1.The Information We Collect.

When providing the AccuReach Services to our Customers, we may obtain information about you through the following means discussed below.

Personally Identifiable Information (“PII”): such information may include any or all of the following: (i) name; (ii) email address; (iii) mailing address; (iv) telephone number; (v) company, job title, and job history; (vi) location; (vii) education history; and (viii) social network names, nicknames, or handles. When Customers subscribe to use the AccuReach Services, we may collect personal contact information regarding such users and financial information for billing purposes.

We may also collect certain non-personally identifiable, indirect and/or aggregate information as a result of your use of, and interaction with, AccuReach Services and the Website (collectively, “Other Information”). When you access our Website, we may automatically receive certain information about you through your use of your device(s). We and our service providers (which are third parties working on our behalf) may use a variety of technologies, such as cookies, to receive such Other Information.

Info-Bridge (“Info-Bridge Data”): In addition to PII and Other Information as defined above, we also obtain information about you through the provision of AccuReach Services to our Customers via our “Info-Bridge.” Our Info-Bridge is a data sharing group comprised of certain of our participating Customers. Such Customers participating in the Info-Bridge are the entities that collect various information about you, which may include PII, Other Information, and otherwise publicly available information.

2.Personally Identifiable Information.

You may choose not to provide any PII that we ask for. However, if you choose not to provide the PII that we ask for, it is possible that you may not be able to participate in or complete particular activities or transactions available via AccuReach Services.

Some laws (such as GDPR) distinguish between a “controller” and a “processor”, or similar terms. We are a “processor” for those AccuReach Services where we only use PII as allowed by our customers. Where we use PII as allowed by our customers (where we are acting as a processor), our customers are responsible for the obligations of a “controller” under applicable laws in connection with the processing of PII, and, if you are using the AccuReach Services through one of our customers, you should contact them if you have questions or concerns about the processing of your PII or compliance with applicable laws.

3.Other Information.

We may use certain standard web measurement and tracking technologies such as “cookies” or other statistics programs to collect Other Information and track and record how you use the AccuReach Services. This data is anonymous and does not personally identify you. Other Information helps us measure the success of the AccuReach Services and its features and to improve your experience.

4.Our Use of Information Collected.

We use your information for only the following business purposes: (i) to provide AccuReach Services; (ii) to respond to inquiries we receive from you or in connection with a transaction you initiate; and (iii) for any other specific business purpose stated at the time you provide your information.

In providing AccuReach Services for our Customers, we may use your information to help Customers identify potential candidates, assist those Customers in analyzing and improving their proprietary databases and in mitigating potential fraud through verification tools, and to provide Customers with marketing insights. We may also use your information to optimize the AccuReach Services content, functionality, and useability metrics; improve and address any security issues, service interruptions, and other reported issues.

We may also aggregate your information that is processed through the AccuReach Services, and/or de-identity such information, for the purpose of removing any association of such information to you or to your device. Such aggregated and/or de-identified information may be used by us for any purpose, such as research and marketing, and we may also share such information with third parties at our sole discretion. You expressly authorize us to share your PII, Other Information, and Info-Bridge Data with any third parties retained or utilized by us to the extent necessary to perform any of the business purposes listed above.

5.Mobile Devices.

From time to time, we may offer certain mobile applications for download. We will use commercially reasonable efforts, given the limitations imposed upon us by third party platform providers (e.g., Apple Inc. and Google, Inc.), to clearly disclose what, if any, PII or Other Information is collected by each particular application, how it is used, and with whom it is shared. In the event that it is not commercially feasible for us to provide this explanation, for example if you download the application directly via your mobile device without visiting any Internet website where we could publish such explanation, this Privacy Policy shall govern any information collected by us as a result of your use of the application

Please be aware that certain information collection and tracking practices are not within our control (e.g., tracking by third party platform providers or telecommunications carriers). We cannot be and are not responsible for the actions of such third parties. You should read and understand all policies of any third party platform provider, telecommunication carrier or other applicable third party prior to downloading any mobile application

6.Information That We Do Not Collect.

