1. Introduction

This Global Privacy Policy (“Privacy Policy”) describes how Januus LLC. and its affiliates will gather, use, and maintain your Personal Information on the Januus Platform. It will also explain your legal rights with respect to that information.

By using the Januus Platform, you confirm that you have read and understand this Privacy Policy, and our Global Terms of Service (together referred to herein as the “Agreement”). The Agreement governs the use of the Januus Platform. Januus will collect, use, and maintain information consistent with the Agreement.

If you are a California resident, please see the “Additional Disclosures for California Residents”. If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section below.

2. General Terms

In this Privacy Policy:

• Januus, Inc. may be referred to as “Januus,” “we,” “our,” or “us.”

• We call a user of the Januus Platform “User,” “Users,” “you,” “your,” or “Client” and “Provider,” as appropriate.

• The community platform that we offer at our website (www.januus.com) and local variants referred to as the “Site(s).”

• The mobile applications (whether on iOS or Android) are referred to as the “Apps.”

• Januus 's Sites, Apps and related services, information and communications are collectively referred to as the “Januus Platform.”

• “Terms of Service” refers to our Global Terms of Service, which can be found here. This Privacy Policy is incorporated into, and considered a part of, the Terms of Service.

3. Information Collection

Information you provide to Januus

Januus collects certain personally identifiable information about you, including information that can identify, relate to, describe, be associated with you, or is reasonably capable of being associated with you (“Personal Information”). Examples of Personal Information that Januus collects include but are not limited to:

Contact Information. This may include your first and last name, postal address, telephone number, and email address.

Billing Data, including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments.

Identity Information. If you are a Tasker, we may collect Personal Information, such as your date of birth and address, national identification number if applicable, together with the result of basic criminal record checks as provided by you, or by our Third-Party Agents (as defined below), as applicable and to the extent permitted by law in your jurisdiction, as well as such information as may be needed to validate your identity.

Financial Information. To help Taskers set up a payment account and help Clients make payments to Taskers and pay fees to Januus, we may collect financial information, including credit card number, bank routing numbers, tax information, taxpayer identification number, and other payment information, as applicable. We use Financial Information in order to operate the Januus Platform and to ensure that Taskers are paid by Clients. We do this as necessary for our legitimate interests in providing our platform and services and to fulfill our contracts with Users. To keep your financial data secure, we have contracted with a third party to maintain and process your payment information.

Promotional Information. Certain offerings of the Januus Platform, such as newsletters, surveys, contests, and the like are optional and so you are not required to enter them or to give us your data in connection with them. Where you do consent to take advantage of Januus Platform offerings, we will use your data to (as applicable) send you newsletters and other communications that are tailored based on information we have about you, or to operate and manage the survey, contest or similar offering in connection with our legitimate interest in promoting our business and the Januus Platform. To opt-out of receiving marketing communications from us, please see Section 7, Your Rights and Choices.

Employment Information. We collect employment and education history, transcripts, writing samples, and references as necessary to consider your job application for open positions.

Content Information. You also may choose to send Januus Personal Information in an email or chat message containing inquiries about the Januus Platform and we use this Information in order to help us respond to your inquiry. We also collect content within any messages you exchange with other Users through the Januus Platform (such as through our chat functionality).

We require that you furnish certain information when you register an account with us in order to provide services through the Januus Platform. For example, if you are a Client, we collect your first and last name, email address, and your zip or postal code in order to create and administer your Januus account. We also collect additional information in order to facilitate your booking request, such as information about the task you are seeking, the time, date and location of the task, and Billing Data. If you are a Tasker, we collect your first and last name, email address, mobile phone number and zip or postal code in order to create and administer your Januus account and facilitate communications between you and your Clients through the Januus Platform. We also collect information about your tasks, rates, and skills, as well as Identity Information and Financial Information.

Third Party Information. If you registered through a co-branded version of our Januus Platform through one of our Partners (as defined below) or IKEA, they may provide us with basic information such as your name, address, email, and purchase history related to your Task needs. We may receive additional information about you, such as demographic data, Financial Information, or fraud detection information, from Third-Party Agents (as defined below) and combine it with other information that we have about you, to the extent permitted by law, in order to comply with our legal obligations and for the legitimate interest in improving the Januus Platform. Januus may work with Third-Party Agents to perform identity checks and criminal background checks on Taskers, if applicable and permitted by local law, in order to advance our legitimate interests in ensuring the safety of our Users and maintaining the integrity of the Januus Platform.

