erase their personal information as the processing is unlawful, but they want us to continue to store it;
  • Where we no longer need their personal information for our processing, but they require us to retain the data for the establishment, exercise, or defense of legal claims; or
  • Where they have objected to us processing their personal information based on our legitimate interests and we are considering their objection.
• Right to Object: Data subjects can object to our processing of their personal information based on our legitimate interests. We will no longer process their personal information unless we can demonstrate an overriding legitimate purpose.
• Objection to Marketing, Automated Decision Making, and Profiling: Data subjects have the right to object to our processing of personal information for marketing communications, automated decision making and profiling. We will stop processing the data for that purpose.
• Withdrawal of Consent: Where a data subject has provided consent for us to process their personal information, they can withdraw their consent by emailing privacy@centigrade.earth.

Please note that before we respond to requests for information, we will require that identity verification, or the identity of any data subject for whom one is requesting information. Our verification methods may include requesting that the data subject log into their Centigrade account, confirm their contact information or email address, and/or provide documents for identity verification.

Centigrade commits to resolve complaints about our collection or use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints should first contact Centigrade using the contact information provided below.

Exercising Your Rights

To exercise any of the rights above, please contact us as noted in the “Contact Us” section in this Appendix B. If you are a Customer end user, contact the applicable Customer acting as the data controller directly to fulfill any requests.

We will fulfill your request within 30 days of receipt. Please note that the above rights may be limited in the following situations:

• Where fulfilling your request would adversely affect other individuals, company trade secrets or intellectual property;
• Where there are overriding public interest reasons; or
• Where we are required by law to retain your personal information.

If you have unresolved concerns, we encourage you to come to us in the first instance, but you are entitled to address any grievance directly to the relevant supervisory authority. If you are a Customer end user, we encourage you to reach out to the relevant Customer first to address any complaints.

Contacting Us

To submit questions regarding this Privacy Policy, you can contact Centigrade by emailing us at privacy@centigrade.earth or at our mailing address at:

Centigrade, Inc.
Attention: General Counsel
315 Montgomery Street, 2nd Floor
San Francisco, CA 94104
U.S.A.