Privacy Policy

This privacy policy (“Privacy Policy” or “Policy”) governs the data processing practices of Xaria (“Company”, “we”, “us”, or “our”) “) when you use any of our Products:

Access and use our website available at: https://www.sidehustlerbaby.com/ (“Visitor(s)” and “Website,” respectively); and
Access, install, use or interact with our side hustle mobile application (“User(s)” and “App” respectively) available on Google Play and App Store.
Download and active our chrome browser extensions available on Chrome Web Store (“User(s)” and “Extension”)

The services enabled through the App and Extensions includes, without limitation, the offer to participate as panelists in research market panels (“Panels”), respond to a demographic survey (“Demographic Survey”), and respond to surveys, market research surveys (“Market Research Survey(s)”) browse the web and conduct searches and the receiving of points for such participation (“Points”), that may be redeemed to gift cards provided by our third-party partners (“Partners”).

The Panels, Demographic Surveys and the Market Research Surveys as well as the other services available within the App, Extension and Website shall be collectively referred to herein as the “Services”. Each of the Visitors and Users are collectively referred to within this Privacy Policy as “you” or “your”.

This Privacy Policy constitutes an integral part of our End User License Agreement (“Terms”), and it governs the data collection, process and transfer in respect with our Services, all in accordance with the relevant data protection and privacy laws and regulations, including, if relevant to the user’s jurisdiction, the EU General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act (“CCPA”) and any other applicable privacy laws and regulations. Definitions used herein but not defined herein shall have the meaning ascribed to them in our Terms.

This Privacy Policy does not cover your interaction with third-party content available in through the Service, this Privacy Policy may be different from third parties’ privacy practices and we shall not be liable or responsible for the acts of those third parties.

POLICY AMENDMENTS:

We reserve the right to amend this Policy from time to time, at our sole discretion. The most recent version of the Policy will always be posted on the website. The updated date of the Policy will be reflected in the “Last Modified” heading. We will provide notice if these changes are material and, where required by applicable law, we will obtain your consent. Any amendments to the Policy will become effective within 30-days upon the display of the modified Policy. We recommend you to review this Policy periodically to ensure that you understand our most updated privacy practices.

Data Controller Information

__________ is incorporated under the laws of the State of _________, is the data controller of (as such term is defined under the GDPR or equivalent privacy legislation).

For any question, inquiry or concern related to this Privacy Policy or the processing of your Personal Data, you may contact our privacy team as follows:

Data Protection Officer: [Name]
[Email]
[Address]
[Tel]

Data Sets Processed Through the App, Extension, Services and Website

Non-Personal Data

During your interaction with our Services we may collect aggregated, non-personal non-identifiable information which may be made directly or indirectly through your use of the Services (“Non-Personal Data“). We are not aware of the identity of the user from which the Non-Personal Data is collected. The Non-Personal Data which is being collected may include your aggregated usage information and technical information transmitted by your device, such as: browser version, operating system type and version, mobile network information, internet service provider, mobile carrier, device settings, etc.

Personal Data

We may also collect from you, during your access or interaction with the Services, individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Data” or “Personal Information”).

For avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

For the avoidance of doubt, any Non-Personal Data that is connected or linked to any Personal Data will be considered and treated by us as Personal Data for as long as such connection exists. Additionally, please be advised that you are not required by law to provide us with any of your information and you may choose to refrain from providing us with certain types of Personal Data as you see fit.

We will only collect, use and disclose your Personal Data where we are satisfied that we have an appropriate legal basis to do so. We have also included the legal bases which we rely on, which will impact the rights you have in relation to your Personal Data (see below for more details).

Data Processed from Website Visitors:

DATA SETS

PURPOSE AND OPERATIONS

LAWFUL BASIS UNDER THE GDPR

Contact Information: If you voluntarily contact us for support or other inquiries, you may be required to provide us with certain information such as your name, email address, etc.

We process such data to provide you with the support you requested or to respond to your inquiry. The correspondence with you may be processed and stored by us in order to improve our customer service and in the event, we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable).

We process such information based on our legitimate interest. Unless you are contacting us for support, in which providing support is part of our contractual obligations to you.

Newsletter:

In the event you choose to subscribe to our newsletter, you will be asked to provide us with your full name and email address.

