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PRIVACY POLICY


EFFECTIVE NOVEMBER 1, 2020

Before providing any information to ObservePoint, Inc. (“ObservePoint”, “we”,
“us”, or “our”), please take the time to read our Privacy Policy (the “Policy”)
which describes the types of information we gather from people visiting
www.ObservePoint.com (the “Website”)and from individual users interacting with
the applications we provide to third parties, and how we use such information.
ObservePoint complies with the EU-US Privacy Shield Framework as set forth by
the US Department of Commerce regarding the collection, use, and retention of
personal information fromEuropean Union members countries. ObservePoint has
certified that it adheres to the Privacy Shield Principles. If there is any
conflict between the policies contained herein and the Privacy Shield
Principles, the Privacy Shield Principles shall govern. To learn more about the
Privacy Shield program, and to view our certification page, please
visit https://www.privacyshield.gov/.  As evidenced by ObservePoint’s
self-certification with the EU-US Privacy Shield
(https://www.privacyshield.gov/list), we understand the importance of privacy
and accordingly, treat all information received in a responsible manner. By
accessing the Website, you agree to be bound by this Policy. If you do not agree
to the terms of this Policy, please do not use the Website or our services. Each
time you use the Website or services, the current version of thePrivacy Policy
will apply. Accordingly, when you use the Website or ObservePoint services, you
should check the date of this Policy (which appears at the top) and review any
changes since the last version.


TYPES OF INFORMATION WE COLLECT

ObservePoint may collect two types of information from users of our Website or
application: “personal information”which is information that can be used to
locate you, contact you, or determine your specific identity (such as name,
e-mail address, mailing address, phone number, etc.) and “aggregate information”
which is information about your activities on the Website or in connection with
the services that cannot be used to identify, locate, or contact you (such as
frequency of visits to theWebsite, data entered when using the Website, Website
pages most frequently accessed, browser type, etc).


COLLECTING YOUR PERSONAL INFORMATION

ObservePoint is committed to subject to the EU-US Privacy Shield Principles all
personal data received from the EU and the U.S. in reliance on the Privacy
Shield. ObservePoint collects personal information that is voluntarily provided
when a user on our Website signs up for our services. For example, when you sign
up for an account, we ask you for your name, email address, and business
information. This information is used to assist us in helping you select the
appropriate service package and in connecting you with other users of the
Website or services. When users submit information through our services, the
information is co-owned by us and the user as our customer and the user
information is subject to this Policy and our customer’s applicable privacy
policy. We make no representation or warranty about our customers’ privacy
policies, so if you are submitting information to one of our customers through
our services, you should review and understand that customer’s privacy policy
before providing your information to them and us.


COLLECTING YOUR AGGREGATE INFORMATION

Aggregate information is collected as you visit our Website, application or
interact with our services even if you do not enter any information. Generally,
aggregate information is used in a collective manner, and no single person can
be identified by that compiled information.ObservePoint uses aggregate
information to provide its services and remuneration, as well as to determine
the use of our Website and to monitor, audit and analyze information pertaining
to our business metrics.


SHARING, SELLING AND TRADING OF YOUR PERSONAL INFORMATION WITH THIRD PARTIES


As a Privacy Shield organization, ObservePoint has responsibility for the
processing of any of your personal information it receives under the Privacy
Shield and any subsequent transfers to a third party who would be acting as an
agent on our behalf. ObservePoint, on occasion, may share personal information
with third party service providers as we deem necessary for the third party to
fulfill their duties on our behalf, such as fulfilling orders, processing credit
card payments, or other functions necessary to our business. These third-party
service providers are not authorized to retain, share, store or use your
personal information for any purposes other than to provide the services for
which they have been hired to provide on our behalf. ObservePoint shall remain
liable under the Principles if its agent processes your personal information in
a manner inconsistent with the Principles, unless ObservePoint proves that it is
not responsible for the event giving rise to the damage. When you submit your
personal information, you agree that we may use your personal information to
contact you by email, telephone, cell phone, direct mail, or text message about
information you request and certain offers made available by us or third parties
that we believe you might be interested in based on information you have
provided to us. We do not sell ,trade or otherwise share your personal
information with unrelated third parties for their own marketing purposes,
however, we may market certain offers to you on behalf of third parties we
determine you might be interested in.



