Privacy Policy

1. INTRODUCTION AND SCOPE

This privacy policy (this "Privacy Policy") covers and describes how Assortment Analytics, LLC and its subsidiaries and affiliates ("Assortment Analytics", "We" or "Us") collect, use, share, secure and disclose the personal data we collect from individuals who interact with www.assortmentanalytics.com and our websites that link to this Privacy Policy or who initiate communications with us ("Visitors"), individuals who register to use our AI-powered assortment intelligence products and services on behalf of a Customer ("Customers"), individuals who register for or attend our marketing events or receive our marketing emails ("Attendees") and individuals who submit an application for a career opportunity at Assortment Analytics ("Job Applicants").

Our websites, applications, and services are designed for retail and CPG businesses and their representatives. We do not target consumers – individuals who seek to use products and services for their personal or household use. Accordingly, we treat all personal data we collect as pertaining to individuals in their business capacity and not their individual capacity.

Assortment Analytics as a Data Processor or Service Provider

In their use of our products and services, Customers may submit data and information to Assortment Analytics to be processed through our AI-powered category intelligence platform. The security and privacy practices governing our Customers' use of our services and how we store, process, transmit and disclose the data submitted to the services by our Customers are described in and governed by our service contracts with our Customers.

To the extent a Customer submits to the services the personal data of European persons (including the United Kingdom and Switzerland) or other persons who are protected by similar data privacy laws, Assortment Analytics processes that personal data as a data processor or as the Customer's sub-processor (as the case may be). Customers are solely responsible for establishing the policies governing, and ensuring compliance with all applicable laws and regulations related to, the Customer's collection and submission of personal data to our services. Any personal data about an individual (i.e., a "data subject") provided to us by a Customer is the responsibility of the Customer and is not covered by this Privacy Policy.

Assortment Analytics acknowledges that you may have the right to access your personal data. Assortment Analytics has no direct relationship with the data subjects whose personal data we process on behalf of our Customers. An individual who seeks to access, correct, amend, or delete personal data about them that we process on behalf of our Customers should direct their requests or queries to our Customer (i.e., the data controller). In addition, we will forward to the applicable Customer any request by a data subject received by Assortment Analytics regarding personal data processed on behalf of that Customer.

Assortment Analytics as a Data Controller

Please read this Privacy Policy carefully to understand the categories and specific pieces of personal data we collect and how we collect, use, disclose, and protect the personal data of our Visitors, Customers, Attendees, and Job Applicants, as well as the choices available to you regarding that information.

International Data Transfers

When Assortment Analytics operates as a data controller (i.e., when we determine the manner, purposes and means of the processing of others' personal information), Assortment Analytics may collect from, transfer to, or process, and store your personal information in the United States and other countries other than the country where you live. When we transfer personal data from the EU, Switzerland, or UK to any other country, we will do so according to an adequate mechanism of transfer as required by applicable laws or regulations.

2. ASSORTMENT ANALYTICS COLLECTION AND USE OF PERSONAL INFORMATION

2.1. What categories and specific types of personal data does Assortment Analytics collect?

Information that we collect from or about you includes the following:

We do not collect any "Special Categories of Personal Data" or Sensitive Information as defined by California Consumer Privacy Act about you. This includes details about your race or ethnicity, religious or philosophical beliefs, financial account information, precise geolocation data, or any other sensitive personal information.

2.2. How does Assortment Analytics collect your personal data?

We collect personal data from and about you through:

• Direct interactions: You may give us your personal data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you request a demo, subscribe to our services, create an account on our website, or contact us.
• Automated technologies or interactions: As you interact with our website, we may automatically collect technical data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.
• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources, including business partners, sub-contractors in technical services, advertising networks, analytics providers, and publicly available sources.

2.3. How does Assortment Analytics use your personal data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• Where we need to comply with a legal or regulatory obligation
• Where you have given your consent for us to process your personal data for a specific purpose

We use your personal data for the following purposes:

• To provide our AI-powered assortment intelligence services
• To process and respond to your inquiries and requests
• To send you marketing communications about our products and services
• To improve our website, services, and customer experience
• To comply with legal obligations and protect our rights
• To analyze usage patterns and optimize our AI models

3. LEGAL BASIS FOR PROCESSING PERSONAL DATA

We process your personal data under the following legal bases:

• Contract Performance: Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract
• Legitimate Interest: Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms
• Legal Obligation: Processing is necessary for compliance with a legal obligation to which we are subject
• Consent: You have given consent to the processing of your personal data for one or more specific purposes

4. HOW WE SHARE YOUR PERSONAL DATA

We may share your personal data with:

• Service Providers: Third-party vendors who perform services on our behalf, such as cloud hosting providers, analytics services, and customer support tools
• Business Partners: Partners who help us deliver our AI-powered analytics solutions to retail and CPG businesses
• Legal Requirements: When required by law, regulation, legal process, or governmental request
• Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business
• Consent: With your explicit consent for any other purpose

We do not sell, rent, or trade your personal data to third parties for their commercial purposes. We may share aggregated, anonymized data that cannot identify you individually for research, analytics, and business purposes.

