Privacy

This is the privacy statement (the “Privacy Statement”) that governs how Php Analytic GRAMMARCHECK LLC (“Php Analytic”) collects, uses, discloses, and otherwise processes Personal Data (defined below) in connection with phpanalytic.com (the “Site”) and any other website that links to this Privacy Statement. This Privacy Statement does not, however, apply to Php Analytic in its role as a processor for its customers that use Php Analytic services. Please review the Php Analytic Data Processing Addendum to its Terms of Service, for more information on Php Analytic’s role as a processor.

As used herein, the terms “you” or “your” shall apply to individual users of the Site. If you have any questions or comments regarding this Privacy Statement, please contact us at support@phpanalytic.com

1. What is Personal Data? As used in this Privacy Statement, “Personal Data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. When Php Analytic combines other information (i.e., information that does not, on its own, identify you) with your Personal Data, Php Analytic treats the combined information as Personal Data.

2. When Personal Data is Collected. Php Analytic’s Site may collect the following types of information:

A. Contact, Account, and Billing Information. Php Analytic processes Personal Data that you provide through creation and management of your account, such as your name, e-mail address, and phone number. Php Analytic also processes, via a third- party service provider, payment information for billing purposes. Php Analytic processes this Personal Data only as necessary to provide the Site to you under the Terms of Service. For example, Php Analytic uses this information to bill you for your use of our services; respond to your inquiries; facilitate Php Analytic’s account recovery services in the event you or one of your users forgets their log-in credentials; and for other purposes related to the reasons for which you provide your Personal Data. Php Analytic may use your email address to contact you from time to time in furtherance of Php Analytic’s legitimate interests to provide you with information regarding the Site, such as invoices, payment receipts, and information regarding critical updates to your subscription. Unless you opt out using the process described in Section 6, below, Php Analytic may also send you a newsletter with tips and tricks for maximizing your use of the Site, as well as information on new or additional features.

B. Blog Comments. If you choose to post comments on the Php Analytic blog, Php Analytic requires you to provide your name and your email address (Php Analytic does not publish your email address). By posting a comment, you consent to Php Analytic’s publication and storage of your blog comment. You may withdraw your consent by submitting a request to remove the post to support@phpanalytic.com . Please be aware that whenever you voluntarily disclose Personal Data online, the information you post becomes public and can be collected and used by others and indexed in search engines (even if Php Analytic subsequently removes the post).

C. User ID and Password Information. Php Analytic processes Customers’ user ID and password information to enable them to log into and use the Site. Php Analytic processes this Personal Data only as necessary to provide the Site to you under the Terms of Service. In the event you are able to log into the Site through a social networking site (e.g., Facebook or Twitter), Php Analytic may receive Personal Data in accordance with the privacy notice of that site, which Php Analytic may add to Personal Data you have previously provided.

D. IP Address and Header Information. Php Analytic automatically collects certain information when you visit our Site, such as IP address and Header Information. “Header Information” is information such as browser type, geolocation, operating system, language, screen resolution, referring URL, etc. provided to our web server by your browser. Php Analytic has a legitimate interest in using such information to assist in log-in, systems administration purposes, information security and abuse prevention, and to track user trends.

E. Traffic Data. Php Analytic generates certain anonymous information about visitors’ use of the Site such as pages visited, the visitor’s mouse movements and clicks, keystroke data, HTML data on a page visited by a visitor if such HTML data includes Personal Data (collectively, “Traffic Data”). Php Analytic uses Traffic Data to further our legitimate business interests in analyzing the effectiveness of the Site and to improve the look, function and content of the Site. Php Analytic only collects keystroke data when you provide your consent to such collection. You can also opt-out of our processing of your Traffic Data by clicking the “Do not track me“ button near the top of this page.

F. Contact Information. As a visitor to the Site, Php Analytic may collect your name, email, and free form text entry if you choose to contact us through our “Contact Us” page. Php Analytic processes this Personal Data to address your comments or questions and Php Analytic may send you commercial or transactional emails as a result. You can opt-out of commercial emails any time by following the process set forth in Section 6.