SHARING, SELLING AND TRADING AGGREGATE INFORMATION COLLECTED ONLINE WITH THIRD
PARTIES


We may use aggregate information to improve the Website, application and
services, to monitor traffic and general usage patterns, and for other general
business purposes. We may disclose aggregate information to third parties for a
variety of business reasons, including to advertisers to inform them of the
usage habits or characteristics of the interested audience, and to potential
investors so that they may better understand our user base, etc. Aggregate
information will not include any personal information and we will not disclose
any personal information except as expressly stated elsewhere in this Policy.



OTHER INSTANCES WHEN WE SHARE YOUR INFORMATION


In addition to the foregoing, ObservePoint may elect to share or transfer your
personal information to unrelated third parties: (i) to comply with a legal
requirement, judicial proceeding, court order, or legal process served on
ObservePoint, (ii) to investigate a possible crime, such as fraud or identity
theft; (iii) in connection with the sale, purchase, merger, reorganization,
liquidation or dissolution of ObservePoint;(iv) when we believe it is necessary
to protect the rights, property, or safety of ObservePoint or other persons; or
(v) as otherwise required or permitted bylaw. Please note ObservePoint is
required to disclose personal information in response to lawful requests by
public authorities, including to meet national security or law enforcement
requirements. The Federal Trade Commission has jurisdiction over ObservePoint
with regard to its compliance with the PrivacyShield. Please note that on some
portions of the Website or application, users can choose to have their personal
information displayed. If users choose to have their personal information
displayed on the Website, they will be given forewarning that the action they
are about to take will make their personal information publicly available on the
Website.



COOKIES

If you do not provide us any of your personal information, we are limited in the
information we may collect from you. For example, we may be able to determine
your IP address for the purposes of administering the Website and tracking
Website usage, but your IP address may vary each time you visit or it may remain
the same depending on the type ofInternet connection you are using or the
location from which you access the Website. We may collect information about the
websites that directed you to theWebsite after you clicked on a text or banner
link or an ad from another website, or the day and time you visited the Website
and how long you spent on the Website. We aggregate such information to help us
to compile reports as to trends and other behavior about users visiting our
Website, however such information is anonymous and cannot be tied directly to
you. We may also use“cookies” and your personal information to enhance your
experience on theWebsite and with the services offed to provide you with
personalized offers. A cookie is a small data file placed on your computer’s
hard drive that contains information that allows us to track your activity on
the Website. The cookie itself does not contain any personal information;
however, if you provide us any personal information the cookie may act as an
identifier to tie your personal information to your IP address or computer. You
may choose to delete cookies from your computer’s hard drive at anytime or to
disable cookies on your computer. If you delete cookies that relate to the
Website, we may not be able to identify you upon your return to the Website.
Additionally, if you disable your computer’s cookies, you may not be able to
access certain features of the Website or services that require that cookies be
enabled. The Website’s cookies cannot be used to read data from your hard drive
and cannot retrieve information from any other cookies created by other
websites. ObservePoint’s cookies cannot be used as a virus, Trojan horse, worm,
or any other malicious tool that could impair your use of your computer. Our
cookies are used to help us better understand how you and other users use the
Website so we can continue to provide a better, more personalized user
experience on the Website. We also share website usage information about our
Website with those interested in running targeted promotional campaigns on the
Website. For this purpose, we and our advertisers track some of the pages that
you visit on the Website through the use of pixel tags (also called clear gifs).



