Privacy Policy

This Privacy Policy describes how Town.com, Inc. (“Town”, “we”, “us”, or “our”) processes personal information that we collect through our digital and online properties or services that link to this Privacy Policy (including as applicable, our website, AI assistants and other AI agentic services, web application, member platform, mobile app, electronic communications, and social media pages) as well as our marketing activities and other activities described in this Privacy Policy (collectively, the “Service”).

This Privacy Policy does not apply to information that we process on behalf of our business customers while providing services to them. Our use of information that we process on behalf of our business customers is governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of our business customer, please direct your concerns to the business customer with which you have a relationship.

This Privacy Policy does not apply to our employees or independent contractors or job candidates.

1. Personal information we collect

Information you provide to us

Personal information you may provide to us includes:

• Contact data, such as your first and last name, alias, signature, salutation, email address, billing and mailing addresses, and phone number.
• Demographic data, such as your city, state, country of residence, postal code.
• Profile data, such as account name, the username and password that you may set to establish an online account on the Service, biographical details, job title, avatar, photograph or picture, date of birth, interests, preferences, links to your profiles on social media networks, and any other information that you add to your account profile.
• Payment data needed to complete transactions, including payment card information or bank account number. We use third-party vendors to directly collect and process your payment card information, such as Stripe, as described further below.
• Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via email, phone, chat features, social media, or otherwise.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• User provided data, such as emails, messages, postings, updates, and other communications, documents or data that users provide to, connect with, scan, or otherwise leverage or cause to interact with the Service. When you connect your email account(s) to the Service, this may include message content (such as body text, subject lines, and attachments), sender and recipient information (such as names and email addresses), email metadata (such as dates, timestamps, and threading information), and other data contained within your email communications. Third-party service accounts may be connected to the Service via authentication protocols such as OAuth or similar mechanisms provided by your email service provider. To the extent you connect accounts of your employer (e.g., employer-provided email accounts or other employer-provided accounts), you confirm that you have appropriate authorization to do so.
• 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.
• Data about others. We may offer features that help users invite their contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. In addition, when you connect your third-party service account (e.g., email account) to the Service or otherwise provide communications data to the Service, we may process personal information of third parties contained in those communications, such as the names, email addresses, and other information of individuals with whom you correspond. We process such third-party personal information solely to provide and improve the Service as described in this Privacy Policy. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

Third-party sources

We may combine personal information we receive from you with personal information of the kinds identified above that we obtain from other sources, such as:

• Public sources, such as credit bureaus, government agencies, public records, publicly accessible social media profiles, and other publicly available sources.
• Data providers, such as information services, data licensors/brokers, lead generators and cooperative databases.
• Service providers that provide services on our behalf or help us operate the Service or our business.
• Partners, such as joint marketing partners and event co-sponsors.
• Ad networks
• Data analytics providers
• Social media platforms
• Third-party service providers, such as if you connect your instant message, email, other communications, or other third-party service account to the Service (e.g., Gmail, Microsoft Outlook, Microsoft Teams, Yahoo Mail, GitHub, Slack, Linear, Notion, Granola, or other supported providers), we may receive personal information from those providers in accordance with the permissions you grant and the applicable provider’s terms of service and privacy policy.

Automatic data collection

We and our service providers 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.
• Location data, which may be approximate (for example, as inferred from network data or device settings).
• Communication interaction data such as your interactions with our email, text, chat 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 clear GIFs), which may be embedded invisibly in our emails enabling us to detect if you have opened or forwarded a message.
• Online activity data, such as pages or screens you viewed, search history, how long you spent on a page or screen, the website you visited before browsing to the Service, 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.

Tracking 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, credentials, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a web browser session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our service providers and other third parties 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, clicked or forwarded.
• Chat technologies, such as those provided by third parties that employ cookies and software code to operate the chat features that you can use to communicate with us through the Service. These third parties may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats to respond to your questions and for the purposes described in this Privacy Policy.
• Session-replay technologies, such as those provided by third parties that employ software code to record users’ interactions with the Service in a manner that allows us to watch video replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements and scrolls during those sessions. These replays help us diagnose usability problems and identify areas for improvement.