3. How Php Analytic Uses Cookies and Similar Technology To help operate the Site, enhance your experience, and collect information about online activity, Php Analytic places small data files on your device known as “cookies,” or other similar technologies (e.g., pixel tags, web beacons, local shared objects). These technologies may allow Php Analytic and its Customers to store and manage your preferences and settings; measure and analyze how you use the Site and effectiveness of Php Analytic communications; offer targeted products, programs, and services; and help Php Analytic improve its products, services, and security.

The table below explains the types of cookies Php Analytic uses on its websites and why they are used. Also provided are examples of the cookies set by Php Analytic, with explanations of their purpose. Please note that this is not an exhaustive list, but rather aims to be a representative summary.

Cookie Description Essential and Strictly Necessary These cookies are essential for the website and services to perform their basic functions. These include those required to allow registered users to authenticate and perform account related functions. Functionality These cookies are used to store preferences set by users such as account name, language, and location. Security Php Analytic use these cookies to help identify and prevent potential security risks.

Analytics and Performance Performance cookies collect information on how visitors interact with Php Analytic websites, including what pages are visited most, as well as other analytical data. Php Analytic uses these details to improve how the websites function and to understand how visitors interact with them.

Advertising These cookies are used to display relevant advertising to users who use our services or visitors that visit websites Php Analytic provides, as well as to understand and report on the efficacy of ads served on Php Analytic websites. They track details such as the number of unique visitors, the number of times particular ads have been displayed, and the number of clicks the ads have received. They are also used to build visitor profiles, including showing you ads based on products you’ve viewed or acts you have taken on Php Analytic (and other) websites. These are set by Php Analytic and trusted third party networks and are generally persistent in nature.

Third Party / Embedded Content

These cookies may be set by third parties (such as social media sites), and used by them to track your online activity. Php Analytic has no direct control over the information that is collected by these cookies. You may wish to restrict the use of cookies or completely prevent them from being set. If you disable cookies though, please be aware that some of the features of the Php Analytic Site may not function correctly. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful, or you can use the help option in your browser for more details: • Cookie settings in Internet Explorer • Cookie settings in Firefox • Cookie settings in Chrome • Cookie settings in Safari web and iOS.

To find out more on how to manage and delete cookies, visit https://aboutcookies.org/. For more details on your choices regarding use of your web browsing activity for interest-based advertising you may visit the following sites: • networkadvertising.org • optout.aboutads.info • youradchoices.com • youronlinechoices.eu

On a mobile device, you may also be to adjust your settings to limit ad tracking. You may see a “banner” on our websites that asks for your consent to place cookies or to use other technologies that collect Personal Data. If you consent to the use of cookies or other technologies, Php Analytic and its advertising partners may set cookies on the site you are visiting and on other of our websites, dashboards, and services. Php Analytic will display the banner to you periodically just in case you change your mind.

Php Analytic uses Google Analytics, an analytics service, along with its own tools and technologies, to help analyze the traffic on the Site. For more information on Google Analytics’ processing of Personal Data, please see “How Google uses data when you use Php Analytic partners sites or apps.” You can opt out of Google Analytics by installing Google’s opt-out browser add-on.

4. The Purposes and Use of Personal Data If you submit or Php Analytic collects Personal Data through the Site, then such Personal Data may be used to: • Provide, analyze, administer, improve, and personalize the Site; • Contact you in connection with the Site, notifications, programs or offerings that you may have registered for; • Send you updates and promotional materials; • Provide personalized advertising to you; • Identify and authenticate your access to the parts of the Site that you are authorized to access; • For recruiting and human resources administration purposes; and • Protect Php Analytic rights and/or property and to ensure the technical functionality and security of the Site.

