Privacy Policy

Last modified: February 16, 2022

INTRODUCTION

Alphader and its affiliates (together "Company," "we," "us," or "our") respect your privacy and are committed to protecting it through our compliance with this policy.

This Policy describes the types of information we may collect from you or that you may provide when you visit our website, subscribe to any of our newsletters, any digital subscription, and any other of the Company's products or services including other web, mobile applications, or subdomains (collectively, our "Site") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Site;

• In email, text, and other electronic messages between you and this Site;

• Through mobile and desktop applications you download from this Site, which provide dedicated non-browser-based interaction between you and this Site; and

• When you interact with advertising and applications on third-party websites and services, if any, if those applications or advertising include links to this Policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or

• Any third party (including our affiliates and subsidiaries), including through any application or content that may link to or be accessible from or through the Site.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our Site. By accessing or using this Site, you agree to this Privacy Policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

At all times, your use of the Site is subject to the Terms of Use, which incorporates this Privacy Policy.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect several types of information from and about users of our Site, including information:

• By which you may be personally identified, such as name, email address, or any other identifier by which you may be contacted online or offline ("personal information");

• Signature, online identifier, internet protocol address or similar identifiers;

• That is about you but individually does not identify you (for example, industry or demographic information); and/or

• About your internet connection, the equipment you use to access our Site, and usage details.

We may collect this information:

• Directly from you when you provide it to us;

• Automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and/or other tracking technologies; and/or

• From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Site may include:

• Information that you provide by filling in forms on or off of our Site. and/or

• Records and copies of your correspondence (including email addresses), if you contact us.

Information We Collect Through Automatic Data Collection Technologies

• As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Site, including geolocation, traffic data, location data, logs, and other communication data and the resources that you access and use on the Site; and

• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns;

• Store information about your preferences, allowing us to customize our Site according to your individual interests;

• Speed up your searches; and

• Recognize you when you return to our Site.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small text file that is stored on a user's device (such as a computer, smartphone, or tablet) when they visit our Site. Cookies are commonly used to improve user experience and provide personalized features on the Site. The cookies will be stored on your device and allow your browser to remember information about your specific user profile. We do not use cookies to track information other than information specifically granted to us by the user. Disabling certain cookies may impact the functionality and user experience of our Site.

• Flash Cookies. Certain features of our Site may use locally stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

• Web Beacons. Pages of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related Site statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information, for carefully-considered purposes and for the benefit or our customers as follows:

• To present our Site and its contents to you and to operate our services, products, and systems properly;

• As to the non-public portions of our Site, to authenticate user information and ensure only authorized users access our Site;

• To provide you with information, products, or services that you request from us;

• To fulfill any other purpose for which you provide it;

• To provide you with notices about your account/subscription, including expiration and renewal notices;

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection purposes;

• To communicate with you, including notifying you about changes to our Site or any products or services we offer or provide though it;

• To allow you to participate in interactive features on our Site;

• To analyze use of our Site;

• In any other way we may describe when you provide the information; and

• For any other purpose with your consent.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this Privacy Policy:

• To our subsidiaries and affiliates;

• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;

• To fulfill the purpose for which you provide it;

• For any other purpose disclosed by us when you provide the information;

• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;

• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes;

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

ACCESSING AND CORRECTING YOUR INFORMATION

You may also send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

YOUR STATE PRIVACY RIGHTS

If you are a California, Virginia, Colorado, Connecticut, Utah, Iowa, Indiana, Tennessee, Texas, Florida, Montana, Oregon, or Delaware resident, your State has passed legislation regarding your privacy rights. Of those thirteen, California, Colorado, Connecticut, and Virginia laws are currently effective. To learn about your California privacy rights, see California Privacy Rights. To learn more about your Colorado, Virginia, or Connecticut privacy rights and how to exercise them, please make a written request to [email protected]. While we will make reasonable efforts to accommodate any request, we also reserve the right to place limitations on any request, subject to applicable laws.

CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act (CCPA) provides California residents with additional rights as it relates to the protection of personal data."Personal information" refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with you. If you think Alphader has misappropriated your personal information, California consumers have a right to:

• know about the personal information Alphader collects about you;

• correct inaccurate personal information;

• limit the use and disclosure of sensitive personal information;

• delete personal information collected by Alphader; and

• receive non-discriminatory treatment against you for exercising any of these rights.

You acknowledge that by requesting certain types of personal data be deleted or removed from Alphader's permissible usage, it may consequently affect your user experience of the Site.

Some examples of "personal information" as defined by the CCPA include:

• name, alias, postal address, IP address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers;

• commercial information including records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies;

• internet or other electronic network activity information including, but not limited to, browsing history, search history and information regarding a consumer's interaction with a website, application, or advertisement; and

• geolocation data.

Personal information, as defined by the CCPA, does not include publicly available information that is from federal, state or local government records or other information that is publicly available.

Alphader collects the following types of information which may constitute "sensitive personal information" as defined under the CCPA: log-in and password, email address, signature, online identifier (i.e., IP address), and certain information about your internet connection (i.e., device type). Alphader only uses such information to provide our services and products or as otherwise permitted by the CCPA. Alphader does not sell or share your personal information to third parties and/or other affiliates. For more information on how we collect, use, and retain your information as well as updates, see INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT (above). California customers can exercise their rights directly or through an authorized agent by contacting Alphader's Legal Department. Please include "California Privacy Rights" in the Subject line of your email, if sending an inquiry electronically.

EUROPEAN PRIVACY RIGHTS (GDPR)

The European Union's General Data Protection Regulation (GDPR) provides customers in the European Economic Area (EEA) with additional rights as it relates to protection of personal data. References to "personal information" in this Policy are equivalent to "personal data" as defined under GDPR. "Personal information" or "personal data" refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with you. Under the GDPR, a company may be a "data controller," "data processor" or both.