2. How we use your personal information

Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements, specifically (i) Google user data is accessed and used ONLY to provide or improve the Services directly to you (ii) we do NOT use Google user data to train machine learning models; (iii) we do NOT use Google user data to serve advertisements; (iv) we do NOT share Google user data with third parties except as necessary to provide the services you requested, for security purposes (e.g., detecting abuse), to comply with applicable law, or with your explicit consent; and (v) we do NOT allow humans to read the data unless we obtain your affirmative agreement to view specific messages, files, or other data, it is necessary of security purposes or to comply with law, or the data is aggregated and used for internal operations. For other use of your personal information we may use your personal information for the following purposes or as otherwise described at the time of collection; provided that, in all cases, we will not use any Google user data in any manner inconsistent with the Google API Services User Data Policy, and the uses described below exclude any Google user data except as expressly permitted above.

Service delivery and operations

We may use your personal information to:

• provide and operate the Service (including to scan, analyze, and process your communications using artificial intelligence and machine learning technologies in order to understand context, identify relevant information, and generate suggested draft responses or other outputs on your behalf);
• process your requests;
• facilitate the connection of your third-party service account(s) to the Service and access third-party service content in accordance with the permissions you grant;
• enable security features of the Service;
• personalize the Service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
• establish and maintain your user profile on the Service;
• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, user-to-user communications, and support and administrative messages;
• understand your needs and interests, and personalize your experience with the Service and our communications;
• provide support for the Service;
• respond to your requests, questions and feedback;
• analyze usage;
• improve the Service;
• facilitate your invitations to friends you invite to join the Service;
• to collect and share user testimonials; and
• fraud prevention and security.

Research and development

We may use your personal information for research and development purposes, as well as to create anonymized, de-identified, or synthetic data to develop, analyze and improve our products and services, including to train our AI models, to the extent permitted by and consistent with this Privacy Policy and applicable requirements for access to third-party APIs. For example, our use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements, as described above. Personal information, including communications content processed through the Service, may also be provided to third-party AI providers to facilitate the delivery of the Service; however, we contractually require such providers not to use your personal information to train their own AI models except as necessary to provide services to us. As part of these activities, we may also create aggregated, de-identified or other anonymous data from personal information. We may use this anonymous or de-identified data and share it with third parties for any lawful business purposes. We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.

Marketing and advertising

We 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 in the Your choices section.
• Interest-based advertising. We and our third-party advertising partners may use cookies, pixels and other 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 third-party 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 properties. Where applicable law requires opt-in consent for these technologies (including in the European Economic Area, the United Kingdom, and Switzerland, and the other jurisdictions where we apply an opt-in default), we use them only with your prior consent, which we collect through our cookie banner and which you can withdraw at any time via the “Cookie settings” control. For visitors in the United States, these technologies operate on an opt-out basis under applicable state privacy laws — see the “Your U.S. state privacy rights” subsection in the Your choices section. You can learn more about your choices for limiting interest-based advertising in that section and in our Cookie Policy.

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, court orders, 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 for further purposes, if those purposes are not compatible with the initial purpose for which that personal information was collected. By connecting your third-party service account to the Service and enabling our AI features, you expressly consent to our access, collection, and processing of your third-party service account data, including communications, such as the content of messages sent and received, for the purposes described in this Privacy Policy, and confirm that you have all rights and permissions to permission our access, collection, and processing of your third-party service account data. You may withdraw your consent at any time by deleting your account or, as to each third-party service account, by disconnecting those third party service accounts from the Service. Any information you have used the Service to create will be removed from the Service within 30 days, subject to the subsection in the Your Choices section below titled “Retention Period for Personal Information.”

