Last updated: July 21, 2023

Our Privacy Pledge

Our commitment is to put users first. We strive to be transparent about how we collect and use your information, to keep your information secure, and to provide you meaningful choices. This Privacy Policy is meant to help you understand what information ICF and its affiliates ("ICF," "us," "our" or "we") collect, why we collect it, and what we do with it. This policy applies to ICF websites, apps, advertising services, products, services and technologies (we'll collectively refer to these as "Services").

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If you are a California Resident, Click Here

If you are a Nevada Resident, Click Here

If you are a Virginia Resident, Click Here

If you are a Colorado Resident, Click Here

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Information Collection and Use

We may collect and combine information when you interact with ICF including:

• Information You Provide to Us. We may collect the information that you provide to us, such as:
  • When you create an account with us. (Please note, when you use our Services, we may recognize you or your devices even if you are not signed into our Services.) ICF may use device IDs, cookies, and other attributes, including information obtained from third parties, to associate accounts and/or devices with you.
  • When you use our Services to communicate with others, either text or video/audio, or upload or store content (such as comments, photos, messaging services and attachments).
  • ICF analyzes and stores your actions, including which models you spend money on. This allows us to deliver, personalize and develop relevant features, content, advertising and Services.
  • When you sign up for paid Services, use Services that require your financial information or complete transactions with us or our business partners, we may collect your payment and billing information.
• Device Information. We collect information from your devices (computers, mobile phones, tablets, etc.), including information about how you interact with our Services and those of our third-party partners and information that allows us to recognize and associate your activity across devices and Services. This information includes device specific identifiers and information such as IP address, cookie information, mobile device and advertising identifiers, browser version, operating system type and version, mobile network information, device settings, and software data. We may recognize your devices to provide you with personalized experiences and advertising across the devices you use.


• Location Information. We collect location information from a variety of sources in order make your user experience better. You may visit the location settings tool on your device to make adjustments.

Cookies

Your browser offers so-called "cookies" which – if you allow their use – store small amounts of data on your computer about your visit to our websites. Cookies assist us in tracking which of our features you like best. And when you re-visit our websites, cookies can enable us to customize our content according to your preferences. However, cookies tell us nothing about you personally unless you specifically give us additional information.

Cookies used on our websites by category:

• Strictly necessary cookies - These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of our websites.


• Performance cookies - These cookies, including Google Analytics cookies, collect anonymous information on the pages visited. Google Analytics stores information about what pages you visit, how long you are on the site, how you got there, and what you clicked on. This data is collected via a JavaScript tag in the pages of our websites and is not tied to personally identifiable information. By using our websites, you agree that we can place these types of cookies on your device. These cookies collect information about how visitors use a website, for instance, which pages visitors go to most often. These cookies do not collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.


• Functionality cookies - These cookies remember choices you made to improve your experience. By using our websites, you agree that we can place these types of cookies on your device. These cookies allow the websites to remember choices you make and provide enhanced, more personal features. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.


• Advertising cookies - These cookies are used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.

You also have choices with respect to cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. However, note that if you reject some or all cookies, your experience at our websites and on other sites throughout the World Wide Web may not be complete. Some sites require cookies to function, such as those with e-commerce features. In addition, if you do not allow cookies, you will not be able to take advantage of personalized content delivery offered by us or other Internet sites.

Analytics

We have implemented Google Analytics features known as Google Analytics Demographics and Interest Reporting. You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings provided by Google. In addition, you can use the Google Analytics Opt-Out Browser Add-on to disable tracking by Google Analytics. We will use the data provided by Google Analytics Demographics and Interest Reporting to further develop and improve our products.

Information from Others

We collect information about you when we receive it from third parties, and affiliates such as:

• From advertisers about your experiences or interactions with their offerings.
• When we obtain information from third-parties or other companies, such as those that use our Services. This may include your activity on other sites and apps as well as information those third parties provide to you or us.

How We Use This Information

We are able to deliver, personalize, and improve our Services by combining and using the information we have about you (including information we receive on and off our Services) to understand how you use and interact with our Services and the people or things you’re connected to and interested in. We also may use the information we have about you for the following purposes:

• Provide, maintain, improve, and develop relevant features, content, and Services.
• Analyze your content and other information (including inmail, instant messages, photos, attachments, and other communications). You can review and control certain types of information tied to your account by using Privacy Controls.
• Fulfill your requests when authorized by you.
• Help advertisers and publishers connect to offer relevant advertising in their apps and websites.
• Contact you with information about your account or with marketing messages.
• Associate your activity across our Services and your different devices as well as associate any accounts you may use across ICF Services together. We may associate activity and accounts under a single user ID.
• Carry out or support promotions.
• Conduct research and support innovation.
• Create analytics and reports for external parties, including partners, publishers, advertisers, apps, third-parties and the public regarding the use of and trends within our Services and ads, including showing trends to partners regarding general preferences, the effectiveness of ads and information on user experiences. These analytics and reports may include aggregate or pseudonymized information.
• Provide location-based Services, advertising, search results, and other content.
• Combine information we have about you with information we obtain from business partners or other companies, such as your activities on other sites and apps.
• Detect and defend against fraudulent, abusive, or unlawful activity.