We will process this information solely in order to provide you with the content that you requested to receive from us.

We use a third-party service provider to manage our marketing activities.

We will process this information on the basis of your consent. You may withdraw consent at any time by unsubscribing using the unsubscribe option within the body of the email that you receive from us or by contacting us via email and asking us to remove you from our subscription list.

Device and Browser Data:

We may process certain online and device identifiers from you when you access or use our Website (e.g., IP address, UUID).

We further collect web-usage information and analytic data, such as duration, click stream, directed URLs, etc.

we process such data to provide you our Services and to enable the operation of our Website and for security and fraud prevention purposes (i.e., to prevent or to be able to address any errors or technical issues in our Services). In addition the data is used to operate and improve the Website and correct any error on the Website. We may use such data for internal analytics and measurement to understand how our Services are used.

Except for Personal Data collected through strictly necessary cookies, which is subject to our legitimate interest in operating the Website, will make sure to obtain your consent for the collection and processing of this data through the cookie consent notice available on the Website. You may withdraw your consent at any time through the cookie preference tab or as detailed below

Data Processed from App and Extension Users:

DATA SETS

PURPOSE AND OPERATIONS

LAWFUL BASIS UNDER THE GDPR

Account Information:

When you sign up to the Services directly you will need to provide us with your full name and Email address. Additionally, if you sign up via your social media account (i.e., Google or Facebook), we may have access to certain information that you allow social media to share with us.

We will use this data in order to create you an account, provide you with account management, support and to provide the Services as well as to send you needed information related to our Services and which related to our business engagement (e.g., send you a welcome message, notify you regarding any updates to our Services, send applicable invoices, etc.) and additional occasional communications and updates related to the Services, as well as promotional and marketing emails (“Direct Marketing”).
We may also use the information to authenticate you.

We process such data for the purpose of performing our contract with you, to provide the Services and to designate your account.

Demographic Survey and Market Research Surveys:

Demographic Survey: In order to participate in one of our Panels and the Market Research Surveys you may need to fill out a Demographic Survey where you may need to provide us or our partners with the following information as shall be determined from time-to-time and reflected in the Survey (“Demographic Data”). We store and keep this data to offer you relevant Market Research Surveys so you can earn more Points.

Market Research Surveys: based on the Demographic Survey, and other information we have on you, we may offer you to participate in a Market Research Survey. A Market Research Survey is provided by third party partners, either through a direct survey in which you will be required to respond to various questions and provide the information manually (“Direct Survey”), or an automated survey in which we will collect certain information automatically through technical means (API, SDK) subject to the Permissions you enable (as detailed below) (“Automatic Survey”). For Direct Survey, the Personal Data we process is a Sidehustle generated unique identifier associated with the Direct Survey. We are not aware of or have access to the content or information provided through or in the Direct Survey.

The Personal Data processed through the Automatic Survey is further detailed in the next section under “Permissions”.

The Demographic Data is processed in order to provide you the Demographic Data

The results of the Direct Surveys are shared with our Partners pseudonymized, de-identified way, meaning they are able to access the User’s response, which is identified with our generated unique identifier, however, it does not identify the User’s name or permanent Device ID. Our Partners will process the information in accordance with the Partner’s privacy policy as shall be reflected in the App and the Market Research Survey terms.

We process the unique identifier generated and associated with your response for calculating payments or Points, as applicable and detecting fraud.

The Demographic Data is processed (a) in order to assess a User’s Panel eligibility, to ascertain whether a User will meet the target audience for a Market Research Survey; and (b) in an aggregated anonymized manner for our market research, enabling the User to earn Points.

The Demographic Data is considered Sensitive Data and shall be processed based on your explicit consent, which can be withdrawn at any time.

We process the unique identifier generated and associated with your response for our legitimate interest.

Any Personal Data processed by the Partner shall be subject to your consent in responding to the direct Survey.

Point Redemption:

As part of the Services and in order to redeem your Points, depending on how you choose to redeem your Points, you may need to provide us with additional information such as your email address, bank account or physical address to which the gift will be sent.

This information will be processed by us in order to provide you with the gifts you have earned while using the Services.

