Privacy Policy


HowGood, Inc., on behalf of its affiliates and subsidiaries (collectively, “HowGood,” “us,” “we,” or “our”) has prepared this Privacy Policy (“Privacy Policy”) to describe to you, or if you represent an entity or other organization, that entity or organization (in either case, “you” or “your”) our online and offline practices regarding the personal information that HowGood collects, uses, and shares on behalf of end users (“Users”) of our website available at and other websites operated by HowGood that contain a hyperlink to this Privacy Policy (each, the “Website”) and the information, data, and other materials and content (“Content”) and services (“Services”) described on the Website.

HowGood reserves the right, at any time, to modify this Privacy Policy.  If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy.  You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices.  We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy.  Your continued use of the Website following posting of changes constitutes your acceptance of such changes.

Collection of Personal Information


Personal Information

The following are categories (with non-exhaustive examples) of personal information we may collect from you or about you:

  • Identifier Information, such as your name, email, address, phone number, login name and password.
  • Business data, such as the company you work for and job title.
  • Communications that we exchange, including when you contact us with questions, feedback, or otherwise through our chat service.
  • Cookies and internet activity, such as text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns.
  • Marketing data, such as your preferences for receiving communications about our Services, activities, events, and publications, and details about how you engage with our communications.
  • Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed on the Website at the time of collection.

Deidentified or Aggregate Information

Personal information does not include Deidentified and Aggregate Information. “Deidentified Information” means information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular individual, and for which HowGood has implemented technical safeguards and business processes that prohibit reidentification of the individual.  “Aggregate Information” means information that relates to a group or category of individuals, from which individual identities have been removed, that is not linked or reasonably linkable to any individual or household, including via a device.

Sources of Personal Information

We obtain personal information from the following categories of sources:

  • Personal Information You Provide. HowGood collects personal information when you voluntarily submit it to us.
  • Personal Information that is Automatically Collected. In addition to personal information that we may receive directly from you, HowGood indirectly collects other information from you automatically through the Website, your computer or mobile device, and your activity over time on our Website, and other sites and online services.
  • Personal Information Obtained from Third Parties. HowGood may receive personal information about you from other third party sources, including from business partners or data providers.  We may merge or combine such personal information with the personal information we collect from you directly or automatically.

Use of Personal Information


HowGood’s primary purpose in collecting personal information is to provide the Services and Content that you request on the Website.  HowGood may also use personal information for various purposes, including without limitation:

  • To Provide Our Content and Services. This could include fulfilling your requests for Services. It could also include processing purchases or other transactions.  For example, if you share your personal information to request a price quote or ask a question about our Services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a Service, we will use such information to process your payment and facilitate delivery.
  • To Improve Our Content and Services. We use personal information to understand and analyze the usage trends and preferences of our Users to make our Website, Services, or Content better, diagnose technical issues, prevent fraud, and develop new features and functionality.
  • To Understand Your Interests. We use your personal information to personalize your experience on the Website and to deliver information about Services relevant to your interests.  Our Website may make suggestions for Content that may be interesting to you and others. We use the data you provide and the data we have about other users, to make these recommendations.
  • To Respond to Your Requests or Questions. We use personal information to provide you with support and to respond to your requests for customer support, including to investigate and address your concerns and monitor and improve our responses.  This may also include responding to your feedback.
  • To Determine Your Eligibility and Set Up Your Account. We use your personal information to verify your identity or determine your eligibility for some of our Services and promotions.  For example, this may include verifying your age, date of birth, and place of residence.  If you set up an account on the Website, we will use the personal information you provide to establish and maintain that account.
  • To Secure the Website. We use personal information to maintain the safety, security, and integrity of our Website, Content, and Services, databases and other technology assets, business, and other Users.
  • To Communicate with You. We may communicate with you about your account or our relationship.  We may also contact you about this Privacy Policy.
  • As Required by Law. We use personal information to respond to requests from law enforcement and as required by applicable law, court order, or government investigation.

Sharing of Personal Information


In addition to the specific situations discussed elsewhere in this Privacy Policy, HowGood may share your personal information in the following circumstances:

Related Companies and M&A Transactions

We may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us).  In addition, if we sell all or part of its business or make a sale or transfer of assets or is otherwise involved in a merger or business transfer, we may transfer your personal information to a third party as part of that transaction, including at the negotiation stage.


We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy, and we may do so with your consent.

Legal Compliance

We may disclose personal information in response to subpoenas, warrants, or court orders, in connection with any legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our rights; to defend against a legal claim; to investigate, prevent, or take action regarding possible illegal activities or fraud; to protect the safety and security of other Users.