5. To Whom Personal Data Is Disclosed Php Analytic will not disclose Personal Data except as set forth in this Privacy Statement or with your consent and Php Analytic does not sell, lease, or exchange your Personal Data. This Section 5 describes to whom Php Analytic discloses Personal Data, and for what purposes:

A. Our Service Providers. Php Analytic employs service providers to perform tasks on its behalf and to assist in providing the Site. For example, Php Analytic may share your Personal Data with service providers who assist in the performance of core Site functions (such as hosting, data storage, and security) related to the operation of the Site and/or by making certain interactive tools available to you. Php Analytic also uses third parties for technical and customer support, application development, tracking and reporting functions, quality assurance, and other services. Php Analytic uses commercially reasonable efforts to only engage with third parties that post a publicly available privacy notice.

B. Advertising. Php Analytic engages advertising services to assist in advertising its Site. From time to time, those services target advertisements on third-party websites based on cookies or other information indicating previous interaction with the Site.

C. Companies Involved in Mergers and Acquisition Transactions or Change of Control. In some cases, Php Analytic may choose to buy or sell assets. In these types of transactions, user data (including Personal Data) is typically one of the business assets transferred. If Php Analytic were to sell all or substantially all of its assets or is otherwise acquired under a change of control event, Personal Data would be one of the assets that is reviewed and transferred or acquired by a third party. Php Analytic may transfer or assign this Privacy Statement and any Personal Data to a third party entity in the event of some other change of control (such as the result of a bankruptcy proceeding).

D. Law Enforcement, Government Agencies, and Courts. Php Analytic may disclose Personal Data at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal process to establish, protect, or exercise our legal or other rights or to defend against a legal claim or as otherwise required or allowed by law, or to protect the rights, property, or safety of any other person. Php Analytic may also disclose Personal Data to investigate or prevent a violation by you of any contractual or other relationship with Php Analytic (such as a violation of the Terms of Service) or your illegal or harmful activity.

6. How You Can Opt-Out You may choose not to receive future promotional or advertising emails from Php Analytic by selecting an unsubscribe link at the bottom of any email that you receive from php Analytic. Additionally, you may send a request specifying your communications preferences to support@phpanalytic.com Please note that even if you opt out of receiving the foregoing emails, Php Analytic may still send you a response to any “Contact” request as well as administrative, maintenance and operational emails (for example, in connection with a password reset request).

At the top of this page and in the link provided here, Php Analytic provides access to a data privacy management tool that allows you to opt out of being tracked by the Php Analytic’s technologies.

7. Personal Data from Children Php Analytic does not knowingly collect the Personal Data of children under the age of sixteen (16). If Php Analytic learns that it has collected Personal Data from children, and there is no lawful basis or parental consent to process such Personal Data, Php Analytic will use commercially reasonable efforts to delete all such Personal Data.

8. Retention of Personal Data Php Analytic will retain your Personal Data for the period necessary to fulfill the purposes for which your Personal Data has been collected as outlined in this Privacy Statement, unless a longer retention period is required by law. Where feasible, Php Analytic disposes of data, including Personal Data, on a regular schedule.

9. How We Protect the Confidentiality and Integrity of Your Personal Data Php Analytic has implemented security measures to protect Personal Data from loss, misuse, and alteration. Php Analytic uses industry- standard practices such as encrypted storage, firewalls, and password protection systems to safeguard the confidentiality of Personal Data. Php Analytic takes steps to help ensure its employees and contractors are aware of their information security obligations, and further restricts employee and contractor access to Personal Data. Despite efforts to store Personal Data in a secure operating environment that is not available to the public, Php Analytic does not and cannot guarantee the security of Personal Data during its transmission or storage on our systems. Further, while Php Analytic attempts to ensure the integrity and security of Personal Data, it does not and cannot guarantee that the security measures will prevent third parties such as hackers from illegally obtaining access to Personal Data. Php Analytic does not represent or warrant that Personal Data about you will be protected against, loss, misuse, or alteration by third parties.

