Privacy Statement

MarblesHR LLC respects your privacy and is committed to protecting it through our compliance with this statement.

This Privacy Statement (“Statement”) describes the information MarblesHR LLC and its subsidiaries (collectively, “MarblesHR”, “We”, “Us”, or “Our”) may collect from you or that you may provide to us when you visit MarblesHR websites (such as https://www.MarblesHR.com) (collectively “Websites”), as well as other customized subdomains and clientspace.net sites and how the information is used, shared, and secured.

This Statement was last updated on January 26, 2022.

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This Statement applies to information we collect on our websites, in email and other electronic messages between you and MarblesHR, information you provide to us, and information we collect when you use an online service through our websites.

This Statement does not apply to information collected by any third party, including through any application or content, including advertising, which may link to or be accessible from our websites. MarblesHR is not responsible for the privacy practices or the content of those other websites. Please note that this Statement does not apply to information collected via MarblesHR’s products and so ware.

Please read this Statement carefully to understand our practices regarding your information and how we will treat it. If you do not agree with the terms, do not access or use our websites or use our services or any other aspect of MarblesHR’s business. This Statement may change from me to me (see Changes to Our Privacy Statement below) so please check the Statement periodically for updates. If there are any material changes to this Statement, we will no fy you as required by applicable law.

Our websites are not intended for children under the age of 16. We do not knowingly collect personal information from children under 16. If you are under the age of 16, do not use or provide any information on our websites, including providing any information about yourself to us. If we learn we have collected or received personal information from a child under the age of 16 without parental consent, we will delete that information. If you believe we have any information from a child under the age of 16, please contact us (see Help below).

What Information Do We Collect?

Depending on how you interact with us, we may collect personal information that can be used to identify you. Notably personal information does not include publicly available information from government records or deidentified or aggregated consumer information.

In particular, we collect, and have collected within the last twelve months, the following categories of information:

¹ We do not use any process or technique to derive from a device information regarding your physical location or movements. We may, however, collect your address as an identifier.
² If you submit a job application, we may collect information in this category. Our application expressly states our information collection practices.
³ If you submit a job application, we may collect information in this category. Our application expressly states our information collection practices.

We obtain the categories of information listed above from the following sources:

Information you provide to us voluntarily. In general, you can visit our websites without providing any information other than the information we collect automatically. There are times, however, when we may need information from you. You may choose to give us personal information in a variety of situations. For example, we may collect your name, address, email address, telephone number, billing and financial information, or other information you may provide when you engage with our websites to register to use or use any of our services, when you submit a form to contact us, when you register for an event, or request a white paper or other information from us. If you contact us, we maintain records of your correspondence, including your address or email address. We also maintain any information you provide if you participate in one of our surveys.

If you choose not to provide us with certain information, you may not be able to take advantage of certain features of our services.

We may also ask for your personal information when you express an interest in employment opportunities by submitting an application through our website. The information we collect will be apparent at the time you are submitting your application and we will use this information to review,verify, and evaluate your candidacy for a position at MarblesHR. Notice of the categories of information collected and the purposes for which the categories of personal information will be used is included on our application form.

Information we collect automatically. As you navigate through and interact with our websites and services, we may use automatic data collection technologies to collect certain information about your browsing actions, equipment, and patterns including details of your visits to our websites and services and information about your computer and internet connection, including your IP address or device identifier, operating system, and browser type.

The information we collect automatically may include personal information and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. This helps us to improve our websites and services and deliver a more personalized experience by, for example, storing information about your preferences, allowing us to customize our websites according to interests, speed up your searches, and/or recognize you when you return to our websites, improve the content of our websites, provide you with tailored information about our services, provide you with tailored advertisements, and compile reports and analyze how well our websites and services are performing.

Cookies. The technologies we use for this automatic data collection may include cookies. A cookie is a small file sent to your computer as you surf the web. They store useful information about how you interact with the websites you visit.

In order to offer and provide a customized website experience, targeted marketing, and analytical services, MarblesHR may use third party services such as Google Analytics and Google Ad services. These third parties use cookies in various ways and our ability to use and share information collected by such third parties about your activity is subject to such third party’s privacy policy. How Google uses data may be located at www.google.com/policies/privacy/partners/ and their privacy policy may be located here: https://www.google.com/policies/privacy/. We also send Google Analytics your IP Address to track aggregated website behavior to help us improve our website user’s experience. To manage such data collected by Google Analytics, you can delete your Google Analytics cookies by installing the Google Analytics Opt-Out Browser Add-On, or you may contact us (see Help below).

How you can control cookies. You may refuse to accept browser cookies by activating the appropriate setting on your browser, including, for example, setting your browser to refuse cookies or using your browser’s anonymous usage setting. However, if you refuse cookies, this may prevent our websites or services from working properly. You can also set your browser to delete cookies every time you finish browsing.

Third Party Use of Cookies or Other Tracking Technologies. Some content on our websites are served by third parties (for example, through our Marketplace link, https://www.MarblesHR.com/ marketplace/). These third parties may use cookies or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based advertising or other targeted content.

