Privacy Policy This “Privacy Policy” describes the privacy practices of Daasity, Inc. (“Daasity”, “we”, “us” or “our”). This Privacy Policy describes how we collect, use, disclose and otherwise process personal information in connection with our website and other Internet-enabled services (together “Services”), and explains the privacy rights and choices available to individuals. This Privacy Policy governs any of the Services on which the policy is posted. Please note that this Privacy Policy does not apply to the information we process on behalf of our clients. Our platform helps the direct to consumer community make optimal use of the vast quantities of highly complex customer, order, product, marketing and supply chain data by integrating the data points into our platform and placing the data into a useful context. Our processing of data on behalf of our clients is governed by agreements between us and our clients. These agreements require our clients to comply with applicable privacy laws and, to the extent the clients are legally required, provide privacy notices to the individuals whose data our clients process using Daasity’s platform. You can find further details on our processing of data on behalf of our clients in our Product Privacy Statement. Table of Contents Personal Information We Collect How We Use Your Personal Information How We Share your Personal Information Your Choices Cookies and Similar Technologies Other Important Privacy Information How to Contact Us Notice to European Users Personal Information We Collect Information you give us. You may provide information to us when you interact with the Services, for example, by registering, establishing an account, requesting information or otherwise communicating with us via the Services. You may provide your personal and business information, such as your name, mailing and email address, telephone number, company and other details you may choose to share with us. Information we collect automatically. Our servers and third party service providers may automatically record certain information about how you use the Services, such as your Internet Protocol (IP) address, domain name, device and browser type, operating system, Internet service provider, referring/exit pages, clickstream data, the pages or features of the Services that you browse and the time you spend on those pages or features, the frequency with which you use the Services, the links that you click on or use and other statistics. We collect this information in server logs and by using cookies and similar tracking technologies. See our Cookie Policy for more information. How We Use Your Personal Information We use the information we collect for the following purposes: To operate and improve the Services, including to: • Establish and manage accounts and registrations; • Communicate with you regarding the Services, including by sending you announcements, updates, security alerts, and support and administrative messages; • Respond to your requests, questions and feedback related to the Services; • Analyze our visitors’ and users’ needs and interests, and personalize experience with the Services; and • Analyze use of the Services to study trends and users’ movements around the Services, improve the Services and develop new features and services. To send you marketing and survey communications. We may send you surveys, newsletters or other marketing communications, but you may opt out of receiving them as described in the Opt out of marketing section below. For compliance, fraud prevention and safety. We may use your personal information as we believe appropriate to (a) investigate violations of and enforce our Terms of Service; (b) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. For compliance with law. We may use your personal information as we believe appropriate to (a) comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; and (b) where permitted by law in connection with a legal investigation. With your consent. We may ask for your consent to collect, use or share your personal information, such as when we are required to do so by law. How We Share your Personal Information We do not share your personal information with third parties without your consent, except in the following circumstances: Service providers. We may share your personal information with third parties that provide services that help us with our business activities (such as customer support, payment processing, hosting and storage, website analytics, email delivery and legal and other professional advice). We authorize these third parties to access your personal information to the extent reasonably necessary for them to provide their services. For legal reasons. We may disclose your personal information as we believe appropriate to government or law enforcement officials or to private parties for the purposes described above under the following sections: For compliance, fraud prevention and safety and for compliance with law. Your Choices Access or update your information. Service account holders may review or update information in their registration profile by logging into their account or contacting us at privacy@daasity.com. Opt out of marketing emails. You may opt out of marketing-related emails by following the unsubscribe instructions in the email. You may continue to receive Services-related and other non-marketing emails. Cookies and Similar Technologies We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Services and third party websites. For more details, see our Cookie Policy. 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” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. Other Important Privacy Information Third party sites and services. The Services may contain links to other websites and services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites, applications or services, and are not responsible for their actions. Other websites and services follow different rules regarding their collection, use and sharing of your personal information. We encourage you to read their privacy policies to learn more. Security practices. The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. Changes to this Privacy Policy. We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy we will notify you by email or through the Services if we are required to do so by applicable law. How to Contact Us Daasity, Inc. 4370 La Jolla Village Drive Suite 310 San Diego, CA 92122 privacy@daasity.com Notice to European Users The following applies to individuals in the European Economic