10. Links to Third Party Websites The Site may contain links to third party websites. Please be aware that Php Analytic is not responsible for the privacy practices of third party websites you choose to visit. If you provide any information directly to parties other than Php Analytic, different rules may apply to the use or disclosure of that information. Php Analytic encourages you to investigate and ask questions before disclosing your Personal Data to third parties.

11. Your California Privacy Rights. This Section 11 applies to our collection and use of Personal Information if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (the “CPRA”). This Section 11 describes (1) the categories of Personal Information, collected and disclosed by us, subject to CPRA, (2) your privacy rights under CPRA, and (3) how to exercise your rights. When we use the term “Personal Information” in the context of the CPRA, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household. If you would like to receive a copy of this Section in an alternate format (e.g., printable) or language, please contact us using the information provided below.

A. Categories of Personal Information Collected, Used, and Shared We have collected the following categories of Personal Information from our consumers within the last 12 months. The sources from which we obtain this information and the ways in which we use this information are set forth in Section 2 above. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Category Examples Collected Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. Yes

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories. Yes Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). No

Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes

Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. No

Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Yes

Geolocation data. Physical location or movements. Yes

Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No

Professional or employment-related information. Current or past job history or performance evaluations. Yes

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. No

Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes

Sensitive personal information Social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; genetic data; biometric information for the purpose of uniquely identifying a consumer; personal information collected and analyzed concerning a consumer’s health; or personal information collected and analyzed concerning a consumer’s sex life or sexual orientation. Yes We share each of these categories of Personal Information with our service providers to the extent necessary for them to facilitate our business purposes. We also share this Personal Information for the purposes set forth in Section 4 above. We will retain your Personal Information for as long as we need it to provide you with our products and services. Because the length of your use of our services are not foreseeable, we cannot provide you with an exact timeframe for how long we retain your information. Our legal obligations may also require us to maintain your Personal Information for longer periods of time if your Personal Information becomes subject to such legal obligations.

B. Your California Privacy Rights

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

Privacy Right Description Notice The right to be notified of what categories of Personal Information will be collected at or before the point of collection and the purposes for which they will be used and shared.

Access The right to request the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such Personal Information is collected and shared. You may also have the right to request the categories of Personal Information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your Personal Information. Data Portability The right to receive the Personal Information you have previously provided to us.

Erasure The right to have your Personal Information deleted. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required or permitted to retain your Personal Information for one or more of the following categories of purposes: (1) to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); or (4) to otherwise use your Personal Information internally, in a lawful manner that is compatible with the context in which you provided it.

Correction You have the right to request that we correct any incorrect personal information that we collect or retain about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see below), we will correct (and direct any of our service providers that hold your data on our behalf to correct) your personal information from our records, unless an exception applies. We may deny your correction request if (a) we believe the personal information we maintain about you is accurate; (b) correcting the information would be impossible or involve disproportionate; or (c) if the request conflicts with our legal obligations. To Opt Out of Sales or Sharing of Personal Information We do not sell or share your Personal Information. However, if we did, you would have the right to opt out of the sale or sharing of your Personal Information.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child. You may only make a request for access or data portability twice within a 12-month period. The request must: • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

12. Colorado, Connecticut, Virginia, and Utah Residents This Section 12 applies to our collection and use of Personal Information if you are a resident of Colorado, Connecticut, Virginia, or Utah, as required by the Colorado Privacy Act, Connecticut Act Concerning Personal Data Privacy and Online Monitoring, Virginia Consumer Data Protraction Act, and Utah Consumer Privacy Act. For a description of the categories of Personal Information collected and disclosed by us and whether such Personal Information is sold or shared, please see Section 11(A).

As a resident of Colorado, Connecticut, Virginia, and Utah, you have the following rights with respect to your Personal Information: • Notice • Access • Data Portability • Erasure • Correction • Opt Out of Sales of Personal Information

For a description of these rights, see Section 11(B) above. In addition, you have the right to opt out of targeted advertising and profiling, to the extent that profiling makes decisions that produce legal or similarly significant effects concerning you. To exercise any of these rights available to you, see Section 13 below.

