Entera Privacy Notice

Entera Holdings Inc. and its affiliates and subsidiaries (“Entera”, “we”, “our”, or “us”) respects your privacy and are committed to protecting it through this Privacy Notice (“Privacy Notice”). This Privacy Notice describes the type of information we may collect from you or that you may provide to us when you visit our Site and Services (both as defined in our Terms of Use).

Capitalized terms not defined herein have the same meanings as in our Terms of Use. By using our Services, you acknowledge that your Personal Information will be handled as described in this Privacy Notice. Your use of our Services and any dispute over privacy, is subject to this Privacy Notice and our Terms of Use, including their applicable terms governing limitations on damages, and the resolution of disputes.

Please read this Privacy Notice carefully to understand our policies and practices. BY ACCESSING OR BROWSING THE SITE OR REGISTERING OR USING THE SERVICES, YOU CONSENT TO THE COLLECTION AND USE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY NOTICE.  If you do not agree with our policies and practices, your choice is not to use our Site or Services.

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This Privacy Notice applies to information we collect:

• From Users;
• From visitors to our Site;
• In email, text, and other electronic messages between you and us; and
• Through mobile and desktop features and applications using the Services.

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If you have any questions about this Privacy Notice or our use of your information, you can email us at support@entera.ai.

1. CHANGES TO THIS PRIVACY NOTICE

We reserve the right, at any time and without notice to you, to make changes to this Privacy Notice. We will post a new notice on our Site and change the date at the top of the Privacy Notice. If we make a material change to our Privacy Notice that affects how we collect or use your Personal Information, we will notify you via email, SMS text message, or a notification under the account settings page.  Your continued use of the Site or Services after we make changes is deemed to be acceptance of those changes.  Please check this Privacy Notice periodically for updates. 

2. PERSONAL INFORMATION COLLECTION AND USE

This Privacy Notice covers our collection, storage, and use of Personal Information. “Personal Information” means any information that can be used to identify you individually, such as your name, mailing and email addresses, phone number, location, and other information that permits us to contact you at a physical location, online, or by electronic communication, including telephone, email, or text messages (including by an automatic telephone dialing system).    Personal information does not include information that has been de-identified or aggregated such that you can no longer be identified.

The types of information we collect depends on your level of engagement with the Services. The more you interact with the Services, the more information we need to provide the Services. This Section explains how we collect and use personal information based on your level of engagement with the Services.

2.1. All Users of the Entera Sites 

We automatically receive and record information whenever you interact with the Sites, whether as a registered user or as a visitor. This includes IP address data from our server logs, cookie information, browser information, information about your activity while on the Sites (such as the pages you request, properties that you view or save, and property that you claim), and the URL of the site you came to the Sites from. We also may approximate your location based on your IP address, to customize your experience on our Sites.

We may also use the information listed above to help diagnose problems and performance with the Services, analyze trends, customize your experience, and administer the Services. We may provide IP addresses to third-parties to help us analyze website user survey data. We use computer and device information for marketing purposes, to examine traffic to the Site and Services, identify any misuse of the Site and Services, and improve the Site and Services to provide you a better experience. We may also use the information described in this section to better target information about Entera’s Sites and Services, for example, by displaying more accurate or relevant information on our Sites, matching you to a public record listing of a property, tailoring the advertising we display on third party websites and platforms, and sending better targeted and tailored messages, including via email and/or push notifications. 

You can turn-off and adjust settings on your computers and devices that will not allow us to collect information. For example, in many cellular devices, you can turn off location settings by selecting the “Settings” feature, choosing “Privacy” and turning-off “Location.”  

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All the stated categories in this Privacy Notice exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

2.2. Registered Users of the Entera Sites

We are required to collect certain information, including your name and email address, as a condition of our licenses with the multiple real estate listing services (the "MLSs") in order to allow you to access the full MLS listings. You give us this information when you create your Entera account. We may use the information that we collect from registered users in order to provide the Services, including providing customized recommendations through our proprietary algorithms. 