Area. Controller. Daasity, Inc. is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation. Legal bases for processing. We describe the legal bases for our processing of your personal information in the table below. If you have questions about the legal basis of how we process your personal information, contact us at privacy@daasity.com. Processing purpose Legal basis To operate and improve the Services To send you marketing and survey communications For compliance, fraud prevention and safety These activities constitute our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on your rights and freedoms (unless we have your consent or are otherwise required or permitted to by law). In some cases, for example where you establish an account on the site, we process your data to fulfill our obligations under a contract with you or with the organization with which you are associated. For compliance with law Processing is necessary to comply with our legal obligations. With your consent 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 the Services. To share your personal information as described in this Privacy Policy This sharing constitutes our legitimate interests, and in some cases may be necessary to comply with our legal obligations. Retention We retain personal information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested; to comply with applicable legal, tax or accounting requirements; to establish or defend legal claims; or for fraud prevention). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. Cross-border data transfer If we receive or transfer your personal information from the European Economic Area ("EEA") to a third country and are required to apply additional safeguards to your personal information under European data protection legislation, we will do so. Daasity complies with the EU-US Privacy Shield Framework Principles as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EEA to Daasity in the United States. Daasity has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. 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/. Further details regarding our compliance are in our Privacy Shield Policy Statement. In compliance with the Privacy Shield Principles, Daasity commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield Statement should first contact Daasity at privacy@daasity.com. Daasity has further committed to refer unresolved Privacy Shield complaints to BBB, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.bbb.org/EU-privacy-shield/file-a-complaint for more information or to file a complaint. The services of BBB are provided at no cost to you. If neither Daasity nor BBB resolves an individual's complaint, the individual may have the ability to engage in binding arbitration through the Privacy Shield Panel. Additional information on the arbitration process is available on the Privacy Shield website at http://www.privacyshield.gov. Daasity may share personal information with third party services providers that perform services on behalf of Daasity. Daasity may be liable if these third parties fail to meet those obligations, and Daasity is responsible for the event giving rise to the damage. 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. • Correct. Update or correct inaccuracies in your personal information. • Delete. Delete your personal information. • 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. • Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights. You may submit these requests by email to privacy@daasity.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here. Cookie Policy This Cookie Policy explains how Daasity, Inc. (“Daasity”, “we”, “us” or “our”) uses cookies and similar tracking technologies when you visit our website at www.Daasity.com or any other site to which we post this Cookie Policy (the “Sites”). What are cookies? Cookies are small data files that are placed on your computer when you visit a site. Cookies serve different purposes, like helping us understand how a site is being used, letting you navigate between pages efficiently, remembering your preferences and generally improving your browsing experience. Who places cookies on my device? Cookies set by the site you visit are called “first party cookies”. Cookies set by parties other than us are called “third party cookies”. Third party cookies enable third party features or functionality within the site, such as site analytics. The parties that set these third party cookies can recognize your computer or device both when it visits the site in question and also when it visits certain other sites and/or mobile apps. We do not control how these third parties use your information, which is subject to their own privacy policies. See below for details on use of third party cookies and similar technologies with our Sites. How long will cookies stay on my device? The length of time a cookie will stay on your device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device after you have finished browsing until they expire or are deleted. What other tracking technologies should I know about? Cookies are not the only way to track visitors to a site or app. Companies use tiny graphics files with unique identifiers called beacons (and also “pixels” or “clear gifs”) to recognize when someone visits its sites. These technologies often depend on cookies to function properly, and so disabling cookies may impair their functioning. What types of cookies and similar tracking technologies does Daasity use? We use cookies and other tracking technologies in the following categories described in the table below. Type Description Who serves the cookies How to control them Analytics These cookies help us understand how our Sites are performing and being used. These cookies may work with clear gifs included in emails we send to track which emails are opened and which links are clicked by recipients. Google Analytics See 'your choices' below. Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Sites by downloading and installing a browser plugin available here. Your choices 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 Sites may not work properly. For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit http://www.allaboutcookies.org. For more information about how we collect, use and share your information, see our Privacy Policy. Changes Information about the cookies we use may be updated from time to time, so please check back on a regular basis for any changes. Questions If you have any questions about this Cookie Policy, please contact us by email at privacy@daasity.com.