5. DATA SECURITY

We have implemented appropriate technical and organizational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. Our security measures include:

• Encryption of data in transit and at rest
• Regular security assessments and penetration testing
• Access controls and authentication mechanisms
• Employee training on data protection and security
• Incident response procedures and monitoring systems

However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

6. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personal data, and whether we can achieve those purposes through other means.

In some circumstances, we may anonymize your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

7. YOUR RIGHTS

Depending on your location and applicable law, you may have the following rights regarding your personal data:

• Access: Request access to your personal data
• Rectification: Request correction of inaccurate or incomplete personal data
• Erasure: Request deletion of your personal data
• Restriction: Request restriction of processing of your personal data
• Portability: Request transfer of your personal data to another service provider
• Objection: Object to processing of your personal data
• Withdraw Consent: Withdraw consent where processing is based on consent

To exercise these rights, please contact us using the information provided in the Contact section below. We will respond to your request within the timeframes required by applicable law.

8. CALIFORNIA CONSUMER PRIVACY ACT (CCPA) RIGHTS

If you are a California resident, you have the following rights under the CCPA:

• Right to Know: Request information about the categories and specific pieces of personal information we collect, use, and disclose
• Right to Delete: Request deletion of your personal information
• Right to Opt-Out: Opt-out of the sale of personal information (we do not sell personal information)
• Right to Non-Discrimination: Not be discriminated against for exercising your privacy rights

To exercise your CCPA rights, please contact us using the information provided in the Contact section below.

9. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to collect and use personal data about you. For detailed information about the cookies we use, the purposes for which we use them, and how you can control them, please see our Cookie Policy below.

10. COOKIE POLICY

Published on: January 11, 2025

Effective as of: January 11, 2025, Assortment Analytics, LLC ("Assortment Analytics") and its subsidiaries and affiliates (collectively, "Assortment Analytics", "we", or "us") have adopted this Cookie Policy (this "Policy").

10.1. Introduction

This Policy explains how and when we use cookies on our websites.

10.2. Assortment Analytics uses Cookies

When you visit Assortment Analytics websites, information is stored on your device in the form of a "cookie." Cookies are small files that are stored on your device and save certain settings and data to exchange with our websites via your browser. For example, cookies enable us to tailor a website to better match your interests or remember your username or password so that you do not have to re-enter it every time.

Web beacons and other similar files can perform similar functions and we use "cookie" in this Policy to refer to all files that collect information in this manner.

We as well as our marketing partners and analytics or service providers use cookies and other technologies to ensure everyone who uses our websites has the best possible experience.

10.3. How does Assortment Analytics use Cookies?

When you first visit our websites, we send one or more necessary cookies to your device. Upon your return to our websites, any necessary cookies and other device cookies that you opt in to enable us to recognize your web browsers. Assortment Analytics uses session-based cookies, which last only during one browsing session. A session-based cookie is erased from your device when you close your web browser or turn off your device. Assortment Analytics also uses persistent cookies, which remain on your device after you have closed your browser or turned off your device.

Assortment Analytics may use web beacons, tags and scripts in our websites or in emails to help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our service/analytics providers on an individual and aggregated basis. We use this information collected from web beacons for determining which of our emails are more interesting to you and other users and improve our websites, our services and email communications.

If you opt in to cookies that collect analytics information, we collect analytics information when you use our websites to help us improve them. We may also share data about activity on our websites with third-party service providers for analytics of our website performance.

10.4. Why does Assortment Analytics use Cookies?

Different cookies perform different functions. Some cookies will always be used and some cookies are only used if you opt in to them. For example, we use cookies to analyze how our websites are performing and what content our visitors are interacting with. Certain cookies allow us to improve your experience by recommending or tailoring content displayed to you to improve the relevancy of the information to you. Other cookies permit us to serve targeted advertisements and gather generalized location information about visitors.

We assign our use of cookies according to four categories depending on their function and purpose as set forth in the table below:

10.5. How to Manage and Disable Cookies

If you do not want us to recognize your device, please configure your Internet browser to erase all cookies from your device or to block all cookies. You can control the use of cookies at the individual browser level. Refer to the following links for information to deactivate cookies in commonly used browsers:

• Mozilla Firefox
• Google Chrome
• Safari

Please note that certain functions of our website may no longer work, or not work correctly, without cookies.

If you have any further questions about our Cookie Policy, please send your questions to privacy@assortmentanalytics.com.

11. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Published on" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes.

Changes to this Privacy Policy are effective when they are posted on this page. Your continued use of our services after any changes to this Privacy Policy constitutes your acceptance of those changes.

12. CONTACT INFORMATION

If you have any questions about this Privacy Policy or our data practices, please contact us: