INFLUENCER, INC. PRIVACY POLICY

This statement of the privacy policy (“Privacy Policy”) of Influencer, Inc., (“Influencer”) is intended to provide you the user (“You”) of the Influencer website located at www.moves.ai “Website”), applications (Moves, content, products, and services (collectively, with the Website the "Services,") the following information:
1. What personally identifiable information which may be used to identify or contact an individual (“Personal Data”) of yours or third party personally identifiable information is collected from You through the Services.  The term Personal Data also encompasses personally identifiable information and personal data as defined in the GDPR General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”).
2. The organization collecting the Personal Data. 
3. How the Personal Data is used. 
4. With whom the Personal Data may be shared. 
5. What choices are available to You regarding collection, use and distribution of the Personal Data. 
6. The kind of security procedures that are in place to protect the loss, misuse or alteration of Personal Data under Influencer’s control. 
7. How You can correct any inaccuracies in the Personal Data.

      A. Information Collection and Use
Influencer is the sole owner of the information collected on the Services. The Services include the Moves social media influencer and reward  system platform, mobile application, and its user manual and other documentation.
 
In order to access the core functionality of the Services, You must register for and maintain an active personal user Services account ("Account"). You must be at least 16 years of age to obtain an Account.
 
Influencer collects certain information from our users at several different points on our Services, such as your name, address, mobile phone number, profile photo, age, gender, log in credentials for social media sites,  the Brands (defined as the third parties for whom we provide marketing, advertising, and other promotional activities and with whom we may share and otherwise exchange Personal Data) You mention in your posts, as well as at least one valid payment method supported by Influencer.

We will not sell, share, or rent Personal Data to others in ways different from what is disclosed in this Privacy Policy.  
Influencer uses your Personal Data to (1) operate and improve our Services; (2) respond to inquiries and provide support; (3) communicate with You about verification, promotions, updates, and other news about us and our Services and our partners; (4) link or combine it with information we receive from third parties to help us understand your preferences and needs and to personalize content; (5) perform our obligations; (6) marketing and other legitimate business purposes. As Influencer further develops, we may buy other businesses or their assets or sell our business or assets. Customer information is generally one of the business assets involved in such transactions. Thus, in the event that Influencer sells all or substantially all of its assets are acquired, customer information, including any Personal Data and visitor information collected through the Services would be one of the transferred assets, unless You opt out of such transfer of your personal information by following this link www.moves.ai/DONOTSELLMYPERSONALINFORMATION.html.

We use information relating to your posts about products and Brands, as well as Your comments and posts relating to the posts and comments of others relating to products and Brands to detect sentiment and for data analytics purposes.

Influencer reserves the right but not the obligation to disclose Personal Data in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) Influencer’s rights or property, other visitors, or anyone else that could be harmed by such activities. Influencer also reserves the right to disclose Personal Data when we believe in good faith that the law requires it.

      B. Other Information Collected and Used
In order to communicate with Influencer through the Services (e.g., through use of the “Contact” or “Send Us a Message” links) concerning Influencer’s Services, a user must first provide contact information (such as name and email address). This information is used to contact the user about the products and services for which they have expressed interest.
   
Geolocation capabilities in the user’s mobile device must also be enabled to access and use some of the features of the Services. You must explicitly grant permission to Influencer to use the geolocation capabilities of the device through an interactive dialogue in the app. To prevent location data from being shared, You may deny permission to use the geolocation capabilities.  

We also collect information from the social media account including information relating to posts (for example. name, date of creation/update, mentions, reposts, likes, comments). We also collect information from public sources, including information You post or are otherwise publicly available on the web, including social media sites. 

Your post preferences are used by our Services and our social media assistant, Bobbi, to determine your interests and provide a more personalized user experience, which includes displaying relevant content as well as suggestions on how You may improve your social media communications effectiveness. Our Services have, and continue to develop metrics to quantify influence.

Such information which we collect will be used in accordance with the terms of this Privacy Policy.  

      C. Cookies
We use "cookies" to collect website usage data and to improve our website. A cookie is a small data file that our website places in your web browser. Cookie data may expire, and they may remain in your browser until such time as they are automatically deleted by the browser or through direct action using the browser settings. Our Website may use cookies to provide us with insights on how You interact with our Website, to monitor aggregate usage data and web traffic on the Website, and to improve the user experience on our Website.

You can adjust your browser options to disable and remove cookies or to prompt You before accepting a cookie from the websites you visit. Please note that if You delete or disable cookies from our Website, You may not experience all of its features.

      D. Sharing
Users of our Services are always notified when their information is being collected by any outside parties.  We do this so our users can make an informed choice as to whether they should proceed with Services that require an outside party, or not.

We will share aggregated demographic information with our partners and affiliated websites. This is not linked to any personal information that can identify any individual person. We may also share, exchange, purchase, or sell Personal Data with Brands.  These Brands may use this information for marketing purposes. Brands who partner with Influencer may offer “opportunities” for users to compete by posting with hashtags at a certain location and show content specified by the Brand.

In order to improve the features and usability of our Services, we may utilize analytics services from Google. We enable the functions of Google Analytics by sharing analytic data from Influencer sites. The information we derive from Google Analytics may be used to send You relevant content, suggest new features, products, and/or services that can enhance your experience with our Services. Any information maintained in aggregate is anonymized to ensure an individual cannot be identified.

We may partner with other parties to provide specific services to support our business such as web hosting and other technical services providers. We will share names, contact and other information that is necessary for the third party to provide these services. These parties are not allowed to use personally identifiable information except for the purpose of providing these services.

You agree that the information which is collected by your social media services providers, public sources, and other third parties with whom we share information are subject to the privacy policies of such service providers. The privacy practices of such third parties are broadly consistent with this Privacy Policy. You agree that Influencer shall not have any liability to You for the privacy practices of those service providers.

NOTICE TO CALIFORNIA RESIDENTS – If You are a California resident, California law permits You to request and obtain from us once a year, free of charge, whether we have disclosed your Personal Data to third parties for a business purpose in the last 12 months and if so, a list of the third parties to whom we have disclosed your Personal Data (if any) for a business purpose in the prior calendar year, as well as a list of the categories of Personal Data disclosed to those third parties. You may send your request to privacy@moves.ai. We do not share Personal Data with third parties for their own direct marketing purposes without your prior consent. Accordingly, You can prevent disclosure of your personal data to third parties for their direct marketing purposes by withholding consent. We do not sell Personal Data of users whom we have actual knowledge are under the age of 16.  You also have the right to have your Personal Data deleted.  Be advised that our Services do not respond to the Do Not Track feature on your web browser. You may exercise this right by calling 800###-#### or by submitting your request to privacy@moves.ai.  If your Personal Data is deleted, we may not be able to provide You with Services.

      E. Your Personal Data Choices
We recognize your preferences to choose which forms of communications You receive from us, how You manage your information and how You set your sharing preferences. You may opt-out of receiving our promotional emails by following the “unsubscribe” instructions in those emails.  Please note that if You opt-out of receiving such promotional emails, we may continue to send You non-promotional emails, including emails about your account.

      F. Surveys & Contests
From time-to-time our site may request information from users via surveys or contests.  Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information.  Information requested may include contact information (such as name and shipping address), and demographic information (such as zip code, age level).  Contact information will be used to notify the winners and award prizes.  Survey information will be used for purposes of monitoring or improving the use and satisfaction of the Services.

      G. Data Retention and Security
We retain Personal Data for so long as is reasonably required to fulfill the purposes for which such data was collected and to perform our obligations associated with that data.

We exercise reasonable precautions to protect your Personal Data and when required or appropriate, we obtain written assurances from our third party technology providers that they also implement reasonable safeguards to protect your Personal Data.

We take reasonable precautions to protect our users’ information.  When users submit sensitive information via our Website, your information is protected both online and off-line.

When our registration/order form asks users to enter sensitive information, that information is encrypted and is protected with the industry standard Secure Socket Layer (SSL) encryption software.  While on a secure page, such as our order form, the lock icon in the address window of  most Web browsers appears locked, as opposed to un-locked, or open, when You are visiting an unsecured web page.  To learn more about SSL, follow this link https://en.wikipedia.org/wiki/Transport_Layer_Security.
   
If You have any questions about the security of our Services, You can send an email to privacy@moves.ai.

      H. Supplementation of InformationIn order for the Services to properly function, it may be necessary for us to supplement the information we receive with information from 3rd party sources. We may also group this information into aggregate user data in order to describe the use of the Services to our affiliates, existing or potential business partners or other third parties, or in response to a government request. However, please be assured that this aggregate data will in no way personally identify You or any other users of the Services.

      I. Special Offers
We send all new users a welcoming email to verify password and username. Established users will occasionally receive information on products, services, special deals, and a newsletter. Out of respect for the privacy of our users, we present the option to not receive these types of communications. Please see our choice and opt-out section below.

      J. Site and Service Updates
We also send the user site and service announcement updates. Users are not able to un-subscribe from service announcements, which contain important information about the service. We communicate with the user to provide requested services and in regards to issues relating to their account via email or phone.

      K. Correction/Updating Personal Information
If a user’s personally identifiable information changes, or if a user no longer desires our Services, we will endeavor to provide a way to correct, update or remove that user’s personal data provided to us.  This can usually be done at the user account page or by emailing our Customer Support at privacy@moves.ai or by sending a written request to Influencer, Inc. Attention: Privacy Officer, 323 Sunny Isles Blvd. Ste. 700, Sunny Isles Beach, FL 33160.     

      L. Choice/Opt-out
Our users are given the opportunity to ‘opt-out’ of having their information used for purposes not directly related to our site at the point where we ask for the information.  For example, our account sign-up form has an ‘opt-out’ mechanism so users who subscribe to Services from us, but don’t want any marketing material, can keep their email address off of our lists.  

Users who no longer wish to receive our newsletter or promotional materials from our partners may opt-out of receiving these communications by replying to unsubscribe in the subject line in the email or email us at contact@moves.ai or by sending a written request to Influencer, Inc., Influencer, Inc. Attention: Privacy Officer, 323 Sunny Isles Blvd. Ste. 700, Sunny Isles Beach, FL 33160.

      M. Notification of Changes
If we decide to change our privacy policy, we will post those changes on our Website so our users are always aware of what information we collect, how we use it, and under which circumstances, if any, we disclose it.  If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an update to this Privacy Policy. This Privacy Policy may be revised from time to time by Influencer.  The revised Privacy Policy will be posted by Influencer on the Website as it becomes available. Please review the Privacy Policy periodically as it is applicable to all users of the Services.  You hereby agree to review at first opportunity any modification or revision to the Privacy Policy and You further agree to be bound by any modification or revision of the Privacy Policy made by Influencer. We will use information in accordance with the privacy policy under which the information was collected. 

      N. If You are an European Union/European Economic Area User
This section applies if You are a user of the  Services in the EU (reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, to the extent applicable, Switzerland).  Influencer exercises commercially reasonable efforts inclusive of recommended technical and organizational measures to comply with the GDPR.

             Data Controller.
Influencer is the data controller for Personal Data that we collect from or about You, but we act as a data processor for Personal Data provided or otherwise made available to us by certain third parties, including Brands, through the Services, which we process on those third parties’ behalf pursuant to our contracts with the applicable third party. 

            Your Rights.
Subject to applicable EU law, You have the following rights in relation to your Personal Data:
Right to Be Informed. You have the right to be informed of how we use your Personal Data, where that data will be processed, how long we plan to hold on to the data and the details of your rights under the GDPR.

Right of Access. If You request, we will confirm whether we are controlling or processing your Personal Data and, if so, provide You with a copy of that Personal Data.
 
Right to Rectification. If your Personal Data is inaccurate or incomplete, You are entitled to request that we correct or complete it. If we have shared your Personal Data with others, we will tell them about the correction where possible. If You ask us, and where possible and lawful to do so, we will also tell You with whom we shared your Personal Data so You may contact them directly.

Right to Erasure (“Right to be Forgotten”). You may ask us to delete or remove your Personal Data. If we’ve shared your data with others, we will tell them about the erasure where possible, unless it requires a disproportionate effort. If You ask us, and where possible and lawful to do so, we will also tell You with whom we shared your Personal Data so You may contact them directly.

Right to Restrict Processing. You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where You contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell You before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible, unless it requires a disproportionate effort. If You ask us, and where possible and lawful to do so, and unless it requires a disproportionate effort, we will also tell You with whom we shared your Personal Data so You may contact them directly.

Right to Data Portability. You have the right to obtain your Personal Data from us. We will give You your Personal Data in a structured, commonly used and machine-readable format.
 
Right to Object. You may ask us at any time to stop processing your Personal Data and profiling You for direct marketing purposes.  If we are processing your Personal Data for other purposes, we will stop upon your request unless we have compelling legitimate grounds for the processing which override Your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

Right to Not Be Subject to Automated Decision Making and Profiling.  You have the right to refuse the automated processing of your Personal Data to make decisions about You if such decisions significantly affect You or if they produce legal effects.  

To exercise these rights, You may contact us at privacy@moves.ai or by mail at Influencer, Inc., Attention: Privacy Officer, 3370 Hidden Bay Drive, Suite 2211, Miami, Florida 33180 with their request.
      O. International Users. If You are accessing or  using the Services from outside of the United States, You expressly acknowledge and agree that your Personal Data and other information will be processed in the United States and in other third countries. Privacy and data security laws may be  less stringent than or otherwise different from the laws in effect in your country of residence.  You expressly agree to the processing of your Personal Data and other information in accordance with this Privacy Policy. If You are using the Services from the EU, your Personal Data will be processed and transferred to the United States in accordance with the Privacy Shield Principles as explained below.

      P. Privacy Shield.Influencer complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and/or Switzerland to the United States.  Influencer has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Influencer is a Miami-based company with servers housed in the United States. Personal Data collected from users outside the United States is transferred to the United States. If You are using the  Services from outside the United States your information may be transferred to, processed, and stored in the United States. 

As required under the Principles, when Influencer receives information under the Privacy Shield and then transfers it to a third-party service provider acting as an agent on Influencer’s behalf, Influencer has certain liability under the Privacy Shield if both (i) the agent processes the information in a manner inconsistent with the Privacy Shield and (ii) Influencer is responsible for the event giving rise to the damage.

If You have any questions or complaints about Influencer’s privacy practices, including questions related to the Privacy Shield, You may contact us at ​privacy@moves.ai​  or by mail at Influencer, Inc.,Attention: Privacy Officer, 323 Sunny Isles Blvd. Ste. 700, Sunny Isles Beach, FL 33160.

If You are a resident of the EU or Switzerland and are dissatisfied with the manner in which we have addressed your concerns about our privacy practices  or You have not received a response from us, You may seek further assistance, at no cost to You, from our designated Privacy Shield independent recourse mechanism, which You can learn more about by visiting https://www.icdr.org/privacyshield.
Residents of the EU or Switzerland may also elect to arbitrate unresolved complaints but prior to initiating such arbitration, You must: (1) contact Influencer and afford us the opportunity to resolve the issue; (2) seek assistance from Influencer’s designated independent recourse mechanism above; and (3) contact the U.S. Department of Commerce (either directly or through a European or Swiss Data Protection Authority) and afford the Department of Commerce time to attempt to resolve the issue. Each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the individual. Influencer is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

In addition to the rights granted in this Privacy Policy, some international users (including those whose information we collect under the Privacy Shield) have certain legal rights to access certain information we hold about them and to request the deletion of such information. To exercise those rights, those users may contact us at privacy@moves.ai or by mail at Influencer, Inc., Attention: Privacy Officer, 323 Sunny Isles Blvd. Ste. 700, Sunny Isles Beach, FL 33160 with their request.

Rev. 190905