4. Information Januus Collects Automatically

We automatically collect certain information when you use the Januus Platform. The categories of information we automatically collect and have collected, including in the last 12 months, are as follows:

Service Use Data, including data about features you use, pages you visit, emails and advertisements you view, portions of the Januus Platform that you view and interact with, the time of day you browse, and your referring and exiting pages.

Device Data, including data about the type of device or browser you use, your device's operating system, your internet service provider, your device's regional and language settings, and device identifiers such as IP address and Ad Id. When you visit and interact with the Januus Platform, Januus may collect certain information automatically through cookies or other technologies, including, but not limited to, the type of computer or mobile device you use, your mobile device’s unique device ID, the IP address of your computer or mobile device, your operating system, the type(s) of internet browser(s) you use, and information about the way you use the Januus Platform (“Device Information”). We may use Device Information to monitor the geographic regions from which Users navigate the Januus Platform, and for security and fraud prevention purposes. Use of any IP-masking technologies or similar technologies (like the TOR network) may render portions of the Januus Platform unavailable and are forbidden on the Januus Platform.

Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level), and, with your consent, precise location data (such as latitude/longitude data). When you visit the Januus Platform via a native mobile application, we use, with your consent when required under applicable law, GPS technology (or other similar technology) to determine your current location in order to determine the city you are located in and display a relevant location map. We will not share your current location obtained in this manner with other Users.

Cookies and similar technologies are described in our Cookie Policy, which sets out the different categories of cookies and similar technologies that the Januus Platform uses and why we use them.

5. Januus's Use of Information

We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information include:

• To operate and make available the Januus Platform. We use your data to connect you with other Users to enable the posting of, selection for, completion of, and payment for Tasks, in order to fulfill our contracts with Users;

• For billing and fraud prevention, on the basis of our legitimate interests in ensuring a safe and secure environment in which Clients and Taskers can meet and conduct business, and in order to comply with our legal obligations;

• To conduct identification and criminal background checks, if applicable and to the extent permitted by local law, on Users, in order to advance our legitimate interests as well as for the substantial public interest of ensuring the safety of our Users both online and offline, preventing or detecting unlawful acts, protecting the public against dishonesty, and maintaining the integrity of the Januus Platform given that Taskers often interact directly with Clients and may enter their homes;

• To analyze Januus Platform usage as necessary for our legitimate interest in improving the Januus Platform to grow our business;

• To contact you and deliver (via email, SMS, push notifications, or otherwise) transactional information, administrative notices, marketing notifications, offers and communications relevant to your use of the Januus Platform, with your consent when required under applicable law, as necessary for our legitimate interests in proper communication and engagement with our Users, and in promoting our business;

• To provide you with customer support in order to fulfill our contracts with Users;

• For internal market research for our legitimate interest in improving the Januus Platform to grow our business;

• For troubleshooting problems for our legitimate interests in ensuring a safe and secure environment in which Users can meet;

• To assist Users in the resolution of complaints and disputes between them, as necessary for our legitimate interests in facilitating good relations among Users;

• To enforce our Terms of Service and our legitimate interests in ensuring our Agreement is complied with; and

• As otherwise set forth in the Agreement.

Interest-Based Advertising. Ads are a standard part of user experience on the Internet, and Januus believes that targeted advertising enhances this experience. Januus and affiliate third parties may use cookies and other technologies to place ads where they believe interested Users will see them. In addition to banner ads, Januus may advertise products, companies and events that we think might interest you through the email address and/or phone number you provide. We may incorporate Tracking Technologies on the Januus Platform (including our website and emails) as well as into our ads displayed on other websites and services. Some of these Tracking Technologies may track your activities across time and services for purposes of associating the different devices you use and delivering relevant ads and/or other content to you (“Interest-Based Advertising”).

For more information and to understand your choices regarding third-party ads, please see our Cookie Policy. Advertising and marketing is carried out as necessary for our legitimate interests in providing an engaging and relevant experience, promoting our services, and growing our business.

Analytics and Market Analysis. Januus may analyze information (“Market Analysis”) as necessary for our legitimate interests in providing an engaging and relevant experience, and promoting and growing the Januus Platform.

Januus uses information to offer services to Users who express an interest in these services, through a poll for example, or to Users who can be presumed to have an interest based on results from our Market Analysis. We do this as necessary for our legitimate interests in providing an engaging and relevant experience, promoting our services, and growing our business.

Cell Phone Numbers. Januus may use your cell phone number to call or send recurring text messages to you, using an auto dialer or prerecorded voice, in order to provide you notifications about Tasks, for marketing purposes (with your consent where required by law), and to administer the Januus Platform. If you would like more information about our policy, or how to opt-out, please review the “Your Rights and Choices” section below or Section 9 of our Terms of Service. You may be liable for standard SMS and per-minute charges by your mobile carrier. Januus may also message you via push notifications (with your consent when required under applicable law), which you can opt-out of on your mobile device. Data rates may apply.