SECURITY PERTAINING TO YOUR INFORMATION


We take appropriate security measures to protect against unauthorized access to
or unauthorized alteration, disclosure or destruction of data. These include
internal reviews of our data collection, storage and processing practices and
security measures, as well as physical security measures to guard against
unauthorized access to systems where we store personal data. We restrict access
to personal information to ObservePoint employees, service providers and agents
who need to know that information in order to operate, develop or improve our
services. These individuals are bound by confidentiality obligations and may be
subject to discipline, including termination and criminal prosecution, if they
fail to meet these obligations.We use secure socket layer (“SSL”) technology to
encrypt and protect the security of your personal information, when it is sent
over the Internet. No method of transmission over the Internet, or method of
electronic storage, is100% secure, however. Therefore, while we strive to
protect your personal information, we cannot guarantee its absolute security.



INTEGRITY OF YOUR DATA


ObservePoint processes personal information only for the purposes for which it
was collected and in accordance with thisPolicy. We review our data collection,
storage and processing practices to ensure that we only collect, store and
process the personal information needed to provide or improve our services. We
take reasonable steps to ensure that the personal information we process is
accurate, complete, and current, but we depend on our users to update or correct
their personal information whenever necessary.



CHILDREN AND PRIVACY


Our Website and application are not directed to children and we will not request
personally identifiable information from anyone who we know to be under the age
of 18, unless we have obtained verifiable parental consent from a parent or
legal guardian. If we become aware that a user under the age of 13 has
registered with our Website, application or services and ObservePoint has not
obtained prior verifiable consent from a parent or legal guardian, we will
immediately remove the user’s personal information from our files.



LINKS TO OTHER WEBSITES


The Website or our application may contain links to websites operated by other
people or companies. Those websites may have their own privacy policy or no
privacy policy at all. ObservePoint does not have any responsibility for those
websites, and we provide the links solely for the convenience of our visitors.



BUSINESS TRANSFERS


In the event that ObservePoint sells substantially all of its assets, or one of
ObservePoint’s business units is acquired, personal information of visitors to
the Website and aggregate information will likely be one of the transferred
assets.



CHANGES TO THIS POLICY


We may change this Privacy Policy at any time and without prior notice, by
posting the revised version of this Policy on our Website. Your continued use of
the Website and/or services indicates your consent to our collection of and use
of your personal and aggregate information under the then current Policy.



CORRECTIONS/INFORMATION REMOVAL/OPT-OUT


When ObservePoint processes your personal data, you have a right under the EU-US
Privacy Shield to access, correct or delete your personal data and to opt-out of
disclosures of your personal information to third parties or any other use of
your personal information and may do so at any time for any reason by contacting
ObservePoint CustomerService at support@ObservePoint.com. If your name, e-mail
or postal address, telephone number or other personal information changes, you
may update, correct or omit the relevant information by contacting ObservePoint
Customer Service at support@ObservePoint.com. If you prefer not to receive
newsletters or other marketing e-mails from ObservePoint, please let us know by
clicking on the unsubscribe link within any newsletter or marketing e-mail you
receive. If you prefer not to receive marketing mail via the mail carrier,
please let us know by contacting customer service at support@ObservePoint.com.
Please be sure to include in any e-mail your full name, e-mail address, and any
message. Please note that such requests may take up to ten (10) days to become
effective.



CONTACT US


In compliance with the Privacy Shield Principles, ObservePoint commits to
resolve complaints about your privacy and our collection or use of your personal
information. All individuals with inquiries or complaints regarding this privacy
policy should first contact ObservePoint at: privacy@observepoint.com.
ObservePoint has further committed to refer unresolved Privacy Shield complaints
to JAMS, 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 resolved your complaint, please contact or
visit https://www.jamsadr.com for more information or to file a complaint.  The
services JAMS are provided at no cost to you. If you contact ObservePoint and do
not receive a resolution to your privacy concerns, you may possibly, under
certain limited conditions, invoke binding arbitration before the Privacy Shield
Panel to be created by the U.S. Department ofCommerce and the European
Commission (for more information,
see https://www.privacyshield.gov/article?id=ANNEX-I-introduction).


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