Privacy Policy

Effective as of July 19, 2022
This privacy policy (the “Privacy Policy”) applies to the information collection and use practices
of our online services, which are made available to you through a variety of platforms, such as
through the gente mobile application (the “App”), our website, located at
(the “Site”), and through our social media accounts on LinkedIn, Facebook, Google, Twitter,
Instagram, TikTok and others (collectively, “Social Media”), all owned and operated by gente
Employee Benefits and HR Solutions (“gente,” “we,” “us,” or “our”). The App, the Site, and our
Social Media accounts are collectively referred to as the “Platform.” We have created this
Privacy Policy to tell you what information the Platform collects, how we use that information,
and who we will share that information with, if at all. This Privacy Policy does not address the
privacy practices of any third parties that we do not own, control, or are affiliated with.
Capitalized terms not defined in this Privacy Policy will have the meaning set forth in our Terms
of Use. By visiting and/or using our Platform, you are agreeing to the terms of this Privacy
Policy and the accompanying Terms of Use. We encourage you to read the Privacy Policy, and
to use the information it contains to help you make informed decisions.

  1. Information We Collect or Receive. In the course of operating the App, we will collect
    and/or receive the following types of information. You authorize us to collect and/or receive
    such information.
    (a) Personal Information. We only receive or collect information that identifies you
    personally if you or your employer chooses to provide such personally identifiable
    information to us. When you sign up to become a user or contact us, you will be
    required to provide us with personal information about yourself (collectively, the
    “Personal Information”). Such Personal Information may include your name, e-mail
    address, physical address, and phone number. We do not collect any Personal
    Information from you when you use the App unless you provide us with the Personal
    Information voluntarily.
    (b) Reserved.
    (c) Reserved.
    (d) Geolocational Information. Certain features and functionalities of the App or website
    are based on your location. In order to provide these features and functionalities while
    you are using your mobile device, we may, with your consent, automatically collect
    geolocational information from your mobile device or wireless carrier and/or certain
    third-party service providers (collectively, “Geolocational Information”). Collection of
    such Geolocational Information occurs only when the App is running on your device.
    You may decline to allow us to collect such Geolocational Information, in which case
    we will not be able to provide certain features or functionalities to you.
    (e) Other Information. In addition to the Personal Information, we may automatically
    collect or receive additional information regarding you and your use of the App; your
    interactions with us and our advertising; and information regarding your computer and
    mobile devices used to access the App (collectively, the “Other Information”). Such
    Other Information may include:
    (i) From You. Additional information about yourself that you voluntarily provide to
    us, such as your gender and your product and service preferences.
    (ii) From Your Activity. We may collect or receive information regarding:
    (A) IP address, which may consist of a static or dynamic IP address and will
    sometimes point to a specific identifiable computer or mobile device;
    (B) browser type and language;
    (C) referring and exit pages and URLs;
    (D) date and time; and
    (E) details regarding your activity on the App, such as search queries and other
    performance and usage data.
    (iii) About Your Mobile Device. We may collect or receive information regarding:
    (A) type of mobile device;
    (B) advertising Identifier (“IDFA” or “AdID”);
    (C) operating system and version (e.g., iOS, Android or Windows);
    (D) carrier; and
    (E) network type (WiFi, 3G, 4G, LTE).
    (iv) From Cookies. We may use both session cookies, which expire once you close
    the App, and persistent cookies, which stay on your mobile device until you
    delete them and other technologies to help us collect data and to enhance your
    experience with the App. Cookies are small text files an app can use to recognize
    a repeat visitor to the app. We may use cookies for various purposes, including to:
    (A) type of mobile device;
    (B) personalize your experience;
    (C) analyze which portions of the App are visited and used most frequently; and
    (D) measure and optimize advertising and promotional effectiveness.
    If you do not want us to deploy cookies in the App, you can opt out by setting
    your mobile device to reject cookies. You can still use the App if you choose to
    disable cookies, although your ability to use some of the features may be affected.
  1. Reserved.
  1. Reserved.
  1. How Information Is Used and Shared.
    (a) You authorize us to use the Personal Information, Payment Information, Geolocational
    Information, and the Other Information (collectively, the “Information”) to:
    (i) provide and improve our App;
    (ii) provide our services;
    (iii) administer our promotional programs;
    (iv) solicit your feedback; and
    (v) inform you about our products and services.
    (b) In order to provide our services and administer our promotional programs, we may
    share the Information with our third-party promotional and marketing partners,
    including, without limitation, businesses participating in our various programs.(c) We engage third-party companies and individuals to perform functions on our behalf.
    Examples may include providing technical assistance, customer service, marketing
    assistance, and administration of promotional programs. These other companies will
    have access to the Information only as necessary to perform their functions and to the
    extent permitted by law
    (d) In an ongoing effort to better understand our users, the App, and our products and
    services, we may analyze certain Information in anonymized and aggregate form to
    operate, maintain, manage, and improve the App and/or such products and services.
    This aggregate information does not identify you personally. We may also disclose
    aggregated user statistics to describe the App and these products and services to current
    and prospective business partners and investors and to other third parties for other
    lawful purposes.
    (e) We may share some or all of your Information with any of our parent companies,
    subsidiaries, joint ventures, or other companies under common control with us.
    (f) As we develop our businesses, we might sell or buy businesses or assets. In the event
    of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event,
    the Information may be part of the transferred assets.
    (g) To the extent permitted by law, we may also disclose the Information:
    (i) when required by law, court order, or other government or law enforcement
    authority or regulatory agency; or
    (ii) whenever we believe that disclosing such Information is necessary or advisable,
    for example, to protect the rights, property, or safety of us or others, including you.
  1. Accessing and Modifying Information and Communication Preferences. If you have
    provided us any Personal Information, you may access, remove, review, and/or make
    changes to the same by contacting us as set forth below. In addition, you may manage your
    receipt of marketing and non-transactional communications by clicking on the “unsubscribe”
    link located on the bottom of any of our marketing e-mails. We will use commercially
    reasonable efforts to process such requests in a timely manner. You should be aware,
    however, that it is not always possible to completely remove or modify information in our
    subscription databases. You cannot opt out of receiving transactional e-mails related to the
    App (e.g., requests for support).
    We may also deliver notifications to your mobile device (e.g., push notifications). You can
    disable these notifications by deleting the relevant service or by changing the settings on your
    mobile device.
  1. How We Protect Your Information. We take commercially reasonable steps to protect the
    Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.
    Please understand, however, that no security system is impenetrable. We cannot guarantee
    the security of our databases or the databases of the third parties with which we may share
    such Information, nor can we guarantee that the Information you supply will not be
    intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not
    be secure, and you should therefore take special care in deciding what information you send
    to us via e-mail.
  1. Important Notices to Non-U.S. Residents. The App and its servers are operated in the
    United States. If you are located outside of the United States, please be aware that your
    Information, including your Personal Information, may be transferred to, processed,
    maintained, and used on computers, servers, and systems located outside of your state,
    province, country, or other governmental jurisdiction where the privacy laws may not be as
    protective as those in your jurisdiction. If you are located outside the United States and
    choose to use the App, you hereby irrevocably and unconditionally consent to such transfer,
    processing, and use in the United States and elsewhere.
  1. App Stores; External Websites. Your app store (e.g., iTunes or Google Play) may collect
    certain information in connection with your use of the App, such as Personal Information,
    Payment Information, Geolocational Information, and other usage-based data. We have no
    control over the collection of such information by a third-party app store, and any such
    collection or use will be subject to that third party’s applicable privacy policies.