Your Entera account password is encrypted on our server. It is your responsibility not to disclose your password to other people and to ensure you maintain its security. You are responsible for updating your Personal Information associated with your account. You can correct, amend, add or delete Personal Information by editing the information in your account portal or by contacting our customer service teams at support@entera.ai. However, even after you update information, we may maintain a copy of the original information in our records as required by applicable law or other legal obligation.

2.3. Entera Clients

You are an Entera client when you start working with us to buy or sell a home. We will collect information associated with such transactions, including your name, address, phone number, email address, financial or payment information, buyer loan pre-approval documentation and seller property information. 

2.4. Communications with Entera

We may collect Personal Information when you submit comments, questions, or suggestions to us, use the Services, use the Contact Us form, provide to us in person, such as trade shows, or by email, including attached files in an email sent to us. We may also track and retain the details of all transactions and communications you have with other users such as emails, feedback, sale and purchase of products or services, and any other forms of communications. We may record any telephone calls between you and Entera Agents or other representatives for training and quality assurance purposes.

Entera may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, which may include Personal Information.

Any comments and any emails we receive from you are subject to the terms of this Privacy Notice and the Terms of Use. 

Entera may offer interactive features such as chat services, forums, and social media pages. We may collect the information you submit or make available through these features. Any content you provide on the public sections of these channels will be considered "public" and will not be subject to the privacy protections referenced herein.

2.5. Marketing and Sharing

We may send marketing materials to Entera account holders and clients using various communication channels, including without limitation, email, text messages/SMS, push notifications, telephone calls, and direct mail. Individuals may also subscribe to general market analysis emails or other notifications with information such as customized summaries of properties for sale. Entera may send you Entera-related news and surveys in accordance with applicable law.

Entera's Services may allow you to share certain content with a third party. Third party email addresses or phone numbers that you may provide will be used to send the content or link you request in accordance with applicable law. You represent and warrant that you have permission to share such information with Entera.

2.6. Information from Other Sources

We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with the Services.

2.7. Other Uses of Information

In addition to the specific collection and uses listed above, we may use any of the Personal Information we collect for the following business purposes:

• to operate our Sites and provide our Services in accordance with our Terms of Use and/or any other agreement you may have with us;
• to manage your Personal Information and accounts;
• to respond to your questions or inquiries;
• to conduct promotional activities, including surveys;
• to undertake internal research for technological development and demonstration;
• to improve, upgrade or enhance our Sites and Services;
• to send you informational or promotional communications;
• to detect bugs, security incidents (including to protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity);
• to identify and repair errors that impair existing intended functionality;
• to undertake activities to verify or maintain the quality or safety of a Service, Site or transaction;
• to carry out other purposes that are disclosed to you and/or to which you consent; and
• to pursue our legitimate interests where your rights and freedoms do not outweigh these interests.

3. DE-IDENTIFIED AND AGGREGATED INFORMATION

We may use information we collect to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, de-identified or aggregated trends, reports, or statistics, information about the computer or device from which you access our Services, or other analyses we create. De-identified and aggregated information is used for a variety of functions, including the measurement of visitors' interest in and use of various portions or features of the Sites and Services. De-identified and aggregated information is not Personal Information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purpose.

4. PERSONAL INFORMATION SHARING

While we do not exchange your Personal Information with others for monetary consideration, we may share your Personal Information with the following categories of third parties as part of our Services to you or to assist us in conducting our marketing and advertising, or for other business or commercial purposes listed above in this Privacy Notice. Entera may share your Personal Information for other purposes that are clearly disclosed to you at the time you provide Personal Information or with your consent.

4.1. Notice of Public Record Information

Please be aware that home sales and purchases may be a matter of public record, and your name and address, the price you paid, your property taxes, and other information may be available from public sites regardless of the brokerage(s), if any, who assist in the transaction. We post on our Sites some information that typically becomes part of the public record of a home sale or purchase.

4.2. Information to Provide Services

We use your Personal Information to deliver customized content to you. We do this through third party service providers and through business partners. We may share your information with Entera’s affiliates and subsidiaries for various purposes, including to: (i) provide the Services to you; (ii) help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; (iii) help with marketing initiatives; and (iv) manage and improve Entera products, Sites, Services and tools.

