Privacy Policy

Last Updated: June, 11 2024

ALLCITY Network, Inc. and its affiliates (collectively “ALLCITY,” “we,” “us,” or “our”) respects your privacy. This privacy policy (the “Policy”) helps our users (a “User” or “you”) understand why we collect information, what information we collect, how we secure it, and what choices are available for you to manage it.

We collect information about you when you use our websites, thednvr.com, gophnx.com, allchgo.com, allphly.com, allcitynetwork.com, dnvrlocker.com, phnxlocker.com, chgolocker.com, phlylocker.com (collectively, the “Website”), when you use our mobile application, and when you interact with us as a customer or otherwise (collectively, the “Services”).

For purposes of this Policy, personal information or personal data means information that identifies, relates to, describes, or can be associated with you. Nothing in this Policy will constitute an admission or evidence that any particular data privacy or information security law or regulation applies to us generally or in any specific context. Depending on your location, we may provide additional region-specific terms or policies. These apply only to the customers located in those geographic regions.

Please see our Terms of Service for other terms governing the use of this Website, including our arbitration provision.

1. You Consent to This Policy

By using the Services, you confirm you have read, understood, and agreed with this Policy. If you do not agree to this Policy, you may not engage with our Services.

This Policy applies regardless of what Services you use or how our Services are accessed and will cover any technologies or devices by which we make any Services available to you.

We may provide you with additional privacy notices where we believe it is appropriate to do so. It is important that you read this Policy together with any other privacy notice or fair processing notice we may provide on specific occasions, so that you are fully aware of how and why we are using your data.

If you have any questions or concerns about our personal information policies or practices, you can contact us in the methods described below in the “Contact Us” section below.

2. Information We Collect About You

We collect information about you from the following sources: information that you provide directly to us; information that we collect indirectly from you, such as from observing and analyzing your actions on our website, apps, advertisements, or social media websites; and information collected from service providers and/or third parties. The categories of personal information that we collect and the purposes for which we collect that information are described below.

Categories of Personal Information We Collect

The following list describes the categories of personal information we collect.

Account Information includes name, email address, address, phone number, username, and password. We collect this information when you provide it directly to us. We collect this information for the purposes of account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.
Analytics Information. We collect certain analytics information automatically as you navigate our Services. This includes cookies, tracking pixels, tags or similar tools, which may collect information about your browser, device, geolocation, and interactions with the Services, Website, or emails. For more information, please view the “How Do We Use “Cookies” and Other Tracking Technologies?” section below. We collect this information for the purposes of account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.
Contact Information includes name, email address, mailing address, and phone number. We collect this information when you provide it directly to us such as signing up for newsletters, requesting information about ALLCITY Services, creating an account, or filling out a form. We collect this information for the purposes of account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.
Commercial History includes information regarding the purchases you have made through our Services, products or Services you have purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. We collect this information for the purposes of account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.
Payment Information includes name, address, phone number, and debit or credit card information. We use third party payment processors which collect this information for the purposes of account creation and management, analytics and research, customer service, and website security and maintenance.
Responses to Surveys and Questionnaires includes any information you provide to us when you participate in voluntary market research surveys such as email address and interested products. We collect this information for the purposes of advertising and marketing, analytics and research, customer service, and website security and maintenance.
User-Generated Content. If you post, upload, comment, or otherwise submit content on the Services, we may collect certain information about you such as your name, email address, and products you may have purchased. Be aware that as a default, any information you post on the Services, including without limitation reviews, comments, photos, and videos, may be available to and searchable by all users of the Services. We collect this information for the purposes of account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.

Other Ways We May Collect, Use, or Share the Information

We may also reserve the right to collect, use, or share personal information for the following purposes:

For Legal Purposes. We reserve the right to cooperate with local, provincial, state, federal and international officials in any investigation requiring either personal information or reports about lawful of unlawful user activity on this Website. We also reserve the right to share your personal information to establish, exercise, or defend our legal and property rights, including providing information to others for the purposes of fraud prevention. We may also share your personal information with any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

If we are ordered by a legal process or government to provide data about one or more individual users, we will notify those users of our compliance with that order, to the extent permitted by law.

To Present the Website. We will use personal information to present our Website and its contents in a suitable and effective manner for you and your device.
To Provide the Services. We will use personal information to provide the Services, including to improve operations and for security purposes.
Customer Service. We will use your personal information to provide you with customer service, troubleshoot issues, and respond to requests, questions or comments.
Provide Information and Opportunities. We will use your personal information to advertise shows, events, or Services that we think may be of interest to you.
Business Transactions or Mergers. We reserve the right to share your personal information to third parties as part of any potential business or asset sale, merger, acquisition, investment, round of funding, or similar type of transaction. Additionally, if we are entering into a corporate transaction with a third party, we may receive personal information in connection with the diligence. If we close a transaction, the third party may transfer personal information, which we would use as described in this Policy.
Bankruptcy or Insolvency. In the event of bankruptcy, insolvency, or dissolution proceedings, we may share your personal information with third parties as part of the sale or reorganization process.
Information From Our Partners. We may collect information from our partners such as market research firms, and our affiliates, subsidiaries, joint ventures, or other companies under common control. We may combine that information with other information we collect about you, but we will always use the information as described in this Policy. We collect this information for the purposes of marketing, advertising, research, and analytics.

