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Ace East LLC (“Ace East”, “we”, “our” and “us”) provides this Privacy Policy to let you (“you”) know our policies and procedures regarding the collection, use and disclosure of information through our website www.aceeast.net (the “Website”), and any other websites, features, applications, widgets or online services that are owned or controlled by Ace East LLC and that post a link to this Privacy Policy (together with the Website, the “Service”), as well as any information Ace East LLC collects offline in connection with the Service.

This Privacy Policy is incorporated by reference into our Terms of Service.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not access or use the Service. By accessing or using the Service, you agree to this Privacy Policy.

1. INFORMATION COLLECTION

Information You Provide to Us

When you use the Service, you may provide us with information about you. This may include your name and contact information, financial information to make or receive payment for services obtained through the Ace East LLC platform, or information to help us fill out tax forms.

  • Personal Information: In the course of using the Service, we may require or otherwise collect information that identifies you as a specific individual and can be used to contact or identify you (“Personal Information”). Examples of Personal Information include your name, email address, company address, billing address, and phone number.

  • Payment Information: If you use the Service to make or receive payments, we will also collect certain payment information, such as credit card, banking or other financial account information, and billing address.

  • Identity Verification: We may collect Personal Information, such as your date of birth or taxpayer identification number, to validate your identity or as may be required by law, such as to complete tax filings. We may request documents to verify this information, such as a copy of your government-issued identification or photo or a billing statement.

  • Biometric Identifiers or Service Interaction Information: We may collect Personal Information such as a photograph of your face, a selfie, or data about your interactions with the Service to verify your identity and to detect fraud, identity theft, or other misuse of your account through the use of facial recognition and other technologies. We may request documents to verify this information, such as a copy of your government-issued identification. From time to time, Ace East LLC may require you to take and submit an additional or updated image of your face for comparison to your government-issued identification. The biometric identifiers or information collected are used only for identity verification and platform security and use integrity purposes.

  • General Audience Service: The Service is general audience and intended for users 18 and older. We do not knowingly collect Personal Information from anyone younger than age 18. If you are under 18, you are not permitted to provide any information to or on the Service (including any information about yourself, such as your name, address, telephone number, email address or any screen name or username you may use). If we become aware that a child younger than 18 has provided us with Personal Information, we will delete such information from our files.

  • Combination of Personal and Non-Identifying Information: Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers in a way that enables you to be identified (for example, combining information with your name). But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifying Information, but Ace East LLC will treat the combined information as Personal Information.

You do not have a statutory obligation to provide us with any information, but you may have a contractual obligation to do so, and if we do not receive certain information from you, then we will not be able to provide our Service to you. If you have any questions regarding whether provision of information is mandatory and the consequences for withholding such information, please contact us using the contact information below.

Information Collected Automatically

Like other companies, we receive technical information when you use our Services. We use these technologies to analyze how people use the Service, to improve how our Website functions, to save your log-in information for future sessions, and to serve you with advertisements that may interest you.

We and our third party service providers, including analytics and third party content providers, may automatically collect certain information from you whenever you access or interact with the Service. This information may include, among other information, the browser and operating system you are using, the URL or advertisement that referred you to the Service, the search terms you entered into a search engine that led you to the Service, areas within the Service that you visited, which links you clicked on, which pages or content you viewed and for how long, other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages and other information commonly shared when browsers communicate with websites. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, and to improve marketing, analytics, and site functionality.

The information we collect also includes the Internet Protocol (“IP”) address or other unique device identifier (“Device Identifier”) for any device (computer, mobile phone, tablet, etc.) used to access the Service. A Device Identifier is a number that is automatically assigned or connected to the device you use to access the Service, and our servers identify your device by its Device Identifier. Some mobile service providers may also provide us or our third party service providers with information regarding the physical location of the device used to access the Service.

Ace East LLC uses cookies or similar technologies to analyze trends, administer the website, track users’ movement around the Website and the Ace East LLC desktop app (the “App”) to gather demographic information about our user base as a whole. The technology used to collect information automatically from users may include the following:

  • Cookies: Like many websites, we and our marketing partners, affiliates, analytics, and service providers use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use both persistent cookies that remain on your computer or similar device (such as to save your registration ID and login password for future logins to the Service and to track your compliance with the Ace East LLC Terms of Service) and session ID cookies, which expire at the end of your browser session (for example, to enable certain features of the Service, to better understand how Ace East LLC users interact with the Service and to monitor aggregate usage by Ace East LLC users and web traffic routing on the Service). You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functionality of the Service.

  • Web Beacons: We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as “web beacons” and/or “tracking tags” to help us keep track of what content on our Service is effective and to serve relevant advertising to you. Web beacons are small graphics with a unique identifier that may be invisible to you, and which are used to track the online activity of Internet users. Web beacons are embedded in the web pages you review or email messages you receive. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our Service, to monitor how our users navigate the Service, to count how many messages that were sent were actually opened, or to count how many particular articles or links were actually viewed.

  • Embedded Scripts: We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as an Embedded Script. An Embedded Script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your computer or other device and is deactivated or deleted when you disconnect from the Service.

In addition, we and our marketing partners, affiliates, analytics, and service providers may use a variety of other technologies (such as tags) that collect similar information for security and fraud detection purposes and we may use third parties to perform these services on our behalf.

How we respond to do not track signals

Ace East LLC does not respond to Do-Not-Track signals.
Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, Ace East LLC does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.

User Profiles

You may have the opportunity to create a profile, which consists of information about you, and may include Personal Information, photographs, examples of your work, information on work previously performed via the Service and outside the Service, skills, feedback/rating information and other information, including your username (“Profile”). You may edit certain information in your Profile via your account settings page. Clients and Agencies of associated individual users or companies may also have the opportunity to create an organization Profile. If, in any case, you believe that an unauthorized profile has been created about you, you can request for it to be removed by contacting us at contact@aceeast.net.

Identity Verification

We place a premium on trust in our Service, so we may take steps to verify your identity. Before you can complete registration on the Service, or at any time thereafter, we may request or re-request identity verification. Without limiting the manner in which we request identity verification, we may require you to participate in a video call after submitting your government issued ID to enable us to confirm that you are indeed the individual in the ID. We may record such video calls and take screenshots of you during the call. Ace East LLC may use the information obtained from Identity Verification for purposes of verifying your identity, enforcing our Terms of Service and other agreements, and preventing fraud.

2. USE OF INFORMATION

We use information collected through the Service to provide and improve the Service, process your requests, prevent fraud, provide you with information and advertising that may interest you, comply with the law, and as otherwise permitted with your consent.

We Use Information We Collect:

  • To provide and improve the Service, complete your transactions, address your inquiries, process your registration, verify the information you provide is valid, give you notices about your account, and for compliance and internal business purposes.

  • To tailor content we display to you and offers we may present to you, both on the Service and elsewhere online.

  • To administer and develop our business relationship with you and, if applicable, the corporation or other legal entity you represent.

  • To enforce and comply with the law, including to conduct an investigation, to protect the property and rights of Ace East LLC or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or legally actionable activity.

  • For the purposes disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy.

We use your Personal Information for the purposes described above:

  • To Honor Our Contractual Commitments to You. Much of our processing of Personal Information is to meet our contractual obligations, or to take steps at users’ request in anticipation of entering into a contract with them.

  • For Our Legitimate Interests. In many cases, we handle Personal Information on the grounds that it furthers our legitimate interests in commercial activities, such as the following, in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:

    • Providing our Website and Service.

    • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.

    • Measuring interest and engagement in our Services.

    • Improving, upgrading or enhancing our Services.

    • Developing new products and services.

    • Ensuring internal quality control and safety.

    • Authenticating and verifying individual identities.

    • Debugging to identify and repair errors with our Services.

    • Auditing relating to interactions, transactions and other compliance activities.

    • Enforcing our agreements and policies.

    • Analyzing and improving our business.

    • Communications, including marketing and responding to your inquiries about our services.

    • Addressing information security needs and protecting our users, Ace East LLC, and others.

    • Managing legal issues.

  • To Comply with Legal Obligations. We need to use and disclose Personal Information in certain ways to comply with our legal obligations.

3. DATA RETENTION

We store the personal information we collect as described in this Privacy Policy for as long as you use our Service or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. Following termination or deactivation of an account, we may retain information and content for backup, archival, audit or other business purposes, or otherwise in accordance with applicable laws. We may maintain anonymized, de-identified or aggregated data, including usage data, for analytics purposes. If you have any questions about data retention or deletion, please email contact@aceeast.net.

4. INFORMATION SHARING AND DISCLOSURE

We may share information about you to provide the Services, for legal and investigative purposes, in connection with marketing and promotions, or if we are part of a merger or acquisition. We may also share non-identifying information with third parties. You have choices as to whether we share your personal information with third parties for their own marketing purposes.

We may share aggregated Non-Identifying Information and we may otherwise disclose Non-Identifying Information to third parties. We may disclose anonymized, de-identified or aggregated information about our users, and information that does not identify any individual, without restriction. We may also share aggregated, non-personally identifiable information publicly, including with users, partners or the press in order to, for example, demonstrate how the Service is used, evaluate industry trends, or to create our marketing materials. Any aggregated information shared this way will not contain any personal information.

We do not share your Personal Information with third parties for those third parties’ marketing purposes unless we first provide you with the opportunity to opt-in to or opt-out of such sharing. We may also share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information, with your consent, as otherwise described in this Privacy Policy, or in the following circumstances:

  • Information about Consultants Shared with Clients, Agencies, and Ace East LLC Payment Vendors: We share information regarding Consultants who have entered into a project with an individual Client or Agency or who have connected to Ace East LLC’ payment vendor for the payment of completed projects. Note that if a Consultant is suspended from our Service, we may share that information with Clients for whom that Consultant has worked. We may also share information with Clients to whom Consultants are associated for a particular work project. We may share relevant information with applicable Clients seeking project work in your designated zip code area, including, but not limited to, the information contained in your Consultant Profile.

  • Information about Client Agencies Shared with Consultants: If you have entered into a service contract or agreed to use Ace East LLC’ platform to retain a Consultant for a project, we may provide him/her with your name, company address, billing address, or tax ID or VAT number in order to complete the transaction or to facilitate the resolution of a claim or dispute. The user receiving your information is not allowed to use it for purposes unrelated to the transaction, such as to contact you for marketing purposes, unless you have expressly consented to it.

  • Service Providers: We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services (e.g., without limitation, maintenance services, database management, web analytics and online advertising, payment processing, fraud detection and improvement of Ace East LLC’ features) or to assist us in analyzing how our Service is used. These third parties may have access to your Personal Information in order to perform these tasks on our behalf.

  • What Happens If You Agree to Receive Information from Third Parties or Request that We Share Your Information: You may be presented with an opportunity to receive information and/or marketing offers from one or more third parties. If you agree at that time to have your Personal Information shared, your Personal Information will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party. We are not responsible for the privacy policies and practices of third parties, and, if you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly. You also may request, sometimes through your use of an SNS or similar interactive feature or third party application, that we share information about you with a third party and we will typically do so under those circumstances.

  • Legal and Investigative Purposes: Ace East LLC will share information with government agencies as required by law in response to lawful requests by public authorities, including to meet national security or law enforcement requirements and, including without limitation, in connection with reporting earnings. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), or, at the request of governmental authorities or other third parties conducting an investigation where we determine in our sole discretion the disclosure is necessary to (a) protect the property and rights of Ace East LLC or a third party, (b) protect the safety of the public or any person, or (c) prevent or stop activity we may consider to be, or pose a risk of being, illegal, fraudulent, unethical or legally actionable activity.

  • Internal and Business Transfers: Ace East LLC may share information, including Personal Information, with any current or future subsidiaries or affiliates, primarily for business and operational purposes, including activities such as IT management, for them to provide services to you, or support and supplement the Services we provide. We may sell, transfer, or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due-diligence process with any potential acquiring entity) or in the event of bankruptcy.

Ace East LLC disclaims all liability for the disclosure of information (including health information) that you choose to submit voluntarily. You assume all such risks with regards to your use of the Service.

5. THIRD PARTY ANALYTICS PROVIDERS, AD SERVERS AND SIMILAR THIRD PARTIES

We may work with advertising agencies and vendors who use technology to help us understand how people use our Website. These vendors may use technologies to serve you advertisements that may interest you. You can choose to opt out of receiving interest-based advertising.

Ace East LLC works with (or may in the future work with) network advertisers, ad agencies, analytics service providers and other vendors to provide us with information regarding traffic on the Service, including pages viewed and the actions taken when visiting the Service; to serve our advertisements on other websites, within mobile apps and elsewhere online; and to provide us with information regarding the use of the Service and the effectiveness of our advertisements. Our service providers may collect certain information about your visits to and activity on the Service as well as other websites or services, they may set and access their own tracking technologies on your device (including cookies and web beacons), and may use that information to show you targeted advertisements. Some of these parties may collect Personal Information when you visit the Service or other online websites and services. We may also share certain Non-Identifying Information with these parties in connection with the services they provide to us.

6. YOUR CHOICES AND RIGHTS

According to applicable law, you may have certain choices and rights associated with your personal information.

Communication Preferences

  • Registered users may update their choices regarding the types of communications you receive from us through your online account.