Cookies and similar technologies

In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

• Technical operation. To allow the technical operation of the Service, such as remembering selections as you navigate the site and remembering whether you are logged in.
• Functionality. To enhance the performance and functionality of the Service.
• Analytics. To help us understand user activity on the Service, including the volume and demographics of users, which pages are most and least visited and how users move around the Service or interact with our emails. On our public websites, analytics cookies and similar technologies run only where permitted — in regions where consent is required, only after you grant the Analytics category in our cookie banner (see our Cookie Policy). Separately, while you are signed in, we process product-usage analytics on the basis of our legitimate interest in operating and improving the Service; the cookie settings govern cookies and similar tracking technologies, not this in-app analytics, and you may object to processing based on legitimate interests as described in the Your rights section below.
• Data sharing in the context of corporate transactions, we may share certain personal information in the context of actual or prospective corporate transactions – for more information, see How we share your personal information, below.

3. How we share your personal information

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

• Affiliates. In some cases, our corporate parent, subsidiaries, and affiliates might have access to personal information.
• Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, internet service providers, information technology, order fulfillment, customer support, online chat functionality providers, email delivery, marketing, consumer research and website/data analytics).
• Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. The payment processor may use your payment data in accordance with its privacy policy. For example, Stripe’s privacy policy is available at https://stripe.com/privacy.
• Artificial intelligence platforms. We use third-party artificial intelligence (AI) providers to power certain aspects of the Service, including the analysis of your communications on those third-party services that you have connected to the Service and the generation of draft communications. In connection with providing these features, communications content and related personal information may be transmitted to and processed by such third-party AI providers. We contractually require these providers to process your personal information only as necessary to provide services to us and not to retain your personal information beyond what is necessary to deliver the applicable service.
• Advertising partners / ad networks. Third-party advertising companies for the interest-based advertising purposes described above.
• Social networks. We use their ad services to display ads to our customers, or other people like them, on social media.
• Third parties designated by you. We may share your personal information with other third parties where you have instructed us or provided your consent to do so.
• Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account on the third-party service.
• 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 in litigation, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
• Corporate transactions. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments, financings, public stock offerings, the sale, transfer or merger of all or part of our business, assets or shares, liquidation or reorganization). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may disclose your personal information to an acquirer, successor, or assignee or a portion of our business assets 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 choices available to you.

Access or update your information and choices

If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account and navigating to your account profile and settings. You may withdraw your consent at any time by deleting your account or otherwise disconnecting your third-party service account from the Service by logging into the account and navigating to your account profile and settings.

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. It may take time for your opt-out to be effective. 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. You may opt-out of text messages by texting “STOP” in response to a text that you receive or by other reasonable means.

Cookies

You can manage the non-essential cookies and similar technologies we use at any time via the “Cookie settings” control available on every public page of our websites and, when you are signed in, from your in-app settings (for visitors in the United States, this control is labeled “Do Not Sell or Share My Personal Information”). For details of the cookies we use, their purposes and durations, and how our cookie banner and consent choices work, see our Cookie Policy. In addition, most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit https://www.allaboutcookies.org.

Blocking images / clear gifs

Most browsers and devices allow you to configure your device to prevent images from loading, so the business hosting the image will not detect that you have viewed a page. To do this, follow the instructions in your particular browser or device settings.

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. We do, however, honor Global Privacy Control (GPC) signals as described in the “Your U.S. state privacy rights” subsection below. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.

Your U.S. state privacy rights

If you are a resident of California or another U.S. state with a comprehensive privacy law, our use of third-party advertising cookies and pixels for interest-based advertising, as described in this Privacy Policy, may constitute a “sale” of personal information or “sharing” of personal information for cross-context behavioral advertising, as those terms are defined under applicable state law. The categories of personal information involved are the Device data and Online activity data described above. We do not knowingly sell or share the personal information of individuals under 18 years of age, and we do not use or disclose sensitive personal information for purposes that require a right to limit under applicable law.