Service Providers

We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of the Website. Among other things service providers may help us perform Website hosting, app design, maintenance services, database management, web analytics, app analytics, billing, payment processing, fraud protection, credit risk reduction, marketing, or any other use set out in this Privacy Policy.


Security of Personal Information


No method of transmission over the Internet, or method of electronic storage, is fully secure.  While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information.  In the event that we are required by law to inform you of any unauthorized access or acquisition of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.


Your Choices


You can make the following choices regarding your personal information:

Modifications to your Personal Information

We rely on you to update and correct the personal information contained in your account. Note that we may keep historical information in our backup files as permitted by law.  If our Website does not permit you to update or correct certain personal information, please contact us as described in the section titled “CONTACTING US” below.

Promotional E-mails

You may choose to provide us with your e-mail address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials.  You can stop receiving promotional e-mails by clicking the “unsubscribe” links in the e-mails or by contacting us as described in the section titled “CONTACTING US” below.  If you decide not to receive promotional e-mails, we may still send you service-related communications, such as those about your account, to fulfill orders for offers you have requested, or deliver notifications directly to you through the Website.


Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit


Notice to California Residents


Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with HowGood are entitled to ask us for a notice describing what categories of personal information we share with third parties for their direct marketing purposes.  This notice will identify the categories of information shared with and will include a list of the third parties with which it is shared, along with their names and addresses.  If you are a California resident and would like a copy of this notice, please submit your request as described in the section titled “CONTACTING US” below.


International Transfers of Personal Information


HowGood is based in the United States of America.  If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to us, please note that any personal information that you provide to us may be transferred to the United States of America.  By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure.


Residents of the European Economic Area


The following applies to individuals in the European Economic Area (EEA):

Lawful Basis for Processing

HowGood is required to inform you of the lawful basis of our processing of your personal information, which are described in the table below.  If you have questions about the lawful basis of how we process your personal information, contact us as described in the section titled “CONTACTING US” below.


Processing Purpose

  • To Improve Our Content and Services.
  • To Market Content or Services.

Lawful Basis

Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in this Privacy Policy.

  • To Provide Our Content and Services.
  • To Communicate with You.
  • To Understand Your Interests.
  • To Process Your Payment for Services.
  • To Respond to Your Requests or Questions.

Processing is necessary for the performance of a contract.  You are subject to a contract with us and we need to use your personal information to provide Content and Services.

  • To Secure the Website.
  • As Required by Law.

Processing is necessary to comply with our legal obligations.

  • To Improve Our Content and Services.
  • To Understand Your Interests.
  • To Market Content or Services.
  • To Secure the Website.
  • To Use Personal Information as Otherwise Described in this Privacy Policy.

Processing activities constitute our legitimate interests.  We consider and balance the potential impact on your rights before we process your personal information for our legitimate interests.  We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent, or we are otherwise required to perform a contract or by law).

We will use your personal information only for the purposes for which we collected it, unless we reasonably determine we need to use it for another reason and that reason is compatible with the original purpose.  For example, we consider deidentification, aggregation, and anonymization of personal information to be compatible with the purposes listed above and in your interest, because the deidentification, aggregation, and anonymization of such information reduces the likelihood of improper disclosure of that information.



HowGood retains your personal information:

  • For so long as your account is active or as needed to provide you with the Website or to fulfill our contractual obligations;
  • As necessary to comply with our legal obligations, resolve disputes, and enforce our agreements; and
  • For so long as is necessary for the purposes for which we collected such personal information.

Your Rights

European data protection laws give you certain rights regarding your personal information. 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.
  • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
  • Correct. Update or correct inaccuracies in your personal information.
  • Restrict. Restrict the processing of your personal information.
  • Object. Object to our reliance on our lawful basis as the basis of our processing of your personal information that impacts your rights.
  • Delete. Delete your personal information.

When we receive your request, we may ask you to verify your identity before we can act on your request. We may withhold information where we are required by law to do so or if the search for that information would require disproportionate effort or have a disproportionate effect to, for example, the cost of providing the information, the time it would take to retrieve the data, or how difficult it may be to obtain the information requested.

If you are a resident of the EEA and would like to exercise any of these rights, please submit your request as described in the section titled “CONTACTING US” below.  If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection authority in your jurisdiction.  You can find your data protection regulator here.


Other Sites and Services


The Website may contain links to other websites and online services operated by third parties.  These links are not an endorsement of, or representation that we are affiliated with, any third party.  In addition, our content may be included on web pages or online services that are not associated with us.  We do not control third party websites or online services, and we are not responsible for their actions.  Other websites and services follow different rules regarding the collection, use, and sharing of your personal information.  We encourage you to read the privacy policies of the other websites and online services you use.


Contacting Us


If you have any questions or concerns about our Privacy Policy or any other privacy or security issue, please contact us at: [email protected]


Effective Date: January 2021