Call recordings. Calls to or from Januus or its Third Party Agents may be monitored and recorded for the purposes of quality control and training. Such calls may contain Personal Information.

6. Information Sharing

We only share the Information we collect about you as described in this Privacy Policy or as described at the time of collection or sharing, including as follows:

Third Party Agents. We share information, including Identity Information, with entities that process information on our behalf for our business purposes. We contractually prohibit our Third-Party Agents from retaining, using, or disclosing information about you for any purposes other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.

To operate the Januus Platform, including processing your transactions, we may share your Personal Information with our agents, representatives, vendors and service providers (“Third Party Agents”) so they can provide us with support services as follows:

• Email origination;

• Identity checks

• Fraud prevention and detection

• Receipt, invoice, or support services;

• Customer relationship management services;

• Data analytics;

• Marketing and advertising;

• Website hosting;

• Communications services;

• Technical support;

• Financial transaction fulfillment (in which we are currently supported by Stripe, who processes your Personal Information in accordance with its own privacy policy) and related chargeback and collection services; and

• To otherwise help us provide the Januus Platform.

Partners. Some Januus content is “sponsored by” or “presented by” other companies. If you connect to the Januus Platform through a co-branded version of our Januus Platform or otherwise participate in one of our partner programs, we may share information about your use of the Januus Platform with that Partner in order to offer the integrated platform and to evaluate the partner program. We may also share your Personal Information with our Partners in order to receive additional information about you, or in order to create offers that may be of interest to you. Please check such Partner's privacy policy before revealing information about yourself. If you don't want these Partners to have your Personal Information, you can choose to not participate.

Promotions. When you voluntarily enter a sweepstakes, contest, or other promotion, we share information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners' list). By entering a promotion, you agree to the official rules that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice, and/or likeness in advertising or marketing materials. We may occasionally contact you, if you want us to, with information about special events, activities, promotions, contects, submission opportunities, and programs. You always have the ability, in your Account, to ask Januus not to contact you with this type of information. Please see Section 7, Your Rights and Choices, for more information.

Matched Ads. We use Matched Ads by sharing personal information with another party or incorporating a pixel from another party into our own Sites, and the other party matching common factors between our data and their data or other datasets for advertising purposes. For instance, we incorporate the Facebook pixel on our Sites and may share your email address with Facebook as part of our use of Facebook Custom Audiences.

Other Users. Januus facilitates contact between Clients and Taskers and reserves the right to share one User's contact information (e.g., name, phone number, email, or postal address) with other Users, or with the recipient User's legal or other authorized representative, in order to: (1) facilitate or communicate the resolution of an investigation or dispute related to or arising from an interaction between two or more Users of the Januus Platform; or (2) facilitate the performance of a Task. This exchange of information is essential to the operation of the Januus Platform.

Legal Obligations. Januus and our Third Party Agents may disclose your Personal Information or User Generated Content to courts, law enforcement, governmental or public authorities, tax authorities or authorised third parties, if and to the extent required or permitted to do so by law or where disclosure is reasonably necessary to: (i) comply with Januus's legal or regulatory obligations; (ii) respond to a court order, warrant or subpoena; (iii) respond to a valid legal request relating to an investigation into alleged criminal or illegal activity; or (iv) respond to or address any other activity that may expose us to legal or regulatory liability.

In jurisdictions where Januus is, according to applicable law, required to collect or remit information about Users' permits, licenses, tax, or social security registrations, Januus and our Third Party Agents may disclose information, including but not limited to, User contact details, identification information, transaction dates and amounts, license and permit status, and tax identification number(s) to applicable governmental authorities.

Januus reserves the right to disclose Personal Information from both private and public areas of the Januus Platform in the absence of a court order, warrant, or subpoena, to the extent permitted by applicable law, if we are given reason to believe, in our sole discretion, that someone is causing injury to or interfering with the rights of Users, the general public, or Januus or its partners, parents or affiliates.

It is our policy to provide notice to Users before producing their information in response to law enforcement requests unless (i) we are prohibited or otherwise constrained by law or court order from doing so, (ii) we have reason to believe the User's account has been compromised such that the notice would go to the wrong person, or notice would otherwise be counterproductive or would create a risk to safety, or (iii) it is an emergency request and prior notice would be impractical (in which case we may provide notice after the fact).

Merger or Acquisition. Januus reserves the right to share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale, or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.