3. How Do We Use “Cookies” and Other Tracking Technologies?

What are Cookies?

“Cookies” are small data files that are placed on your device to track your behavior in the browsers you visit. Cookies enable us to personalize your Website viewing experience. ALLCITY or our third-party provider places cookies on a User’s hard drive. Cookies can save the information noted above in the “Information We Collect About You” section of this Policy. You can configure your browser to prevent cookies, but please note that disabling cookies may impede Website features.

What Types of Cookies Do We Use and Why?

There are different types of cookies that have different functions. The chart below illustrates the cookies that we and our service providers use on the Services, examples of who serves those cookies, and links to the privacy policies of those cookie servers. The chart is illustrative only. The specific cookies we use may vary over time and may change depending on which page you are visiting.

Types of Cookies	Purpose	Who Serves (for example)
Essential	These cookies are used to recognize you when you return to the Services. This enables us to personalize content for you and remember your preferences. These cookies also enable your interactions with the Services such as emailing us and customer support chat.	● ALLCITY ● Adobe ● Google ● TRUSTe Notice
Functionality	These cookies are used to recognize you when you return to the Services. This enables us to personalize content for you and remember your preferences. These cookies also enable your interactions with the Services such as emailing us and customer support chat.	● Cookiebot ● Google ● TrustArc
Analytics, Performance, and Research	These cookies, beacons, and pixels allow us to analyze activities on the Services. They can be used to improve the functioning of the Services. For example, these cookies recognize and count the number of visitors and see how they move around the Services. Analytics cookies also help us measure the performance of our advertising campaigns to help us improve them and to optimize the content on the Services for those who engage with our advertising.	● Google ● Meta
Social Networking	These cookies are used to enable you to share pages and content that you find interesting on our Services through third party social networking and other websites. These cookies may also be used for advertising purposes.	● Google ● Meta ● LinkedIn ● Gravatar ● TikTok ● X
Advertising	These cookies and pixels are used to deliver relevant ads, track ad campaign performance, or track email marketing.	● AddThis ● Admixer ● Adobe ● Amazon ● Beeswax ● BlueKai ● Criteo ● Google ● Meta ● Microsoft ● SpotX ● Tapad ● TradeDesk ● Yahoo!

How Long Do Cookies Stay on My Device?

Some cookies operate from the time you visit the Website until the end of that particular browsing session. These cookies, which are called “session cookies,” expire and are automatically deleted when you close your Internet browser. Some cookies will stay on your device between browsing sessions and will not expire or automatically delete when you close your Internet browser. These cookies are called “persistent cookies” and the length of time they will remain on your device will vary from cookie to cookie. Persistent cookies are used for a number of purposes, such as storing your preferences so that they are available for your next visit and to keep a more accurate account of how often you visit the Website, how your use of the Website may change over time, and the effectiveness of advertising efforts.

Managing Your Cookies

It may be possible to block cookies by changing your Internet browser settings to refuse all or some cookies. If you choose to block all cookies (including essential cookies) you may not be able to access all or parts of the Website. You can find out more about cookies and how to manage them by visiting www.AboutCookies.org.

Does the Website Respond to “Do Not Track” Signals?

ALLCITY responds to the Global Privacy Control (“GPC”) signal. The GPC signal is a browser level signal that can reflect the desire to opt-out of having personal information shared or sold. Some browsers allow transmission of GPC signal. By broadcasting this signal, ALLCITY will not transmit your personal

information to third parties who perform analytics services or who advertise to you based on this information. Please note that your use of our Website will still be tracked by ALLCITY and its service providers who have agreed to limit their use of personal information.

4. Advertising and Marketing Choice

We respect your rights in how your personal information is used and shared. If at any time you would like to unsubscribe from receiving future emails, you can email us at info@allcitynetwork.com or follow the instructions at the bottom of each email, and we will promptly remove you from marketing correspondence. Please note, however, that we may still need to contact you regarding other matters.

5. How Long Is Your Personal Information Kept?

We will retain your personal information until the personal information is no longer necessary to accomplish the purpose for which it was provided. We may retain your personal information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, and unauthorized access, as necessary to protect our legal rights, or for certain business requirements.