  • You may opt-out of receiving marketing emails from us by following the opt-out instructions provided in those emails. Please note that we reserve the right to send you certain communications relating to your account or use of the Service (for example, administrative and service announcements) via email and other means and these transactional account messages may be unaffected if you opt-out from receiving marketing communications.

  • You may opt-out of receiving text messages by replying “STOP” to any text message received.

  • Registered users who access the Service by using a Ace East LLC mobile application may, with permission, receive push notifications. Similarly, registered users who access the Service by using certain desktop browsers may, with permission, receive push notifications. Notification preferences can be modified in the settings menu for the mobile application or the applicable browser.

Data Subject Rights.

In accordance with applicable law, you may have the right to:

  • Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information.

  • Request Correction of your personal information where it is inaccurate, incomplete or outdated. In some cases, you can update your personal information within your Ace East LLC account by logging in and visiting settings/user settings.

  • Request Deletion, Anonymization or Blocking of your personal information when processing is based on your consent or when processing is unnecessary, excessive or noncompliant. Note that if your information is deleted, then your account may become deactivated. If your account is deactivated or you ask to close your account, you will no longer be able to use the Service. If you would like to close your account in our system, you can do so by contacting a Ace East LLC administrator via email at contact@aceeast.net

  • Request Restriction of or Object to our processing of your personal information when processing is noncompliant.

  • Withdraw your Consent to our processing of your personal information. If you refrain from providing personal information or withdraw your consent to processing, some features of our Service may not be available.

  • Request data portability and receive an electronic copy of personal information that you have provided to us.

  • Be informed about third parties with which your personal information has been shared.

  • Request the review of decisions taken exclusively based on automated processing if that could affect data subject rights.

We will use commercially reasonable efforts to honor your requests for deletion; however, certain information will actively persist on the Service even if you close your account, including any messages you send within our App. In addition, the rights described above may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information we are required by law to keep or have compelling legitimate interests in keeping (such as for fraud prevention purposes). Your Personal Information may remain in our archives and information you update or delete, or information within a closed account, may persist internally for our administrative purposes, to the extent permitted by law. In addition, we typically will not remove information you posted publicly through or on the Service. Bear in mind that neither you nor Ace East LLC can delete all copies of information that has been previously shared with others on the Service.

7. SECURITY

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your Personal Information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Service or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Service. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Service, by mail or by sending an email to you.

8. CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits users of the Service 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 contact@aceeast.net.

California Consumer Protection Act (“CCPA”)

If you are a resident of the state of California, you may have certain data protection rights that can be exercised either by emailing us at contact@aceeast.net
contact@aceeast.net

Your rights under the CCPA may include the following:

  • The right to access or delete the information we have on you. Whenever made possible, you can access or request deletion of your personal data.

  • The right to know what personal information is collected, used, shared or sold as to the categories and specific pieces of personal information, and the sources of that information, and types of information we collect, and the intended purposes of that information, and the parties with whom we share it.

  • The right to opt-out of sale of personal information.

  • The right to non-discrimination in terms of price or service when you exercise a privacy right under the CCPA. Exercising these rights may impact your right or ability to receive information about our products and the Services, and the benefits of the Services.

9. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION

Currently, the Service is intended to be accessed and provided within the United States. However, all information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws. If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. Additionally, if you are a European resident, we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Website), or otherwise to pursue our legitimate business interests listed above. Please note that your information will be transferred outside of Europe, including to the United States.

10. LINKS TO OTHER SITES

Our Service contains links to other websites. If you choose to click on a third party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We encourage you to read the privacy policies or statements of the other websites you visit.

11. PHISHING

Phishing websites imitate legitimate websites in order to obtain personal or financial information. Identity theft and the practice currently known as “phishing” are of great concern to Ace East LLC. For more information about phishing, visit the website of the Federal Trade Commission at https://www.consumer.ftc.gov/articles/0003-phishing. In addition, if you believe you have received an email or had a similar interaction with a third party pretending to be Ace East LLC, please report it at contact@aceeast.net.

12. CHANGES TO THIS POLICY

Ace East LLC may update this Privacy Policy at any time and any changes will be effective upon posting. In the event that there are substantial changes to the way we treat your Personal Information, we will display a notice through the Services prior to the change becoming effective. We may also notify you by email, in our discretion. However, we will use your Personal Information in a manner consistent with the Privacy Policy in effect at the time you submitted the information, unless you consent to the new or revised policy. Your continued use of the Service after we make changes is deemed to be acceptance of those changes, so please check this privacy policy periodically for updates.

13. CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

Ace East LLC.

 

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