Compliance with privacy regulations is important to us and to our Customers. We do not collect the following sensitive personal data: race or ethnicity; political affiliation; religion; membership in trade unions; citizenship; genetic and health data; biometric data; sexual orientation; gender identity; status as victim of a crime; precise geolocation; private communications such as email, text, voice calls; financial or payment information when combined with authentication data; device identifier; government issued identifies such as SSN, license; or inferences based on personal data.

7.Disclosure of Your Information to Third Parties.

We may disclose the information we collect from and about you (including but not limited to PII, Other Information, and/or Info-Bridge Data), as permitted or required by law or regulation: (i) when we have reason to believe that such disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with our rights or property, customers or other users of the AccuReach Services, or anyone else who could be harmed by such activities, or is appropriate or necessary to enforce the Terms of Use, take precautions against liability, investigate and defend against any third party claims or allegations, and/or protect the security or integrity of the AccuReach Services; (ii) to respond to governmental, regulatory, law enforcement, or judicial processes and inquiries, and/or to provide information to law enforcement agencies in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law, or in the good faith belief that such action is necessary to comply with local, state and federal laws; (iii) to our business partners for research, analytical and marketing purposes, and/or to our affiliated companies, or other businesses or persons for the purpose of processing any request or transaction on your behalf; (iv) to our attorneys, auditors, and other professional advisors; or (v) otherwise with your consent. We may sell or buy other businesses or entities and, in such case, we may transfer or assign the information we have collected as part of such merger, acquisition, sale, or other change of control. In such transactions, your PII, Other Information, and/or Info-Bridge Data may be included in the transferred business assets. Also, in the event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, we may not be able to control how your PII, Other Information, and/or Info-Bridge Data is treated, transferred, or used and your PII, Other Information, and/or Info-Bridge Data may be included in the transferred assets. We may use your Other Information to identify and develop products and services that may be of interest to you and/or share this information with certain third parties for marketing purposes with respect to special offers, products, services, programs, promotions, surveys, publications, invitations or other opportunities that may be of interest to you.

Except as set forth above, we will not share any of your PII with any third party, unless we have received your express permission to do so, as necessary for our legitimate business interests where those interests do not override your fundamental rights and freedoms related to the privacy of your data and information, and as necessary to provide the AccuReach Services.

8.Security.

We take precautions and have implemented certain technical and commercially reasonable security measures intended to protect against unauthorized access to, disclosure of, unauthorized alteration and/or destruction of, and unlawful interception of PII, Other Information, and/or Info-Bridge Data submitted via the AccuReach Services. However, your communications containing PII, Other Information, and/or Info-Bridge Data may be unlawfully intercepted or accessed by third parties and/or the AccuReach Services may be subject to network attacks or malfunctions. We cannot and do not guarantee the security of any information transmitted over the Internet.

We retain PII, Other Information, and/or Info-Bridge Data only to the degree that such PII is needed to: (i) fulfill the purposes described in this Privacy Policy; (ii) satisfy the timelines as determined or recommended by regulators, professional bodies, or associations; (iii) comply with applicable laws, legal holds, and other legal obligations, including contractual obligations; and (iv) comply with your requests for use of the AccuReach Services.

At all times, we will retain your personal data for no longer than is necessary for the purposes stated in our Privacy Policy and for the purpose of providing the AccuReach Services.

9.Foreign Users.

By using the AccuReach Services or by vising our Website, you agree and acknowledge that the AccuReach Services and the Website are hosted in the United States. If you have accessed the AccuReach Services or Website from a physical location outside of the United States and submitted PII, please be advised that you are transferring your PII to the United States and you consent to: (i) such transfer; (ii) the application of the laws of the United States with respect to any dispute arising from or related to the Privacy Policy and/or your use of the Website, other than such rules, regulations, case law, and/or international treaties that would result in the application of the laws of a jurisdiction other than the United States; and (iii) the exclusive jurisdiction of the courts of the State of New York and the federal courts sitting in New York, New York. Any claim or dispute between you and us that arises in whole or in part from your use of the AccuReach Services or the Website or in connection with this Privacy Policy shall be decided exclusively by a court of competent jurisdiction located in New York, New York, United States of America. Each party hereby submits to exclusive jurisdiction and venue in such courts and waives any objection based on inconvenient forum.