    The App may contain links to third-party websites. We have no control over the privacy
    practices or the content of these websites. As such, we are not responsible for the content or
    the privacy policies of those third-party websites. You should check the applicable third-
    party privacy policy and terms of use when visiting any other websites.
  1. Children. The App is not directed to children under the age of 13. We adhere to the
    Children’s Online Privacy Protection Act (COPPA) and will not knowingly collect Personal
    Information from any child under the age of 13. We ask that minors (under the age of 13) not
    use the App. If a child under the age of 13 has provided us with Personal Information, a
    parent or guardian of that child may contact us and request that such information be deleted
    from our records.
  1. Under California Civil Code Section 1798.83, California residents who have an established
    business relationship with us may choose to opt out of our sharing their PI with third parties
    for direct marketing purposes. If you are a California resident and you wish to request certain
    information regarding our disclosure of your PI to third parties for direct marketing purposes,
    please send write to us at: gente Privacy, 122 Parish Drive, Wayne, NJ 07470.
  1. Changes to This Privacy Policy. This Privacy Policy is effective as of the date stated at the
    top of this Privacy Policy. We may change this Privacy Policy from time to time. Any such
    changes will be posted on the App. By accessing the App after we make any such changes to
    this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to
    the extent permitted by applicable law, our use of the Information is governed by the Privacy
    Policy in effect at the time we collect the Information. Please refer back to this Privacy
    Policy on a regular basis.
  1. How to Contact Us. If you have questions about this Privacy Policy, please e-mail us at
    [email protected] with “Privacy Policy” in the subject line or mail us at the
    following address: 122 Parish Drive, Wayne, New Jersey 07470.