You can use the Services to research and investigate properties, in addition to making a request to tour a home, contacting a real estate agent, or receiving help selling or buying a home. When you make such a request through Entera, you authorize Entera to share your Personal Information including your contact information, home search history, favorites and saved searches, with a real estate professional (an Entera Agent or staff member, or a Partner Agent) for the purpose of responding to your request. 

We share your information with certain third-party service providers to perform the services and facilitate transactions initiated through the Site or Services.  This includes sharing information obtained from you, MLSs and other third-party sources that is not on the public record to facilitate your home purchase or sale transaction. This includes:

• Service Providers to all Entera Clients: Entera Agents work with third parties to process your home search and sale transaction and must share your information with those third parties. Examples include MLSs and providers of software used for document preparation and electronic signing.
• Partner Agents: A Partner Agent is employed by or works with another brokerage and is not a representative or employee of Entera. Partner Agents have contracted with us to provide Entera-quality service to a wider range of customers. We'll refer you to a Partner Agent at our discretion. If you are referred to a Partner Agent for your home purchase or sale transaction, we share your information with that Partner Agent so they can assist you. You will contract directly with the Partner Agent and Entera is not responsible for the work performed or the services provided by Partner Agents in any manner.
• Home Seller Service Providers: As is customary as your home sales agent, we share your listing information with MLSs and other listing websites, such as Realtor.com, Trulia.com and Zillow.com. As a result, your listing may appear on more than one website. We may also share your listing and contact information with listing vendors such as photographers, home staging experts and home repair professionals like plumbers and electricians, as needed.
• Home Buyer Service Providers: As is customary as your home purchase agent, we must share your buying information with inspectors, title companies, escrow agents, closing attorneys, lenders, and other third parties as needed to process your transaction.
• Potential Buyers: By law, we are required to disclose certain information about your property to potential buyers.

4.3. Negotiations

We may post the record of your negotiations within your account. We do not post your name on our Sites without your permission, but if the sale is closed, the price and the fact that you bought or sold your house at that price may be a matter of public record.

4.4. Targeted and Interest-Based Ad Providers

We may share the information that we collect about you with others (including advertising networks and service providers) to tailor and serve you ads on our Services, as well as other websites and social media networks. This practice is commonly referred to as "interest-based advertising" or "online behavioral advertising." These advertising networks track your online activities over time by collecting information through automated means, including through the use of Technologies (e.g., cookies, web-beacons and other methods). This allows Entera to target our advertising to you through demographic, behavioral and contextual means. As a result, you may see ads for Entera on other websites and social media.

4.5. APIs and SDKs

We may use third-party APIs and software development kits ("SDKs") as part of the functionality of our Services. APIs and SDKs may allow third parties, including advertising partners, to collect your Personal Information to provide our Service-related content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.

4.6. Information Disclosed in Connection with Business Transactions

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

4.7. Information Disclosed for Our Protection and the Protection of Others

We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims or legal processes (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable.

5. YOUR CHOICES AND MANAGING YOUR SETTINGS

You may have the right to opt in, object to or opt out of certain uses of your Personal Information. However, you may not be able to access or use certain Services if you do not provide the required Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time by contacting us as described below. Even if you opt out, we may still collect and use Personal Information regarding your activities on our Sites, Services and/or information from the advertisements on third party websites for other legal purposes as described above in accordance with applicable law.

5.1. Electronic Messages, Phone Calls and other Communications

If you receive email communications from our Services, you may use the unsubscribe link contained in the email. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, including notices about policy or Terms of Use updates, and you will not be able to opt out of those communications.

