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Privacy Policy

Effective as of August 31st, 2022, updated November 24th, 2022

Running Tide Technologies, Inc. and our subsidiaries and affiliates ("RunningTide," "we", “us” or "our") is a global ocean health company focused on a number of sustainability initiatives or “Positive interventions”, including rebalancing the carbon cycle by moving fast carbon back to slow through a multi-pathway system, ocean ecosystem restoration and regenerative aquaculture. We partner with businesses across the globe to further this mission. This Privacy Policy describes how Running Tide processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website and social media pages) as well as our offline activities, our marketing activities and live events, and other activities described in this PrivacyPolicy (collectively, the “Service”)).

NOTICE TO EUROPEAN USERS:Please see the below Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly).

Index

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1. Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:‍

Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
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Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Relationship data, such as familial or other relationship to third parties whose personal information you may provide to us.
Payment data needed to complete transactions, including payment card information or bank account number.
Promotion data, including information you share when you enter a competition, promotion or complete a survey. Please note that if you participate in a sweepstakes, contest or giveaway through the Service, we may ask you for your Contact Data to notify you if you win or not, to verify your identity, determine your eligibility, and/or to send you prizes. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules and other relevant information for each sweepstakes and contest that you enter.‍
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Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection
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Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as: Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.

Private sources, such as data providers, social media platforms and data licensors.

Partners, such as joint marketing partners and event co-sponsors.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.

Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.‍

Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clearGIFs), which may be embedded invisibly in our emails. ‍

Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Notice . We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications. ‍

Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

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2. How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

Provide, operate and improve the Service and our business;
Personalizing the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
Enable security features of the Service
Communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
Communicate with you about events or contests in which you participate

Understand your needs and interests, and personalize your experience with the Service and our communications; and
Provide support for the Service, and respond to your requests, questions and feedback.

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Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services.

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described-out of marketing section below. ‍
Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you.This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.You can learn more about your choices for limiting interest-based advertising in the Your choices section of our Cookie Notice.

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Events, promotions and contests. We may use your personal information to contact or market to you after collecting your personal information at an event.

Service improvement and analytics.
We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Compliance and protection. We may use your personal information to:

Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
Audit our internal processes for compliance with legal and contractual requirements or our internal policies;
Enforce the terms and conditions that govern the Service; and
Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business

Cookies and similar technologies. See our Cookie Notice for information regarding how we use cookies and similar tracking technologies

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3. How we share your personal information

We may share your personal information with the following parties and as otherwise described in thisPrivacy Policy, in other applicable notices, or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).

Marketing and advertising partners. Third-party advertising companies for the interest-based advertising purposes described above and third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g.,investments in Running Tide, financing of Running Tide, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counter parties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Running Tide as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets

4. Your choices

In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights int he Notice to European Users below.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies and tracking technologies. For information about cookies and other tracking technologies employed by the Service, including how to control them and how you may be able to limit use of your information for interest-based advertising, see our Cookie Notice .

Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Do Not Track. SomeInternet browsers may be configured to send “Do Not Track” signals to theonline services that you visit. We currently do not respond to “Do Not Track” orsimilar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services.If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

5. Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content maybe integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party.We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

6. International datatransfer

Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Users in Europe should read the important information provided in the Notice to European Users below about transfer of personal information outside of Europe

7. Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

8. Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of thisPrivacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (oras otherwise indicated at the time of posting). In all cases, your use of theService after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

9. How to contact us

Email: Contact@runningtide.com
‍Mail: P. O. Box 10304 Portland, ME 04104, USA
‍Phone: +1-207-747-4226

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10. Notice to European users

General

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Where this Notice to European users applies. The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom and the European Economic Area (i.e., “Europe” as defined at the top of this Privacy Policy).

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from they are either directly identified or can be identified.

Controller. Running Tide is the controller in respect of the processing of your personal information covered by this PrivacyPolicy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called ‘UK GDPR’ (as and where applicable, the “GDPR”)).