We will delete your personal information when it is no longer necessary for the purpose for which it was collected, or upon your request, subject to exceptions as discussed in this Policy or under applicable law, contract, or regulation.

You may also delete your account within our mobile application.

6. Security

The security of your personal information is important to us. We take various reasonable organizational, administrative, and technical measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. If required by law to do so, we will notify you and/or the relevant supervisory authority in the event of a security incident or breach.

7. Where Your Personal Information Is Held

We process personal information on our servers in the United States of America and may do so in other countries. If you use our Services or otherwise provide us with information from outside of the United States, you expressly consent to the transfer of your data to the United States, the processing of your data in the United States, and the storage of your data in the United States.

8. Third-Party Links

This Website contains links and references to other sites, including social media sites. ALLCITY is not responsible for the privacy practices, security measures, or the content of such websites. When we provide links, we do so only as a convenience. It is important to note that this Policy only applies to ALLCITY’s Services. We are not responsible and assume no responsibility for any personal information

collected, stored, or used by any third party as a result of you visiting third-party websites. We also advise that you carefully read the privacy notice of any third-party websites you choose to visit.

9. Children’s Privacy

Protecting the privacy of the very young is especially important. Our Services are not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. In the event that we learn that we have collected personal information from a child under age 13 without verification or parental consent, we will immediately delete that information. If you believe that we might have any information from or about a child under 13, please contact us using the information provided in the “Contact Us” section below.

10. European Users’ Rights

This section of the Policy is applicable to persons located in the European Union (“EU”), a European Economic Area member state (“EEA”), United Kingdom (“UK”), or Switzerland as well as to persons whose personal information is processed in or transferred from the EU, EEA, UK, or Switzerland. You are entitled under the EU General Data Protection Regulation and UK General Data Protection Regulation (collectively, the “GDPR”), to the information in this section of the Policy.

Your Rights

You are entitled by law to access, correct, amend, or delete personal information about you that we hold. A summary listing these rights appears below. Please note that these rights are not absolute and certain exemptions may apply to specific requests that you may submit to us.

To exercise these rights, please contact us using the information below in the “Contact Us” section. For your protection, we may need to verify your identity before responding to your request. In the event that we refuse a request, we will provide you a reason as to why.

Asking us to access your personal information

You have the right to obtain from us confirmation as to whether or not we are processing personal information about you, and if so, the right to be provided with the information contained in this Policy. You also have the right to ask us for copies of your personal information. When making a request, please provide an accurate description of the personal information to which you want access. Where requests are repetitive or manifestly unfounded or excessive, we may charge a reasonable fee based on administrative cost.

Asking us to rectify your personal information

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Asking us to delete your personal information

You have the right to ask us to erase your personal information if:

We no longer need it for the purposes for which we collected it;
We have been using it with no valid legal basis;
We are obligated to erase it to comply with a legal obligation to which we are subject;
We need your consent to use the information and you withdraw consent; or
You object to us processing your personal information where our legal basis for doing so is our legitimate interests and there are no overriding legitimate grounds for the processing.

However, this right is not absolute. Even if you make a request for deletion, we may need to retain certain information for legal or administrative purposes, such as record keeping, maintenance of opt-out requirements, defending or making legal claims, or detecting fraudulent activities. We will retain information in accordance with the “How Long Is Your Personal Information Kept” section.

If you do exercise a valid right to have your personal information deleted, please keep in mind that deletion by third parties to whom the information has been provided might not be immediate and that the deleted information may persist in backup copies for a reasonable period (but will not be available to others).

Asking us to restrict our use of your personal information

You have the right to ask us to place a restriction on our use of your personal information if one of the following applies to you:

You contest the accuracy of the information that we hold about you, while we verify its accuracy; ● We have used your information unlawfully, but you request us to restrict its use instead of erasing it;
We no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or
You have objected to us using your information, while we check whether our legitimate grounds override your right to object.

The right to transfer your personal information to another service provider You have the right to ask that we transfer the personal information you gave us from one organization to another or give it to you (i.e. data portability). This applies to personal information we are processing to service a contract with you and to personal information we are processing based on your consent.

The right to withdraw consent

If we obtain your written consent to collect and process your personal information, you can subsequently withdraw such consent as to any further processing of such information.

The right to lodge a complaint with a supervisory authority

If you believe your rights under the GDPR have been violated, the GDPR gives you the right to file a complaint with your supervisory authority. A list of supervisory authorities is available here: EEA and EU Data Protection Authorities (DPAs); Swiss Federal Data Protection and Information Commissioner (FDPIC); UK Information Commissioner’s Office (ICO).

Rights related to automated decision-making

To the extent that we engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you, you have the right not to be subject to such decision-making.