Public Areas. Your profile on the Januus Platform consists of information about you and your business, and may include information such as photographs, your years in business, skills and expertise, hourly pay rates, feedback/rating information, and other information, including your username (“Profile”). The information in your User Profile may be visible to all Users and the general public. If you choose to post a Task via the Januus Platform, the contents of such listing will be viewable to Taskers you select on the Januus Platform.

7. Your Rights and Choices

You may opt-out of receiving promotional communications from us, including promotional communications related to the Januus Platform, and request the removal of your Personal Information from our databases, or deactivate your account, by logging on to the Site or App and clicking on the “Account” tab, or by contacting us.

Account Settings. During registration you choose whether to receive marketing correspondence from Januus. This information remains on your Profile where you can, at any point, easily edit it. After logging on, click on the “Account” tab, then select “Notifications” to make your preferred selections.

Push Notifications. You have the option to receive updates and relevant offers via push notifications in your app. These notifications can be configured in the settings of your mobile device at any time.

Corrections to Profile. You have the right to access, update, and correct inaccuracies in your Januus Profile at any time by logging in and clicking on the “Account” tab. There, you can view, update, and correct your Account information.

So that we may protect the integrity of the Januus Platform, there are certain pieces of information, such as your age, that you cannot alter yourself. For example, since children under the age of majority in their jurisdiction of residence are not allowed to register as Users, we need to take reasonable measures to preserve the accuracy of our Users' ages. You may contact us at privacy@Januus.com if there is a need to make a correction to such data. Please see Section 11, Children’s Privacy, for more details.

Promotional Communications. You can opt out of receiving promotional communications from Januus via the Account tab in your Profile. In addition, you can opt out of email marketing by clicking on the unsubscribe link in any message. You can opt out of promotional communications from Januus sent via text message at any time by following the instructions provided in those messages to text the word “STOP”. Please note that your opt-out is limited to the phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt-out of receiving promotional communications, Januus will continue to send you non-promotional communications, such as those about your account, Tasks, transactions, servicing, or Januus's ongoing business relationship with you. If you receive unsolicited promotional communications from a Januus domain, please let us know here.

If you are a California Resident, please see the Additional Disclosures for California Residents section below.

8. Januus's Information Retention Policy

We retain personal data for as long as you are a User in order to meet our contractual obligations to you, and for such longer period as may be in our legitimate interests and to comply with our legal obligations (see Exhibit A for exemplar document retention periods). We may also retain data from which you cannot directly be identified, for example where stored against a randomly-generated identifier so we know the data relates to a single User, but we cannot tell who that User is. We use this kind of data for research purposes and to help us develop and improve our services, and we take appropriate measures to ensure you cannot be re-identified from this data.

9. Januus's Security of Collected Information

Your Januus account is password-protected so that only you and authorized Januus staff have access to your account information. In order to maintain this protection, do not give your password to anyone. Also, if you share a computer, you should sign out of your Januus account and close the browser window before someone else logs on. This will help protect your information entered on public terminals from disclosure to third parties.

Januus implements and maintains reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Januus has staff dedicated to maintaining this Privacy Policy and other privacy initiatives, periodically reviewing security, and making sure that every Januus employee is aware of our security practices. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

10. Notification of Changes

Januus's Privacy Policy is periodically reviewed and enhanced as necessary. This Privacy Policy might change as Januus updates and expands the Januus Platform. Januus will endeavor to notify you of any material changes by email. Januus also encourages you to review this Privacy Policy periodically.

11. Children's Privacy

This service is intended for a general audience, and is not directed at children under 13 years of age. In certain jurisdictions, this minimum age may be higher. Please check the Jurisdiction-specific Provisions below for more information.

We do not knowingly gather personal information (as defined by the U.S. Children's Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. If you are a parent or guardian and you believe that we have collected information from your child in a manner not permitted by law, please let us know by contacting us here. We will remove the data.

12. Contacting Us

If you have any questions about this Privacy Policy or the manner in which we or our Third-Party Agents treat your Personal Information, the practices of the Site, your dealings with the Januus Platform, or if you have technical problems, you may contact us here.

Januus's staff will respond to all mail or email from Users with questions about privacy, including the types of Personal Information stored on the Januus databases, and requests to know, delete or rectify such Personal Information.

13. Jurisdiction-specific Provisions

A. Residents of the United States of America Information of U.S. Users. Our collection, use, and retention of the Personal Information of U.S. Users is in accordance with applicable U.S. laws, as is our determination of what is deemed to be “personal data and/or information.”

Januus expressly disclaims any liability that may arise should any other individuals obtain the information you submit to the Januus Platform.