How We Share This Information

ICF shares information within its affiliated companies. We also share information we have about you for the purposes described in this Privacy Notice, including to provide Services that you have requested. We do not sell, license or share information that individually identifies our customers with companies, organizations or individuals outside of ICF unless one of the following circumstances applies:

• With Your Consent. We will share information with companies, organizations or individuals outside of ICF when we have your consent.


• Within ICF. Information may also be shared within ICF, including with other ICF Services and affiliated companies. ICF affiliated companies may use the information in a manner consistent with their privacy policies.


• With Partners. We may share your information with nonaffiliated companies who are:
  • Trusted Partners. We provide user information to trusted partners who work on behalf of or with us based on our directions and in compliance with appropriate confidentiality measures.
  
  
  • Advertising, Analytics and Business Partners (Limited to Non-Personally Identifiable Information). We may share aggregated or pseudonymous information (including demographic information) with partners, such as publishers, advertisers, measurement analytics, or other companies. For example, we may tell an advertiser how its ads performed or report how many people spent money after seeing a promotion. In some cases we do share information that personally identifies you (personally identifiable information is information like name or email address) with these partners, such as publishers, advertisers, measurement analytics, or other companies. When you use third-party apps, websites or other products integrated with our Services, they may collect information about your activities subject to their own terms and privacy policies. We allow other companies that show advertisements on our webpages or apps to collect information from your browsers or devices. Other companies' use of cookies and other data collection technologies are subject to their own privacy policies, not this one. Like many companies, we may allow cookie matching with select partners. But, these parties are not authorized to access ICF cookies.
  
  


• For Legal and Other Purposes. We may access, preserve and disclose information to investigate, prevent, or take action in connection with: (i) legal process and legal requests; (ii) enforcement of the Terms; (iii) claims that any content violates the rights of third-parties; (iv) requests for customer service; (v) technical issues; (vi) protecting the rights, property or personal safety of ICF, its users or the public; (vii) establishing or exercising our legal rights or defending against legal claims; or (viii) as otherwise required by law.
  • This may include responding to lawful governmental requests.


• New Ownership. If the ownership or control of all or part of ICF changes as a result of a merger, acquisition or sale of assets, we may transfer your information to the new owner.

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Information Security and Data Retention

ICF has technical, administrative and physical safeguards in place to help protect against unauthorized access, use or disclosure of customer information we collect or store. To learn more about security, including the steps we have taken and steps you can take, please contact support@icftechnology.com.

Protecting Children's Privacy

Our Services are for an adult audience above 18. We use age verification services, where required, and credit card to prove age. If there is any suspicion of underage users, we immediately block them.

Data Processing and Transfers

ICF may process information related to individuals in the EU/EEA and may transfer that information from the EU/EEA through the use of standard contractual clauses.

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Other Important Information

This Privacy Notice Applies Only to ICF

This Privacy Notice does not apply to the practices of companies that ICF does not own or control, or to people that ICF does not employ or manage. In addition, some affiliated products may have different privacy policies and practices that are not subject to this Privacy Policy.

Changes

We may update this Privacy Notice from time to time, so you should check it periodically.

Questions & Suggestions

If you have questions, suggestions, or wish to make a complaint, please contact Customer Service at:

• ICF Customer Care - Privacy Policy Issues P.O. Box 21508 Seattle, WA 98101

• support@icftechnology.com

Or the Data Protection Officer at:

• members.hellochat.live dpo@icftechnology.com

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California Resident Data Rights and Choices

Starting on January 1, 2020, The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that ICF disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

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

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

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

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Who can make a rights request, and how?

A rights request can be made by you or your legal representative.

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

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

• Phone:(866) 941-3982 Email: support@icftechnology.com Fax: (206) 441-2794 Mail: https://members.hellochat.live/docs/record-keeping-2257

Custodian of Records ICF Technology, Inc. 800 Stewart St Seattle, WA 98101

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Nevada Resident Data Rights and Choices

Effective October 1, 2019, Nevada residents may submit a request asking us to not to sell your information to support@icftechnology.com.

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Virginia Resident Data Rights and Choices

Effective January 1, 2023, if you live in the Commonwealth of Virginia, the CDPA provides you (a "consumer") with several rights, including:

• the right to opt-out of the processing of the personal data for purposes of targeted advertising, the same of personal data, or profiling;
• the right to confirm if data is being processed;
• the right to amend inaccuracies;
• the right to data deletion; and
• the right to data portabililty.

To exercise your rights, phone (866) 941-3982 or email support@icftechnology.com.

Colorado Resident Data Rights and Choices

Effective July 1, 2023, if you live in the State of Colorado, the Colorado Privacy Act ("CPA") provides you (a "consumer") with several rights, including:

• The right of access to consumer’s personal data;
• The right to correct inaccuracies in consumer's personal data;
• Right to data deletion;
• Right to data portability;
• Right to opt out of processing of personal data for the purposes of targeted advertising or sale of personal data; and
• Right to appeal a business’ denial to take action within a reasonable time period.

To exercise your rights, phone (866) 941-3982 or email support@icftechnology.com