5.2. Opting-Out of Technologies and Tracking

• Entera Cookies: We put Entera cookies on your device's browser to help us keep track of when you were last on the Sites, and what you last searched on the Sites. While you are free to disable cookies on your browser, we recommend that you leave cookies activated to use some of the most useful Entera features.
• Third-Party Cookies for Analytics: We may use third parties, such as Google, to help us analyze how people are using the Services, and those third parties are authorized to use Technologies to access Personal Information regarding visitors to the Sites. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
• Opting Out of Entera's Interest-Based Advertising: If you do not want Entera to collect, use and share information about you to deliver interest-based advertising outside of the Services, you can opt-out of being targeted by certain third-party advertising companies online at http://www.networkadvertising.org/choices/. Please note that most opt-out mechanisms are cookie-based and will only affect the specific computer and browser that is used to submit an opt-out request. If you have multiple computers or change computers, or use multiple browsers, you will need to submit opt-out requests for each such computer or browser. In addition, if you delete, block or otherwise restrict cookies, you will need to renew the opt-out choices to ensure that any opt-out cookies remain effective.
• Opting Out of Interest-Based Advertising Generally: Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and your choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative’s (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and your choices regarding having information used by NAI members. The NAI’s main webpage is located at www.networkadvertising.org. Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through the Services. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt-out on the DAA or NAI websites, your opt-out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website.
• Browser Solutions for Disabling Cookies: If you wish to prevent cookies from tracking your activity on our website or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Sites who disable cookies will be able to browse the Sites, but some features may not function.
• Opting Out of Mobile Device ID Tracking: We may use the information that we collect about you (whether directly from our Sites, through your device(s), or from a third party) to help us and our third-party service providers identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). We and our third-party service providers also may use the cross-device use and other information we learn about you to serve targeted advertising on your devices and to send you emails. 
• Do Not Track: Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Flash Cookies: Entera does not currently use flash cookies, but we may in the future. To control flash cookies, click here. Please note that flash cookies do not reside in your browser, so your browser settings will not affect them.

5.3. Delete your Account

You may delete your Entera account by contacting our customer services teams at support@entera.ai. We retain Personal Information for as long as we have a valid business purpose to or to meet our legal obligations. Please be aware that we cannot always delete records of past interactions and transactions. For example, we are required to retain records relating to previous sales and purchases for financial reporting and compliance reasons.  Entera may be required to keep a copy of your Personal Information in accordance with Section 6 below.

6. PERSONAL INFORMATION RETENTION

Entera retains the information we receive as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

7. PERSONAL INFORMATION STORAGE AND SECURITY

Entera is headquartered in the United States. You agree that we may store and process the information we collect anywhere in the world, including but not limited to, the United States, the European Union, or other countries.

We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services.

8. OTHER IMPORTANT INFORMATION

8.1. Children.

Our Sites and Services are not directed to children under 13 (or other age as defined by local law), and we do not knowingly collect Personal Information from children. If you learn that your child has provided us with Personal Information without your consent, you may contact us at the email address below with the subject line "COPPA Child Information Request." If we learn that we have collected any Personal Information from a child in violation of applicable law, we will promptly take steps to delete such information.

8.2. Links to Third Party Sites/Applications

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Sites or other Services. These other websites and applications are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. Entera does not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

9. INDIVIDUAL RIGHTS IN PERSONAL INFORMATION

Depending on where you live, you may have additional rights as a data subject. you may have the right to: (i) request confirmation of whether we are processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the "right of data portability"); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed Personal Information; and (vi) request erasure of Personal Information held about you by Entera, subject to certain exceptions prescribed by law. In accordance with applicable law, if you would like to exercise any of these rights, please contact us at privacy@entera.ai. We will process such requests in accordance with applicable laws. 

Before responding to any of your requests as set forth in this Section 9, we must first verify your identity using the Personal Information you recently provided to us. You must provide us with your full name, email address you used to contact us, and your address (if applicable). We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request more information to verify your identity or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for denial.

Please know that we strive to comply with applicable law, including data protections laws. We periodically audit information to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed. We monitor and update data protection policies and procedures to meet the requirements and standards of applicable law. We do not currently sell, and in the past twelve months have not sold, any Personal Information.

9.1. Additional Information for California Residents

California Privacy Notice Provisions

This section of the Privacy Notice provides additional information for California residents (“consumer” or “you”) and applies to “Personal Information,” as defined by the California Consumer Privacy Act 2018, as amended by the California Privacy Rights Act 2020 (the “CCPA”), whether collected online or offline. This section describes our information practices and any rights you may have regarding your Personal Information pursuant to the CCPA.