10.Amendments to the Privacy Policy.

By using the AccuReach Services or by vising our Website, you agree and acknowledge that the AccuReach Services and the Website are hosted in the United States. If you have accessed the AccuReach Services or Website from a physical location outside of the United States and submitted PII, please be advised that you are transferring your PII to the United States and you consent to: (i) such transfer; (ii) the application of the laws of the United States with respect to any dispute arising from or related to the Privacy Policy and/or your use of the Website, other than such rules, regulations, case law, and/or international treaties that would result in the application of the laws of a jurisdiction other than the United States; and (iii) the exclusive jurisdiction of the courts of the State of New York and the federal courts sitting in New York, New York. Any claim or dispute between you and us that arises in whole or in part from your use of the AccuReach Services or the Website or in connection with this Privacy Policy shall be decided exclusively by a court of competent jurisdiction located in New York, New York, United States of America. Each party hereby submits to exclusive jurisdiction and venue in such courts and waives any objection based on inconvenient forum.

11.Ability to Accept Terms.

You affirm that you are at least 18 years of age, and are fully able and competent to enter into and accept the terms set forth in this Privacy Policy. If you are agreeing to this Privacy Policy on behalf of an entity and its directors, officers, employees and other personnel (collectively, “Personnel”), you hereby represent, warrant and covenant that you are authorized to accept this Privacy Policy on behalf of such entity and its Personnel.

12.Severability.

If any part of the Privacy Policy is determined to be invalid or unenforceable pursuant to court order or applicable law, the parties intend that such provision be amended and construed in a manner designed to effectuate the purposes of the provision to the fullest extent permitted by law.

13.GDPR.

If you are located in the European Economic Area (“EEA”) or Switzerland, you may have rights under the European Union General Data Protection Regulation (“GDPR”). The GDPR has been created to regulate how businesses and other organizations collect, protect, store, and use PII entrusted to them.

Pursuant to this Privacy Policy, and to the extent permitted by law, if you are within the EEA or Switzerland, you have the right to: (i) request access to your PII; (ii) request an update to or correction of your PII; (iii) object to the processing of your PII; (iv) request erasure of your PII; (v) request the transfer of your PII; and (vi) withdraw your consent to the processing of your PII.

You may exercise your rights under this Privacy Policy and under the GDPR by sending us an e-mail at info@accureach.io. Please note that we may ask you to verify your identity before we respond to your request. You have the right to complain to a Data Protection Authority about our collection and/or use of your PII. For more information, and if you are in the EEA or Switzerland, please contact your local data protection authority

You can find out more about your rights, and certain conditions and exceptions applicable to your rights, under the GDPR by reading more about the General Data Protection Regulation available at https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en.

14.Canada Anti-Spam Law.

We comply with the Canada Anti-Spam Law. If you use the Website and/or purchase AccuReach Services by using a Canadian mailing address, you will not receive unauthorized Commercial Electronic Messages (as defined under the Canada Anti-Spam Law) unless you have opted-in to receive such Commercial Electronic Messages. You can opt-in to receive such Commercial Electronic Messages by sending us an e-mail at info@accureach.io.

15.California Statement.

We proudly serve certain natural persons residing in the State of California (a “consumer”). This Supplemental Privacy Statement for California Consumers under the CCPA (“California Statement”) explains rights that California consumers may have under the California Consumer Privacy Act of 2018 (“CCPA”).