This information will be processed by us in order to perform our contract with you, subject to the Terms and Conditions

Usage Data:

Our App and Extension will collect and store certain usage data, such as, access logs (when, time and date, you opened the App and if you opened it), duration, frequency, the Permissions you enabled, how many Survey, Panel or Studies you attend, if there were any crashes or errors, your Wi-Fi connection, and any other information the identifies Users’ use of the App and Extension.

When you use the Services, install the App and Extension, we will process this information for various purposes such as providing the Service, fraud prevention, improving our Services fixing errors, personalizing the Service.

Processing of such data is subject to our legitimate interest.

Device ID; Technical Non-Personal Data:

We may process your Device ID when you access or use our App or Services. Additionally, as explained above, we may collect certain types of Non-Personal Data from you when you access or use our App or Services.

We will use such Personal Data in order to operate, provide, maintain and manage our Services. Furthermore, some of this data will be processed to perform research, conduct analytics and statistical activities, detect fraud, security or technical issues with respect to the Services and for our legitimate business purposes.

Processing of such data is subject to our legitimate interest.

Browsing and Search Data

Following the installation and activation of the Extension or App’s applicable permissions we will collect your browsing activity including any search queries performed. As part of such collection our Extension will change your browser search feed to Sidehustle search feed.

We will process such data in order to provide you our services and allow you to accumulate Points as detailed in our Terms of Use. We will further use the Browsing and Search Data as part of the Automatic Survey Data as detailed above.

We may use the Browsing and Search Data to create solutions as part of Sidehustle’s market intelligence services in an aggregated anonymized way based on our legitimate interest.

We process such data for the purpose of performing our contract with you, to provide the Services. We will ask for your consent to collect such data and to change your browser search feed either through the App’s Permissions or Extension’s native notice provided to you prior to launching the Extension.

How We Collect Data

Depending on the way you interact with us, we may collect data from you in the following ways:

Automatically: we may automatically collect some data from you when you use our Website, the App, Extension, and the Services.
Voluntarily: we will collect certain data from you when you choose to provide us with it, as explained in this Privacy Policy.
Third Parties: we may receive information from third-parties, such as survey providers.

Disclosing of Data

We will not disclose any of your Personal Data with a third party, except under the following circumstances:

Service Providers: We may disclose Personal Data with our authorized third-party service providers as necessary and reasonable for our business purposes, including investigations of potential violations of our Terms. These third-party service providers and agents have agreed to confidentiality restrictions and only have access to Personal Data that they need in order to perform their services and functions and they are not permitted to use it for any other purpose.
Security: We may disclose your Personal Data in order to detect, prevent or otherwise address fraud, security or other technical issues.
Legal: we may disclose your personal data with regulators, in order to comply with any applicable law, regulation, requests of law enforcement, legal process, subpoena or other similar investigative demand or governmental request.
Business Transfers and Affiliates: We may disclose your information when we are undergoing a change in control of any kind including by way of a merger, acquisition or purchase of all or substantially all of our assets. Additionally, we may disclose your Personal Data with our parent company, any of our parent company’s subsidiaries, joint ventures or other companies under common control with us (“Affiliates”) when necessary for the purposes described in this Privacy Policy (including as necessary and reasonable for our business purposes, market analytics and market research activities and services that we and our Affiliates may provide or do) or upon the occurrence of the corporate transactions listed above.
Explicit Consent: We will disclose your Personal Data if you provide us with your explicit consent to disclose this information, prior to its disclosed.
Business Partners: We disclose your pseudonymized, de-identified Personal Data in order to provide our Services (including our Market Research Services) to our buyers of our market place (collectively, “Partners”). Our Partners utilize our Services to gain information they purchased or licensed, develop insights, conduct research, as determined in their sole discretion. In limited cases, we may disclose Personal Data with our Partners for their own analytics and marketing purposes.

Cookies and Tracking or Analytic Technologies

We or our third-party service providers may use cookies, other similar tracking technologies or methods of web and mobile analysis to gather, store, and track certain information related to your access of, activity and interaction with our Website, Extension, the App or your device. A “cookie” is a small piece of information that a website assigns to your device when you access the Website. Cookies are very helpful and may be used for a variety of different purposes. These purposes include, without limitation, allowing you to navigate between pages more efficiently, enabling the automatic activation of certain features, remembering your preferences and making the interaction between you and our Website quicker and easier, to prevent fraud and protect our Services. Please visit: www.allaboutcookies.org to learn more about cookies.