Categories of Personal Information We Collect

For purposes of this section, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Please note that Personal Information does not include:

• Publicly available information, such as information lawfully made available from government records, information we have a reasonable basis to believe is lawfully made available to the general public by you or by widely distributed media, or by a person to whom you have disclosed the information and not restricted it to a specific audience; and
• Deidentified or aggregated information.

The following identifies the categories of personal information we collect about you as enumerated by the CCPA. Depending on how you use the Services, we collect the following categories of personal information through our Services:

• Identifiers. Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
• Commercial information. Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
• Internet or other electronic network activity. Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.
• Geolocation data. Precise geolocation information derived from a device.
• Audio, electronic, visual, or similar information. Includes audio, electronic, visual, or similar information, photographs, and images (e.g., that you provide us), call recordings (e.g., of customer support calls), and other visual or similar information you provide via our Services.
• Inferences. Such as inferences drawn from any of the information described in this section reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
• Sensitive personal information. In limited circumstances, we may collect your precise geolocation.

Categories of Sources from Which Personal Information is Collected

Depending on how you interact with our Services, we generally collect the categories of Personal Information listed above from the following categories of sources:

• directly from the Users;
• from our affiliates and business partners;
• from advertising networks;
• from operating systems and platforms;
• from data brokers;
• from third parties, and
• from publicly available sources, including government records.

Retention of Personal Information

Entera retains the Personal Information we collect as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. Rather than delete your Personal Information, we may also deidentify it or by removing identifying details. If we deidentify the data, we will not attempt to reidentify it.

Business or Commercial Purposes for Collecting and Disclosing Personal Information

We may use and disclose the Personal Information we collect for the following business purposes, as more fully described above:

• To operate our Sites and provide our Services in accordance with our Terms of Use and/or any other agreement you may have with us;
• To manage your Personal Information and accounts;
• To respond to your questions or inquiries;
• To conduct promotional activities, including surveys;
• To undertake internal research for technological development and demonstration;
• To improve, upgrade or enhance our Sites and Services;
• To send you informational or promotional communications;
• To detect bugs, security incidents (including to protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity);
• To undertake activities to verify or maintain the quality or safety of a Service, Site or transaction;
• To carry out other purposes that are disclosed to you and/or to which you consent;
• To conduct financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions, and to maintain appropriate business records and enforce company policies and procedures;
• To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings; and
• To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.

Disclosures of Personal Information for a Business Purpose

We may disclose your Personal Information to the third parties or others as described above in this Privacy Notice, for any of the business purposes described above in this Privacy Notice.

Sensitive Personal Information

Our collection, use, and disclosure of Sensitive Personal Information is generally limited to what is reasonable and proportionate for the following purposes:

• To perform the services or provide the goods as reasonably expected by you;
• To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of sensitive Personal Information that is stored or transmitted;
• To resist malicious, deceptive, fraudulent, or illegal actions directed at Entera and to prosecute those responsible for those actions;
• To ensure the physical safety of you and others;
• For short-term, transient uses;
• To verify your information, provide customer support, or provide similar services; and
• With respect to a service or device that is owned, manufactured, manufactured for, or controlled by Entera, to verify or maintain the quality or safety, improve, upgrade, or enhance the service or device.

Sales and Sharing of Personal Information

The CCPA defines “sale” broadly as “disclosing or making available Personal Information to a third party in exchange for monetary or other valuable consideration,” and “sharing” as “disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising.” While we do not disclose personal information to third parties in exchange for monetary consideration, we may be considered to be “selling” or “sharing” certain categories of Personal Information to third parties through our use of ad companies, analytics providers, and social networks (through third party tags on our Sites) to improve and measure our ad campaigns and reach users with more relevant ads and content.

The categories of Personal Information that we may have “sold” or “shared” include:

• identifiers;
• internet or other electronic network activity information;
• geolocation information; and
• inferences.

The categories of third parties under the CCPA to whom we have disclosed this information are:

• data analytics providers;
• advertising networks; and
• social networks.

We do not sell or share Personal Information about individuals we know are under age eighteen (18).