13. Exercising Your Individual Privacy Rights To exercise any of the privacy rights afforded to you under applicable data protection law, please submit a request to us by one of the following methods: • E-mailing us at support@phpanalytic.com California Residents: If you would like to opt out of sharing or the sales of your Personal Information, you may submit your opt-out request here. If you would like to limit the use of your sensitive Personal Information, you may submit your request support@phpanalytic.com

Colorado, Connecticut, Virginia, and Utah Residents: If you would like to opt out of targeted advertising, the sale of your Personal Information, or profiling, you may submit your opt-out request at support@phpanalytic.com Verification: We must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. We will only use Personal Information provided in a request to verify the requestor’s identity. If you are an authorized agent making a request on behalf of a California consumer, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney. We endeavor to respond to requests within the time period required by applicable law. If we require more time, 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. We do not charge a fee to process or respond to your 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.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We may deny certain requests, or only fulfill some in part, as permitted or required by law. For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes Appeals: If you are not satisfied with the resolution of your request and would like to submit an appeal, please click here: support@phpanalytic.com

GDPR and UK GDPR Policy (for European Data Subjects only). This Section 14 explains how Php Analytic collects and processes Personal Data about you if you are a data subject located in the European Economic Area (“EEA”) or the United Kingdom (“UK”) under the General Data Protection Regulation (“GDPR”) or the United Kingdom GDPR, as applicable. As used in this Section 14, a “data subject” is an identified or identifiable person, and “process” or “processing” means any operation or set of operations which is performed on Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

A. Php Analytic’s Basis for Processing. The following sets out the lawful basis under the GDPR to which Php Analytic may your Personal Data, which may include a cross-border transfer: Basis Description Your Consent Where you have given Php Analytic consent to process your Personal Data for one or more specified purposes, such as to provide our Site and other services as requested by you. To Perform a Contract Where the processing is necessary for the performance of contract to which you are a party and to which Php Analytic is acting as a processor or subprocessor. Comply with the Law Where the processing is necessary for compliance with a legal obligation to which Php Analytic is subject. Legitimate Interests Where the processing is necessary for the purposes of the legitimate interests pursued by Php Analytic or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of Personal Data.

B. Data Subject Privacy Rights. In certain circumstances, local data protection laws and certain local laws (including the GDPR) may give you rights with respect to Personal Data if you are located in the EEA. These rights differ by country/region, but may include access, amend, erase, export (i.e., data portability), or object to or restrict the processing of Personal Data collected via the Site. You may exercise these rights at any time by submitting at support@phpanalytic.com or sending an email to support@phpanalytic.com and Php Analytic will comply with all applicable laws. Php Analytic also provides Customers with access to—and the ability to edit or delete—certain categories of Personal Data through the Account Management page. Php Analytic has appointed EU Business Partners as its representative in the EU for the purposes of Article 27 of GDPR. You may contact the EU representative, as well as Php Analytic directly with any query that you may have in relation to your personal data. The contact details are as follows:

EU Business Partners 10 Ashe Street, Clonakilty, County Cork, P85 E4303, Ireland info@eubusinesspartners.com Flor McCarthy, Director Depending on where you live, you may have the right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that Php Analytic has violated any of the rights concerning Personal Data about you. Php Analytic encourages you to first reach out at support@phpanalytic.com to provide an opportunity to first address your concerns directly.

14. Changes to the Privacy Statement Php Analytic may revise and update this Privacy Statement at any time and will post the updated Privacy Statement to the Site. If these changes are material (i.e., changes believed to be of importance to you), Php Analytic will post notice of material changes on the Site. Where required by applicable law, Php Analytic will obtain your consent. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS PRIVACY STATEMENT SHALL BE EFFECTIVE IMMEDIATELY UPON POSTING TO THE SITE.

15. Contact If there are any questions regarding this Privacy Statement you may contact Php Analytic using the information below:

phpAnalytic GrammarCheck LLC 2769 Jefferson Davis Hwy #111-Z123, Stafford VA 22554 support@phpanalytic.com