We use the following cookies, third-party tracking or analytic technologies on our Website:

Name

Type and Purpose

Google Analytics

Analytical, Measurement and Performance Cookie

http://www.google.com/policies/privacy/partners

https://policies.google.com/technologies/managing?hl=en

https://tools.google.com/dlpage/gaoptout/

Please click here for more information regarding our use of Google products.

Google Doubleclick.net

Targeting and Advertising

Facebook

Targeting and Advertising

https://www.facebook.com/about/privacy/previous

https://www.facebook.com/policies/cookies/

Clerk

Functional, and Operational

https://clerk.com/legal/privacy

It is important to note that most browsers allow you to erase cookies from your computer’s hard drive, block the acceptance of certain cookies, or receive a warning before a cookie is stored on your device. Please note however, that by choosing to block or erase certain cookies you may be limiting or diminishing your online experience with us. We encourage you to visit the following links to learn more about how you can block or erase cookies via your browser of choice: Google Chrome; Firefox; Internet Explorer; Safari; Edge; Opera.

Children

Our Website, Extension, App and Services are not directed to and are not meant to be used by individuals who are under the age of 16. If you are under 16 years of age, we request that you not use our Website, Extension, Services or our App. We do not knowingly collect Personal Data from individuals who are considered children in their jurisdictions (i.e., under the age of 16 or as otherwise defined under the applicable law in their jurisdictions). If we become aware of the fact that Personal Data of children has been collected through our Website, Services, Extension or App, we will take the appropriate steps to delete this information. Please contact us at Support@sidehustlerbaby.com if you become aware of or have any reason to believe that a child has shared Personal Data with us.

Links to Third Party Websites and Services

Our Services, Extension, App and our Website may contain links to third party services or websites that are not operated by us. These links are provided as a service and do not imply any endorsement of the activities or content of these websites, nor any association with their operators. Similarweb is not responsible for the privacy policies or privacy practices of any third party including, without limitation, websites directly linked to our Services, Extension, App or our Website (including any of the brands included in our cash back program). We encourage you to review the privacy policies of any such third-party websites or services before you access them.

Security

We takes reasonable and has put in place industry standard technical and organizational precautions to protect the confidentiality, security and integrity of your Personal Data and in order to prevent any unauthorized use of such Personal Data. In addition, we limit access to your Personal Data on our servers. The data collected by us is stored mainly on the servers of _______________ located in the _____________. Please contact us at: Support@sidehustlerbaby.com If you believe that your privacy was treated in a way that was not in accordance with this Privacy Policy. We will make a reasonable effort to notify you or any applicable supervisory authority in the event that a security incident occurs in which your Personal Data may be at risk, provided that we are required to do so in accordance with applicable law.

Retention
We will store and retain your Personal Data for no longer than is necessary for the purposes set forth above, as otherwise required in accordance with applicable law or until you have requested to opt-out of our collection of such Personal Data, subject to applicable law. We may at our sole discretion delete or amend information that is stored by us, without providing you with any prior notice of our intention to do so once it is no longer necessary for us to retain it for our purposes.

Data Transfers

We may store or process your Personal Data in the UK, the EU, the United States or in other countries. As such, please be advised that any information you provide us may be transferred to and processed in countries other than the country from which you accessed our Website, Extension or App. We will make sure to implement appropriate measures to ensure that your Personal Data receives an adequate level of data protection while it is being transferred. When Personal Data that was collected within the European Economic Area (“EEA”) or the UK is transferred outside the EEA or the UK (as applicable), we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data. You may exercise your rights, where applicable, to receive information regarding the transfer mechanism that was used during the transferring of your Personal Data. Personal Data that is being transferred outside the EEA to a country which has not received an adequacy decision from the European Commission (“Adequacy Decision”)will be transferred pursuant to the standard contractual clauses approved by the European Union (“Standard Contractual Clauses”). Personal Data that we transfer outside of the UK to a country that is not in the EEA, has not received an Adequacy Decision or an adequacy regulation has not been passed regarding it by the UK will be transferred, depending on the situation, either pursuant to the International Data Transfer Agreement or the addendum to be used with the Standard Contractual Clauses, both as issued by the UK’s Information Commissioner.

