WEBSITE PRIVACY POLICY

Last modified: May 13, 2025

Introduction

ATTENTABILITY LLC („Company“ or „We“) respects your privacy and is committed to protecting it through our compliance with this policy. We do not sell your personal information or share it for marketing purposes. Any sharing of data is strictly limited to what is necessary to deliver our services or comply with legal requirements. We are committed to collecting only the information needed to operate our services effectively and improve your experience on our website.

This policy describes the types of information we may collect from you or that you may provide when you visit the website attentability.com (our „Website„) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Website is primarily intended for users in the United States and Canada, although it is accessible worldwide. Users located in the European Union are encouraged to visit our designated EU website, which is governed by applicable EU data protection laws.

This policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info(at)attentability.com.

Residents of certain states under 13, 16, or 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your State Privacy Rights for more information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, email address, telephone number, or any other identifier by which you may be contacted online or offline („personal information“)
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us.

No tracking technologies such as web beacons or fingerprinting tools are employed. This website does not use marketing or analytics cookies.

Information You Provide to Us

The information we collect on or through our Website may include:

• Records and copies of your correspondence (including email addresses), when you contact us.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To provide you with information or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• For any other purpose with your consent.

Disclosure of Your Information

We may need to disclose personal information that we collect or you provide as described in this privacy policy:

• To our affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ATTENTABILITY LLC ’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by ATTENTABILITY LLC about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our  Terms of Use  or and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ATTENTABILITY LLC, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

The categories of personal information we may disclose include:

• Identifiers such as name, email address, mailing address, and telephone number;
• Internet or other electronic network activity information, and interactions with our Website or advertisements;
• Any other information you voluntarily provide to us that is reasonably necessary for us to provide services or comply with legal obligations.

Accessing and Correcting Your Information

You may also send us an email at info(at)attentability.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah).
• Data portability.
• Opt-out of personal data processing for: (1) targeted advertising (excluding Iowa), (2) sales, or (3) profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
• Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state. To exercise any of these rights please contact us at info(at)attentability.com.

Data Retention

We retain personal information, including email correspondence, only for as long as necessary to fulfill the purposes for which it was collected or to comply with applicable legal obligations. In most cases, this retention period does not exceed 12 months, unless a longer period is required by law.

You may request the deletion of your personal information at any time by contacting us at info(at)attentability.com.

Governing Law

This Privacy Policy is governed by the laws of the Commonwealth of Massachusetts, United States, without regard to its conflict of laws principles. Any disputes arising from or relating to this Policy shall be subject to the exclusive jurisdiction of the state and federal courts located in Massachusetts.

Hosting and Data Handling

Your personal information may be processed or stored on secure third-party infrastructure located in the United States or other jurisdictions, including those outside your home country. These providers operate under strict contractual obligations and industry-standard data protection protocols.

Access to stored data is role-based and granted only when necessary for operational purposes. As part of our commitment to safeguarding your information, we regularly evaluate and update our data handling practices. In certain cases, we may require verification of identity before disclosing personal information.

International Data Transfers

If you access this Website from outside the United States or Canada and choose to provide personal information, you acknowledge that your data may be transferred to, stored, and processed in the United States or other countries where our service providers operate. These jurisdictions may have different data protection laws than those in your home country. By submitting your information, you consent to such transfers and understand that your data may be subject to the laws and legal authorities of the applicable jurisdictions.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users‘ personal information, we will notify you by email and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: info(at)attentability.com