We do not control these third parties’ content, tracking technologies, or how they may be used. If you have questions about an advertisement or other targeting content, you should contact the responsible provider directly.

How Do We Use This Information?

Ways we use your personal information include:

• MarblesHR will use personal information provided to respond to inquiries, support requests, and to contact you in regards to our services.
• MarblesHR may use information provided or collected from your visits to our Websites to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Websites, and via email.
• MarblesHR may use information gathered through our use of cookies to understand how our websites and services are being used and to measure their effectiveness.
• MarblesHR may use personal information you provide when registering for or when you attend a conference or event or when accessing our websites related to a conference or event to:
  • enable you to attend our events
  • plan, coordinate, and host such events
  • analyze your interests in and interactions with the event
  • post photos and recordings of the event online through our websites or social media sites
  • populate online attendee profiles on event mobile applications and allow you to participate in social forums on these platforms if you opt-in to such participation
  • allow you to access MarblesHR products and solutions
  • provide sponsors or partners a conference attendee list if you opt-in to share such information
• MarblesHR may use personal Information for marketing purposes to contact you about our own or third party products and services that may be of interest to you. We provide you the option to opt-out of receiving such information.
• If you visit our offices, you may be required to register as a visitor and provide certain personal information including your name and email address.
• MarblesHR may receive information about you from other sources, including from third parties (for example, from professional networking sites, or from third-party lists that we purchase, where legally permitted). We may combine this information with information provided by you which helps us to update and expand our records, identify new customers, and tailor our advertising and marketing communications.
• To help maintain the safety, security, and integrity of our Websites, products or services, databases and other technology assets, and business, including verifying that you are a person and not a spammer or webbot.
• To notify you about changes to our website or any products or services we offer or provide through it.
• To fulfill any other purpose for which you provide it or for which you consent.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users or clients/customers/other name? is among the assets being transferred.

MarblesHR also provides integrations with a number of third party products and services via APIs. MarblesHR cannot access your data in these services unless you explicitly authorize access. If authorization is granted, MarblesHR uses its access to interact with the third party products and provides added value to you by making the product features and functionality more robust.

If you are submitting information on behalf of a third party (for example, registering a fellow employee for a webinar or conference), MarblesHR expects that you have received appropriate consent, according to applicable privacy laws, before transferring any personal information to MarblesHR.

We will not collect additional categories of information or use the information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, click here below.

What Information Do We Share?

We may disclose aggregated information about users without restriction. We may share your personal information with the following categories of parties:

• With our service providers or contractors to the extent required to fulfill the purposes set forth in our contract with them so that they may provide the contracted services on our behalf (for example, credit card processing services, hiring purposes, an event management portal, detecting security incidents or protecting against fraudulent or illegal activity, debugging or repairing functionality of our systems, or providing marketing or analytical services). They are required to protect your information in the same way we do and will not share it or use it for any other purpose.
• With your consent, MarblesHR may share personal information you provide to us as part of an event or conference registration process with event sponsors or partners that wish to connect with you. Where required, MarblesHR requires that these sponsors or partners guarantee equivalent levels of protection as applied by MarblesHR when handling personal information.
• With your consent, if you are contacting us in your role as an employee of a company or other entity, MarblesHR may also share your personal information with third parties to market their products or services to you.
• For any other purpose disclosed by us when you provide the information.
• We may also disclose your information (including personal information) if we believe in good faith that we are required to do so in order to comply with an applicable law, a subpoena, a search warrant, a court or regulatory order or other valid legal process or lawful requests by public authorities, including to meet national security or law enforcement requirements.
• With a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of MarblesHR’s assets, where personal information held by MarblesHR about our Website users is among the assets transferred.

If you are on our mailing list, you may remove yourself from the mailing list at any time by following the unsubscribe instructions found on our emailed newsletters and communications (see http:// info.MarblesHR.com/UnsubscribePage.html)

Choices

You have choices regarding the personal information you provide to us. The following mechanisms give you control over your personal information:

• Tracking Technologies.You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, some parts of our Websites may be inaccessible or not function properly.

• Disclosure to Third-Parties.. If you do not want us to share your information with third parties for promotional purposes, you can choose not to submit your information on the form giving us permission to share your information, you can opt-out of our sharing your information by checking the relevant box located on the form on which we collect your data, or when contacted by us, you can opt-out of being further contacted by us or tell us you do not want us to share your information with any other party.

If you are on our mailing list, you may remove yourself from the mailing list at any time by following the unsubscribe instructions found on our emailed newsletters and communications (see https:// info.MarbleshR.com/PreferenceInfo.html).

We do not control third parties’ collection or use of your information to service interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way.

Security

MarblesHR respects your personal information and takes steps to protect it from loss, misuse, or alteration. Where appropriate, these steps can include technical measures like firewalls, intrusion detection and prevention systems, unique and complex passwords, and encryption. We also use organizational and physical measures such as training staff on data processing obligations, identification of data incidents and risks, restricting staff access to your personal information, and ensuring physical security including appropriately securing documents when not being used.