Right to object to processing

You have the right to object to the processing of your personal information that is based on legitimate interests or your consent (rather than when the reason for using it is to perform an obligation due to you under a contract with us). If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or we can demonstrate the processing is for the establishment, exercise, or defense of legal claims. You can object to the processing of your personal information by contacting us using the information in the “Contact Us” section below.

Legal Bases for Processing Your Personal Information

ALLCITY collects your personal information to provide our products and Services to you; otherwise, we may not be able to process the transactions you request. We will only process your personal information when we have a lawful basis for doing so. If you are in a country in the EU, EEA, UK, or Switzerland, you are entitled to an explanation of the legal bases we rely on to process your personal information. The legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it, which is discussed below.

Consent. We may process your personal information based on your consent such as when you purchase a service or ask us to send you certain kinds of marketing communications. You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.
- Children’s Consent. We do not knowingly process data of EU, EEA, UK, or Switzerland residents under the age of 16 without reasonably verified parental consent.
Our Legitimate Interests. We may process your personal information if doing so is necessary for our legitimate interests relating to our business purposes arising from your relationship with us, and your rights as an individual do not override those legitimate interests. For example, our legitimate interests include but are not limited to when we process your personal information to

carry out fraud prevention activities and activities to increase network and information security, identify usage trends, determine the effectiveness of promotional campaigns, expand our business activities and improve our services and the content and functionality of our Services. Our legitimate interests also include providing you with the products and services you request, view, engage with, or purchase and communicating with you regarding your account or transactions with us.

To Perform a Contract. We may process your personal information to administer and fulfill contractual obligations to you. We will also collect and process your personal information as necessary for the performance of a contract to which you are a party.
To Enable Us to Comply With a Legal Obligation. We may process your personal information to comply with legal obligations to which we are subject. This may include any requirement to produce audited accounts, any legal obligation to share information with law enforcement agencies, public or governmental authorities, and to comply with legal process.
Necessary for the Exercise or Defense of Legal Claims. If you bring a claim against us or we bring a claim against you, we may process your personal information in relation to that claim.

Depending on the situation, we may be the controller or the processor for personal information collected from residents of the EU, EEA, UK or Switzerland. If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information for any specific processing activity, please contact us using the “Contact Us” section below.

Cross-Border Transfers of Personal Information

Our Services are operated in the United States. Personal information about you provided while in the EU, an EEA member state, the UK, or Switzerland may be transferred to the United States. The EU, UK, and Switzerland developed respective Data Privacy Frameworks (the “Framework”), which provide a mechanism for companies to transfer personal data from the EU, UK, or Switzerland to the United States in a privacy-protective way. Companies may certify their privacy practices to join the Framework. Participation is voluntary and ALLCITY does not participate at this time. However, the GDPR permits cross-border transfers when necessary for the performance of a contract between you and us, if we obtain your explicit consent to such transfer, or if it is in our legitimate interest to transfer the personal information. The laws in the United States may not be as protective as the GDPR or the laws of other jurisdictions where you may be located. If we transfer personal information from the EU, EEA, UK, or Switzerland, or another country with cross-border transfer obligations, we will provide an appropriate safeguard, such as using standard contractual clauses.

To obtain a copy of the safeguard(s), please contact us using the information provided in the “Contact Us” section below.

11. Canadian Privacy

Individuals located in Canada have certain rights under Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDIA), including:

Right to Access Personal Information
Right to Correct (inaccuracies in/update personal information records)
Right to Delete Personal Information
Right to Withdraw Consent (to the use or communication of personal information)

In addition to these rights, individuals in Quebec may have additional rights, such as the right to have your personal information deindexed. If you would like to activate profiling functions, please contact us using the information in the “Contact Us” section below.

These rights are subject to certain conditions and exceptions. If you would like to exercise the rights set out above, please submit a consumer request to us via email at info@allcitynetwork.com. You may also contact our Privacy Officer at info@allcitynetwork.com. You also have the right to file a complaint with the Office of the Privacy Commissioner of Canada or your local privacy commissioner.

ALLCITY may need to transfer personal information to third party service providers outside of your province or territory or outside of Canada. For example, personal information may be transferred to the United States. When personal information is transferred outside of Canada, it is subject to the laws of that foreign jurisdiction which may provide for a different level of protection in respect of your personal

information than that which is applicable in your jurisdiction. Please contact us if you would like more details.

12. Policy Changes

This Policy may change from time to time. If we need to change this Policy at some point in the future, we will post any changes on this page. If we make a significant or material change to this Policy we will notify you via email. You should check these terms when you use the Website. Your continued use of the Website constitutes acceptance of the most current version of this Policy.

13. Contact Us

If you have any questions about this Policy, please contact us by email at info@allcitynetwork.com or at 2239 E Colfax Ave., Denver CO 80206.

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