Interest-Based Advertising in the United States. For more information about interest-based ads, or to opt out of having your web-browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.

Januus's Security of Collected Information. While Januus will use commercially reasonable efforts to ensure the security of all Personal Information, we expressly disclaim any liability for any unauthorized access to or use of our secure servers and/or any and all Personal Information stored therein, and you agree to hold Januus harmless for any damages that may result therefrom. If you have any further questions on this issue, please refer to the Terms of Service.

Additional Disclosures for California Residents These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires business collecting or disclosing Personal Information to provide notice of rights California residents have and can exercise.

California Notice of Collection. We have collected Personal Information corresponding to the following categories enumerated in the CCPA, including within the last 12 months.

• Identifiers, including name, address, email address, account name, Social Security Number, IP address - and an ID number assigned to your account.

• Customer records, phone number, billing address, credit or debit card information, employment or education information.

• Demographic information, such as your age or gender. This category includes pieces of Personal Information that also qualify as protected classification characteristics under other pre-existing California or federal laws.

• Analytics and Advertising, including purchases and engagement with the Januus Platform.

• Internet activity, including history of visiting and interacting with our Service, browser type, browser language and other information collected automatically.

• Geolocation data, including location enabled services such as WiFi and GPS.

• Inferences, including information about your interests and preferences.

For more information on what we collect, including the sources we receive information from, review Section 3, Information Collection. We collect and use these categories of personal information for the business purposes described in Section 5, Januus's Use of Information, including to provide and manage the Januus Platform.

Januus does not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those disclosed in Section 5, Januus’s Use of Information, as a “sale,” we will comply with applicable law as to such activity.

Januus discloses the following categories of information for commercial purposes:

• Commercial Information;

• Demographic Data;

• Location Data;

• Identifiers;

• Inferences; and

• Internet activity.

We use and partner with different types of entities to assist with our daily operations and manage the Januus Platform. Please review Section 6, Information Sharing, for more detail about the parties with which we share Personal Information.

Right to Know and Delete. If you are a California resident, you have the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

• The categories of Personal Information we have collected about you;

• The categories of sources from which the Personal Information was collected;

• The categories of Personal Information about you we disclosed for a business purpose or sold;

• The categories of third parties to whom the Personal Information was disclosed for a business purpose or sold;

• The business or commercial purpose for collecting or selling the Personal Information; and

• The specific pieces of Personal Information we have collected about you

In addition, you have the right to delete the Personal Information we have collected from you. However, this is not an absolute right and Januus may have legal grounds for keeping such data.

To exercise any of these rights, please submit a request at privacy@Januus.com or here. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

Right to Opt-Out. To the extent Januus sells your Personal Information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your Personal Information by us to third parties at any time. You may request to opt-out by clicking Do Not Sell My Personal Information and making your choice.

Authorized Agent. You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

Right to Non-Discrimination. You have the right to non-discriminatory treatment by us, should you exercise any of your rights.

Shine the Light. Customers who are residents of California may request: a list of the categories of Personal Information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes, and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please contact us at policies@Januus.com. Requests must include “California Shine the Light Request” in the first line of the description and include your name, street address, city, state, and ZIP code. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year. Please note that Januus is not required to respond to requests made by means other than through the provided email address or mail address.

EU-US Privacy Shield Januus is aware of the Schrems II judgment which invalidated the Privacy Shield as a matter of EU law. Januus has decided, however, to maintain its certification not to legitimise the transfer of personal data under EU law, but as a matter of US law and good practice.

Januus complies with the EU-U.S. Privacy Shield Framework (Privacy Shield) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union and the United Kingdom, as applicable to the United States in reliance on Privacy Shield. Januus has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, Januus commits to resolve complaints about our collection or use of your Personal Information. Individuals with inquiries or complaints regarding our handling of your Personal Information under the Privacy Shield should first contact Januus here.

If we do not acknowledge your Privacy Shield complaint in a timely manner, or if your complaint is unresolved, please contact JAMS, our U.S.-based third-party dispute resolution provider (free of charge) at https://www.jamsadr.com/eu-us-privacy-shield to file a complaint. If neither Januus nor JAMS resolves your complaint, you may, under certain circumstances, pursue binding arbitration under the Privacy Shield Panel. Additional information about binding arbitration can be found here.

As explained in this Privacy Policy, Januus may provide Personal Information to third parties to perform services on our behalf. If we transfer Personal Information received under the Privacy Shield to a third party, the third party's access, use and disclosure of your Personal Information must also be in compliance with our Privacy Shield obligations, and Januus recognizes potential liability under the Privacy Shield for failure to do so by the third party. Januus is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).