Your CCPA Rights and Choices

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. Subject to certain exceptions, consumers have the right to make the following requests:

Right to Know/Access. You have the right to request (up to twice per year subject to certain exemptions), free of charge, that we disclose information about our collection and use of your Personal Information, including:

• The categories of Personal Information we collected about you;
• The categories of sources from which the Personal Information is collected;
• The business or commercial purpose for collecting or selling that Personal Information;
• The categories of third parties with whom we disclose Personal Information; and
• The specific pieces of Personal Information we have collected.

Right to Correct. Subject to certain conditions and exceptions, you have the right to request that we correct inaccuracies in your Personal Information.

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Right to Delete. Subject to certain conditions and exceptions, you have the right to request that we delete your Personal Information. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

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Right to Opt-Out of Sales and Sharing. You have the right to opt-out of “sales” and “sharing” of your Personal Information through the use of an opt-out preference signal. Please see Section 5.2 for opt out options. If our Site detects that your browser or device is transmitting an opt-out preference signal, such as the “global privacy control”—or GPC— signal, we will opt that browser or device out of cookies on our Site that result in a “sale” or “sharing” of your Personal Information. If you come to our Site from a different device or from a different browser on the same device, you will need to opt-out, or use an opt-out preference signal, for that browser and/or device as well.

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Right to Limit Use and Disclosure. We do not engage in uses or disclosures of “sensitive personal information” that would trigger the Right to Limit Use of Sensitive Personal Information under the CCPA.

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Right to Non-Discrimination. We will not discriminate against you in terms of price or service level for exercising any of the rights described in this section.

Exercising Your CCPA Rights

If you are a California resident and would like to exercise your CCPA rights, you may do so via by emailing us at privacy@entera.ai.

California “Shine the Light” Disclosure

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Sites and Services who are California residents to request, once per calendar year, certain information regarding our disclosure of Personal Information (if any) to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information provided below. Please include in your request a current California address and your attestation that you are a California resident.

9.2. Additional U.S. State Privacy Disclosures

If you live in Colorado (effective July 1, 2023), Connecticut (effective July 1, 2023), Utah (effective December 31, 2023), or Virginia (effective January 1, 2023), you may have these rights:

1. The right to confirm whether Entera is processing your Personal Information, and to access your Personal Information.
2. The right to request we correct inaccuracies in your Personal Information.
3. The right to request we delete your Personal Information.
4. The right to request a copy of the Personal Information you provided to us.
5. The right to opt out of (i) processing of your Personal Information for targeted advertising purposes, (ii) the sale of your Personal Information, and (iii) profiling in furtherance of decisions that produce legal or similarly significant effects.

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To exercise rights (1) through (4), please contact us at privacy@entera.ai.

Entera does not sell your Personal Information as that term is defined under the above state privacy laws. Additionally, Entera does not use Personal Information for profiling in furtherance of decisions that produce legal or similarly significant effects. Therefore, there is no need to exercise rights 5(ii) or 5(iii).

Depending on your state of residence, you may have the right to appeal our decision to refuse to act based on your request. To do so, please contact us at privacy@entera.ai and attach or include information related to your original request.

9.3. European Economic Area (EEA) and United Kingdom Residents

Residents of the EEA and the United Kingdom have the following rights under their applicable data protection laws:

• Right of access: You can access your collected personal information by contacting us at privacy@entera.ai.
• Right to correct, update, or delete: You can correct, update, or request deletion of your personal information by contacting us at privacy@entera.ai. 
• Right to restriction of processing: You can ask us to restrict processing your personal information by contacting us at privacy@entera.ai. 
• Right to object to processing: You may object to the processing of your personal information by us at any time by contacting us at privacy@entera.ai.  This right does not exist if we have already processed your personal information.
• Right to data portability: You can ask to take your personal information that you provided to us, in a structured format, from us by contacting us at privacy@entera.ai. 
• Right to withdraw consent: You have the right to withdraw your consent to our processing of your information by contacting us at privacy@entera.ai. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. 
• Right to file a complaint with the local supervisory authority: You have a right to raise questions or complaints with your local data protection authority at any time.

10. CONTACT US

If you have any questions about our privacy practices or this Privacy Notice, please contact us at:

Attn: 

Legal Department

Entera Holdings Inc

12645 Memorial Dr 

Ste F1 PMB 456

Houston, Texas, 77024-4979

privacy@entera.ai 

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