Data Controller

Under Article 4 of the GDPR, a company is a "data controller" when it determines the purposes and means of processing personal data. In Alphader's role as a "data controller," we ensure that European customers have the right to access the data gathered about them and subsequently request a correction, minimization or deletion of the data collected depending on the individual circumstances, with the acknowledgement that in doing so, your experience of the Site may be impacted.

When acting as data controller, Alphader commits to:

• take into account the nature, scope, context, and purposes of processing, and

• implement appropriate measures to ensure the ability to demonstrate processing is in accordance with GDPR.

Data Processor

Under Article 4 of the GDPR, a company is a "data processor" when it processes personal data on behalf of a "data controller." In Alphader's role as "data processor," we process your data safely and legally; and while the majority of Alphader's business operates as a "data controller," circumstances may arise where we process data. Under Article 2 of the GDPR, Alphader retains the right to process personal data by competent authorities for the purposes of the prevention, investigation, detection, or prosecution of criminal offenses or the execution of criminal penalties.

In accordance with this Privacy Policy and the GDPR, personal data shall be:

• processed lawfully, fairly and in a transparent manner in relation to you;

• collected for specified, explicit and legitimate purposes;

• adequate, relevant and limited to what is necessary;

• accurate and, where necessary, kept up to date;

• kept in a form that permits identification of you for no longer than is necessary; and

• processed in a manner that ensures appropriate security of personal data.

In the event of a data breach, Alphader will abide by GDPR requirements of notification and remediation. Alphader will report data breaches within a seventy-two-(72)-hour time frame, or if delayed will give a reason and response for such a delay. If a data breach occurs and puts certain individuals in high risk, Alphader will inform those individuals involved without undue delay. Alphader only retains data so long as is necessary and for the purposes for which it was collected. Alphader will retain your data for the necessary retention period and abide by applicable retention period criteria. Alphader will not keep your personal information for longer than is necessary. Reasons for retaining your data may include, but are not limited to, increased user accessibility of the Site, to comply with legal inquiries, and to help law enforcement with ongoing investigations.

You shall have the right to:

• ask whether we have any personal data about you and request a copy of such personal data;

• request that we update or correct inaccuracies in your personal data;

• request that we restrict the processing of your personal data if such processing is appropriate; and

• object to our processing of your personal data if processing is inappropriate.

You acknowledge that by requesting certain types of personal data be deleted from Alphader's permissible usage, it may consequently affect your user experience of the Site. For more information about how we collect, use, and retain your information as well as updates, see INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT (above). European customers can exercise their rights directly or through an authorized agent by contacting Alphader's Legal Department. Please include "European Privacy Rights" in the Subject line of your email.

DATA SECURITY

Any information that you provide to us is kept secure; however, the safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to our Site's services, you are responsible for keeping that password confidential. We ask you not to share your password with anyone.

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Site home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this Privacy Policy to check for any changes.

TRANSFER OF YOUR PERSONAL INFORMATION TO COUNTRIES OTHER THAN THE UNITED STATES

Our Site is used by customers throughout the world. Some of these countries have different levels of privacy protection than those in the U.S. By using our Site and our products and services, you acknowledge that you agree to any transfer and processing of personal information, including to and in the United States. We implement appropriate safeguards to protect any information that is transferred.

NOTICE FOR GDPR/EEA AND UK/GDPR

If you are a data subject in the European Economic Area (“EEA”), the UK, or Switzerland, you have certain rights with respect to your personal data pursuant to the General Data Protection Regulation of the European Union (“GDPR”) and the UK GDPR. This section applies to you. References to “personal information” in this Privacy Policy are equivalent to “personal data” as defined under GDPR. Company is the controller of your personal information as covered by this Privacy Policy for purposes of GDPR.

We process your personal data in reliance on the legal bases below. Where the purpose of processing is:

• To provide and improve our service: We process your personal data as necessary to perform the contract under which we provide our Services or to take steps that you request prior to signing up for the Services.

• To comply with the law: We process your personal data as necessary to comply with applicable laws and our legal obligations.

• For compliance, fraud prevention, and safety: We have a legitimate interest in processing your personal data, as described in this Privacy Policy, and our reasons for doing so outweigh any prejudice to your data protection rights. We also process your personal data as necessary to comply with our legal obligations.

• To send target communications or aggregated use for analytics: We have a legitimate interest in processing your personal data, as described in this Privacy Policy, and our reasons for doing so outweigh any prejudice to your data protection rights.

• With your consent: We process your personal data in reliance on your consent. You may withdraw your consent at any time in the manner indicated when you provided consent or in the Services.

YOUR RIGHTS

You may: (i) ask whether we have any personal data about you and request a copy of such personal data; (ii) request that we update or correct inaccuracies in your personal data; (iii) request that we delete your personal data; (iv) request a portable copy of your personal data; (v) request that we restrict the processing of your personal data if such processing is inappropriate; and (vi) object to our processing of your personal data (if such processing is inappropriate). These rights are subject to applicable law. If you would like to exercise any of these rights, please contact us at [email protected] or at the email in the “Contact Us” section of our website. To protect your information, we may need to verify your identity before processing your request, including by collecting additional information to verify your identity, such as government-issued identification documents. If you would like to submit a complaint about our use of your personal data or our response to your requests regarding your personal data, please contact us at the same email.

TRANSFERS OUTSIDE OF THE EEA

If we transfer your personal data outside the EEA, we will do so in accordance with the terms of this Privacy Notice and applicable data protection law.