When we use the term “personal information” in this supplemental California Statement, we are using that term as defined by the CCPA. The CCPA generally defines “personal information” to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. However, personal information does not include publicly available, deidentified, or aggregate consumer information (all terms, as defined in the CCPA). Importantly, the definition of “personal information” also does not apply to the collection of personal information from job applicants, employees (whether you are our employee or any employee of the entity arranging access to AccuReach Services for you), business owners, directors, officers, medical staff, or contractors.

Where we act as a “business” under the CCPA (that is, we determine the manner and reasons for why we process your personal information), we may be required to disclose additional information regarding the categories of personal information we collect, the sources where we obtain that information, the purposes for collection, with whom we share that information, and whether we sell that personal information – all of which depends on the specific AccuReach Service. Additional information specific to each subject AccuReach Service can be obtained by sending us an e-mail at info@accureach.io with your concern or question.

If you are a resident of California and are not a job applicant, employee or contractor, or employee or contractor of another entity interacting with us in your job role, you have the right to request what information we collect, use, and disclose. You also have the right to request that we delete your information.

To make a request, you can send us an e-mail at info@accureach.io and provide us enough information to verify your identity. We will use information you provide to us to verify your request. If we cannot initially verify your identity, we may request additional information such as a copy of your driver’s license, a recent utility bill, and/or a recent credit card bill. You can also designate an agent to make such a request for you by either: (i) instructing your agent to send us an e-mail at info@accureach.io attaching a letter, signed by you, certifying that the agent is acting on your behalf and showing proof that that agent is registered with the California Secretary of State; or (ii) sending us an e-mail at info@accureach.io attaching a notarized power of attorney, executed by you and your agent, which states that the agent is authorized to act on your behalf. In any event, we may still require you to verify your identity before we process a request submitted by your agent.

California residents also have certain rights regarding the sale of personal information. California residents have the right to opt-out of the sale of their personal information by notifying us by e-mail at info@accureach.io.

We will not discriminate against you because you have exercised any of your privacy rights under the CCPA.

16.Children’s Privacy.

The Website and AccuReach Services are intended for professionals and/or individuals over eighteen (18) years of age. We do not seek to collect or maintain information (including PII) from children and do not knowingly collection any PII from children under the age of thirteen (13). If we learn we have collected or received PII from an individual under the age of 13, we will delete that PII. When you visit the Website and/or use AccuReach Services, you are representing to us that you are at least eighteen (18) years of age.

17.Your Rights.

In certain circumstances, local data protection laws (such as the GDPR) may give you rights with respect to personal information if you are located in or are a resident of that country, state, or territory, including if you are located in the EU, EEA and/or Switzerland. Please note that we are only required to honor rights to the extent that these rights have been granted to you and apply to you under applicable data protection laws. In addition to your rights under the local data protection laws applicable to you, if you are a resident of the State of Nevada, you may also have certain rights regarding the sale of PII. Nevada residents may opt-out of the future sale of their PII to a third party so that they may license or sell that PII by notifying us by e-mail at info@accureach.io.

Please be aware that your rights under the applicable local data protection laws are not absolutely guaranteed and there may be conditions and exceptions where we may not be obligated to fulfil your requests. Please consult your local data protection laws to determine what rights may be available to you and which conditions and exceptions may apply.

In any event, to make a request or to exercise your rights under the local data protection laws applicable to you, please contact us by e-mail at info@accureach.io. When you make a request, please tell us the following: (i) which right you are exercising; (ii) your relationship with us; (iii) additional information to prove your identity, if necessary; and (iv) your preferred method of receiving a response from us (such as your e-mail address).

18.Data Retention.

We do not retain your PII, Other Information, or Info-Bridge Data unless explicitly authorized and required by law. In rendering the AccuReach Services for our Customers, we process certain data which may or may not include your PII, Other Information, and/or Info-Bridge Data. All such data and information that we process is encrypted and securely transmitted to recipient Customers. After processing, encrypting, and transmitting such data and information to our Customers, we do not retain any of the pre-processed PII, Other Information, or Info-Bridge data, nor do we retain the encrypted versions there of.