You have the right to opt out of the sale or sharing of your personal information. You can do so at any time via the “Do Not Sell or Share My Personal Information” link available on every public page of our websites and, when you are signed in, from your in-app settings. We also honor the Global Privacy Control (GPC) browser signal as a valid universal opt-out: if your browser or extension sends a GPC signal, we treat it as a request to opt out of sale/sharing and do not load the relevant advertising technologies. Once you opt out, we honor your choice for at least 12 months before ever asking you to opt back in. You will not be discriminated against for exercising these rights. For more detail, see our Cookie Policy. State law may also provide you rights to access, correct, or delete your personal information — you can exercise these as described in the Your rights section or by contacting us.

Training data

As set out in the How We Use Personal Information section, we may use your personal information to train our AI models and for other machine learning purposes. You may opt-out of our use of your personal information for AI training purposes by using the toggle feature provided in your account settings. For users under an Organization license (as provided in the Terms of Service), if the Organization’s setting has opted-out of training, this will supersede individual user settings for that Organization.

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.

Retention Period for Personal Information

We generally retain personal information to fulfill 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, for fraud prevention purposes, or otherwise in line with our agreements with you. To determine the appropriate retention period for personal information, including Sensitive Personal Information, we may consider factors such as the length of time we have an ongoing relationship with you and provide services to you; 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; whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations; and applicable legal requirements. For example, we will retain your personal information for as long as you have an account with us or keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise. When we no longer require the personal information we have collected about you, we may either delete it or de-identify it.

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 may be integrated into web pages or other online services that are not associated with us. The Service also enables you to connect third-party service accounts (such as those provided by Google, Microsoft, Yahoo, or other service providers) to facilitate the Service’s AI-powered features. Your use of such third-party services remains subject to the applicable provider’s terms of service and privacy policy, and we encourage you to review those terms. 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. Security

We employ technical, organizational and physical safeguards that are designed to protect the personal information we collect. However, security risk is inherent in all Internet and information technologies, and we cannot guarantee the security of your personal information.

7. International data transfers

We are headquartered in the United States and may use service providers that operate in other countries. 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 outside of the United States should read the information provided below about the transfer of personal information.

8. Children and Teens

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a minor from whom you believe we have collected personal information in a manner prohibited by law, or if information was provided on your behalf when you were under 18, 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.

9. Changes to this Privacy Policy

The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. We reserve the right to modify this Privacy Policy at any time. We will notify you by updating the “Last updated” date. Depending on the kind of change we make, we may also notify you directly or ask for your consent to the change. Any modifications to this Privacy Policy will be effective upon our posting the modified version or as otherwise indicated at the time of posting.

10. How to contact us

• Email: info@corp.town.com
• Website: town.com

11. Notice to users outside of the United States

General

Where this Notice to users outside of the United States applies. The information provided in this “Notice to users outside of the United States” section applies only to individuals located outside of the United States, including those in the United Kingdom and the European Economic Area (“Europe”).

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” or other appropriate term under the local data protection (e.g., the GDPR).

Controller. Town.com, Inc. is the controller in respect of the processing of your personal information covered by this Privacy Policy. See the ‘How to contact us’ section above for our contact details.

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, to the extent applicable data protection law in your jurisdictions requires us to ensure that we have a “legal basis” for that use, we provide the information on legal basis in this section.

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, in a table format, 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’

Other info

No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, information related to sex life or sexual orientation, trade union membership, or information pertaining to criminal convictions) 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 the Service.

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

Your rights

General. Applicable data protection laws may provide you certain rights regarding your personal information. These rights may include:

• 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 good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
• Object. Object to our processing of your personal information where we are relying on Legitimate Interests – 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. For cookies and similar technologies, you can withdraw consent in one click via the “Cookie settings” control available on every public page of our websites and, when you are signed in, from your in-app settings — see our Cookie Policy for details.

Exercising These Rights. You may submit these requests by contacting us as 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: 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/

Data Processing outside your country

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 the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside of your home country.