Our UK GDPR Representative. We have appointed the following representative in the UK as required by the UK GDPR – you can also contact them directly should you wish. Our UK representative appointed under the UK GDPR is EDPO UK. You can contact them:

By using EDPO UK’s online request form: https://edpo.com/uk-gdpr-data-request/‍
By writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a“legal basis” for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).

Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.

Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).

Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

We have set out below, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see ‘How we use your personal information’

Service delivery and operations
Contractual Necessity‍

Communications data
Transactional data
Relationship data
Payment data
Device data

Research and development
We have legitimate interest, and believe it is also in your interests, that we are able to take steps to ensure that our services and how we use Personal Information is as un-privacy intrusive as possible.

‍Any and all data types relevant in the circumstances

Direct marketing‍

Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organisation and sending marketing communications for that purpose.

Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.

Contact data
Communications data
Transactional data
Marketing data

Interest-based advertising
Consent

Device data
Online activity data

Events, promotions and contests
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Contractual Necessity to administer the promotions and contests in accordance with the terms or rules thereof (including communicating with you as and where necessary).

In respect of promoting these events, promotions and contests:

Legitimate Interests – we have a legitimate interest in promoting these promotions and contests, including associated publicising of our business and operations.
Contractual Necessity to administer the promotions and contests in accordance with the terms or rules thereof (including communicating with you as and where necessary).
In respect of promoting these events, promotions and contests:
Legitimate Interests – we have a legitimate interest in promoting these promotions and contests, including associated publicising of our business and operations.

Consent – in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given promotional communications.

Promotion data
Contact data
Communications data

Service improvement and analytics

We have a legitimate interest in providing you with a good service, which is personalised to you and that remembers your selections and preferences.

Consent, in respect of any optional cookies used for this purpose

Contact data
Device data
Online activity data
Communication data

Compliance and protection
Compliance with Law.
Legitimate interest. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.

Contact data
Demographic data

To create aggregated, de-identified and/or anonymized data

Legitimate interest. We have legitimate interest, and believe it is also in your interests, that we are able to take steps to ensure that our services and how we use Personal Information is as un-privacy intrusive as possible.

Any and all data types relevant in the circumstances

Further uses

The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected.

Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Any and all data types relevant in the circumstances

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11. Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for Compliance and protection purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can not longer be associated with you), we may use this information indefinitely without further notice to you.

12. Other Info

No sensitive personal information. We ask that you not provide us with any sensitive personal in formation (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services, or otherwise to us. If you provide us with any sensitive personal information to us when you use the services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our services.

No Automated Decision-Making and Profiling. As part of theService, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects.

13. Your rights

General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information where there is no lawful reason for us continuing to store or process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be described to you, if applicable, at the time of your request;
Portability. Port a machine-readable copy of your personal information to you or a third party of your choice, in certain circumstances. Note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you.
Restrict. Restrict the processing of your personal information, if, (i) you want us to establish the personal information's accuracy; (ii) where our use of the personal information is unlawful but you do not want us to erase it; (iii) where you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use it.
Object. Object to our processing of your personal information where we are relying on LegitimateInterests (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedom – you also have the right to object where we are processing your personal information for direct marketing purposes.
Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

Exercising These Rights. You may submit these requests by online form or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.

Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area:
the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
For users in the UK:
the contact information for the UK data protection regulator is below:

The Information Commissioner’s Office

Water Lane, Wycliffe House

Wilmslow - Cheshire SK9 5AF

Tel. +44 303 123 1113

Website: https://ico.org.uk/make-a-complaint/

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Data Processing outside Europe

We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use theService, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.

It is important to note that that the US is not the subject of an ‘adequacy decision’ under the GDPR – basically, this means that the U.S. legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information, which is equivalent to that provided by relevant European laws.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented: ‍

Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).

Transfers to territories without an adequacy decision.
We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S., see above).
However, in these cases:
We may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has inEurope – for example, standard-form contracts approved by relevant authorise for this purpose; or

In limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or‘ appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.