Changes to Our Privacy Statement

MarblesHR reserves the right to change this Privacy Statement. If we decide to make changes, we will post the updated statement on our website so you are always aware of what information we collect, how we use it, and the circumstances, if any, we disclose it. The date the privacy statement was last revised is identified at the top of the page. You are responsible for ensuring that we have an up-to-date active and deliverable email address for you, and for periodically visiting our website and the privacy statement to check for any changes. Where required by applicable data protection laws, we will also seek your consent to any material changes that affect how we use your information.

Help

If you need help with unsubscribing, or have questions regarding this privacy statement, please use the form on the Contact Us page or email us at privacy@MarblesHR.com or you can contact us by regular mail addressed to:

MarblesHR

Lakewood, NJ 08701
Attn: privacy@MarblesHR.com

Privacy Notice for California Residents

Effective date: January 26, 2022

This portion of the Statement supplements the information contained in MarblesHR’s general Statement and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). This Statement complies with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Statement.

This Statement does not apply to employment-related personal information collected from California based employees, job-applicants, contractors, or similar individuals. Our privacy practices for these individuals are separately provided as applicable.

Where noted in this Statement, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some requirements.

What Information Do We Share?

We may share your personal information as follows:

For a Business Purpose

With service providers.In the preceding twelve months, MarblesHR may have disclosed the following categories of personal information for a business purpose, such as credit card processing services, hiring purposes, event management services, detecting security incidents or protecting against fraudulent or illegal activity, debugging or repairing functionality of our systems, or providing marketing or analytical services:

• Category A and B: Identifiers and Personal Information as defined in Cal. Civ. Code § 1798.80(e), such as name, postal address, unique personal identifier, online identifier, IP address, email address, or other similar identifiers.
• Category F: Internet or other similar activity, such as browsing and search history and your interaction with our Websites.
• Category I: Professional or employment related information, such as your current employer and job title.

When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sales of Personal Information

With third parties. With your consent, in the preceding twelve months MarblesHR may have disclosed the following categories of personal information that you provided to us as part of an event or conference registration process with event sponsors or partners that may wish to connect with you:

• Category A and B: Identifiers and Personal Information as defined in Cal. Civ. Code § 1798.80(e), such as name, postal address, or other similar identifiers.
• Category I: Professional or employment related information, such as your current employer and job title.

Where required, MarblesHR requires that these sponsors or partners guarantee equivalent levels of protection as applied by MarblesHR when handling personal information.

With third parties. With your consent, if you are contacting us in your role as an employee of a company or other entity, in the preceding twelve months MarblesHR may have disclosed the following categories of personal information with third parties to market their products or services to you:

• Category A and B: Identifiers and Personal Information as defined in Cal. Civ. Code § 1798.80(e), such as name, postal address, or other similar identifiers.
• Category I: Professional or employment related information, such as your current employer and job title.

Other

For any other purpose disclosed by us when you provide the information.

We may also disclose your information (including personal information) if we believe in good faith that we are required to do so in order to comply with an applicable law, a subpoena, a search warrant, a court or regulatory order or other valid legal process or lawful requests by public authorities, including to meet national security or law enforcement requirements.

With a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of MarblesHR’s assets, where personal information held by MarblesHR about our Website users is among the assets transferred.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and con rm your veri able consumer request (see Exercising Access, Data Portability, and Dele on Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not provide these access and data portability rights for B2B personal information.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Dele on Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We do not provide these deletion rights for B2B personal information.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at 1 (866) 212-7655
Emailing us at privacy@MarblesHR.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, you must, unless the authorized agent has been provided with a power of attorney pursuant to Probate Code sections 4000 to 4465:

• Provide the authorized agent written permission to submit your request; and
• Verify your identity directly with MarblesHR
• The authorized agent must be a person or business entity that is registered with the Secretary of State.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information from. The CCPA requires us to verify the identity of the individual submitting a consumer request to access or delete personal information before providing a substantive response to the request. Where possible, we will attempt to verify your identify by asking you to confirm information that we have on file about your or your interactions with us. Where we must ask for additional personal information to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer. You do not need to create an account with us to exercise your rights.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to a total of 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, such as an excel document.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). Our business, as a business-to-business (“B2B”) provider, is targeted to business professionals. Therefore, we do not knowingly collect or sell the personal information of consumers we actually know are less than 16 years of age.

Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: https://info.MarbleshR.com/PreferenceInfo.html

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by clicking here:

Opt-in Instructions

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@MarblesHR.com or write us at:

MarblesHR
1999 Cedarbridge Ave. Suite 2A
Lakewood, NJ 08701
Attn: Privacy Rights Request

Changes to Privacy Notice

We reserve the right to amend this Statement at our discretion and at any time. When we make changes to this Statement, we will post the updated Statement on the applicable Websites and update the Statement’s effective date.

Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Help. Contact Information

If you have any questions or comments about this Statement, the ways in which MarblesHR collects and uses your information described in this Statement, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 866-212-7655
Website: MarblesHR.com
Email: letsroll@MarblesHR.com
Postal Address: POB 286
Lakewood, NJ 08701
Attn: Privacy Rights Request