User Rights for EEA and UK Residents

Depending on your jurisdiction, data protection and privacy laws may provide you with the ability to exercise certain rights with respect to your Personal Data. We have included the rights that apply to EEA and UK residents below for your reference and convenience. If you are a California resident, please see our CCPA Exhibit below for a description of your privacy rights.

Right to Access: You may have the right to access your Personal Data by asking us to confirm what Personal Data we process about you, as well as additional information regarding how and the purposes for such processing, and to request and obtain a copy of such Personal Data.
Right to be Informed: You have the right to be informed regarding our information (e.g., our name and address) as well as what Personal Data we process, and how and why we process Personal Data.
Right to Rectification: You may have the right to require us to update and complete any Personal Data that we have about you that is inaccurate or incomplete and to require us to inform third parties that process such Personal Data on our behalf to update such inaccurate or incomplete data.
Right to Erasure: You may have the right, depending on the circumstances, to request that we delete your Personal Data that is held by us. The deletion right is not absolute and in certain cases we may refuse and reject such request.
Right to Restrict the Processing: Depending on the circumstances, you may have the right to limit the purposes for which we process your Personal Data. We can continue to use your Personal Data following your request to restrict the processing of your Personal Data, where we have your consent; or to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.
Right to Data Portability: You may have the right to request that we send or “port” the Personal Data that we process about you to a third-party, but in each case only where the processing is based on your consent or on the performance of a contract with you, and the processing is carried out by automated means. It is important to note that the GDPR and the CCPA differ in the application of this right and therefore we will handle the fulfillment according to the applicable laws in your jurisdiction
Right to Object: You may have the right to object to the processing of your Personal Data on the basis of our legitimate interest. The right to object does not exist, in particular, if the processing of your Personal Data is necessary in order to enter into a contract with you or to perform a contract with you.
Right to Withdraw Consent: If you have given us your consent for the processing of your Personal Data, you may have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before your consent was withdrawn.
Data Transfer Rights: You may be able to obtain a copy of, or reference to, the safeguards under which your Personal Data is being transferred outside the UK/EEA. We have included links and explanations regarding these mechanisms in above.
Rights in relation to automated decision making and profiling: You may have the right to not be subject to a decision based solely on automatic decision making or profiling.

Where you believe that we have not complied with our obligation under this Privacy Policy, the GDPR, the UK data protection laws, or the CCPA you have the right to make a complaint to an EU Data Protection Authority or the UK Information Commissioner's Office (as applicable).

If you would like to exercise any of your rights listed above, please contact us at: Support@sidehustlerbaby.com to submit a request to exercise such rights.

We reserve the right to ask that you send us reasonable evidence in order to verify your identity before we provide you with any of the information that you requested, subject to applicable law. We aim to respond to a verifiable request without undue delay and in any event in accordance with applicable law. We will notify you if we require more time to respond to your request and inform you of the reason and length of the extension period in writing. Our response to your request may also explain the reasons why we cannot fulfill your request, if applicable. When you request to exercise your data portability right, we will provide your Personal Data in a format that is able to be used and that would allow you to easily transmit the information from one entity to another.

If you have any questions about this Privacy Policy or our privacy practices, please contact us as follows: Support@sidehustlerbaby.com

CCPA PRIVACY EXHIBIT

Introduction

This CCPA Privacy Exhibit (“Exhibit”) governs the way in which we process the data of consumers who reside in the State of California (“Consumers” as defined under the CCPA, and will be referred to herein as “you”). Any terms defined in the CCPA have the same meaning when used in this Exhibit. Furthermore, this Exhibit is an integral part of our Privacy Policy and therefore, any definitions used herein but not defined herein shall have the meaning ascribed to them in our Privacy Policy.

To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.

Categories of Personal Information

When you access our Website and use our App, Extension or Services, we collect certain information with respect to such use and access. This data may include “Personal Information” which is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer, household or device as specified in the table below.

The following table specifies the categories of Personal Information that we may collect (or may have collected within the last 12 months):