Create an Account or Sign in Email Password First Name Last Name Nickname Phone I agree to the Terms of Service and Privacy Policy. Terms of Service PLEASE READ THESE TERMS OF USE CAREFULLY BEFORE USING THE WEBSITE. By using this website, or any SIMPLE BUSINESS GROUP online property, you signify your agreement to everything in these Terms of Use, our Privacy Policy, our Terms of Purchase and Refund Policy, and our Legal Disclaimers. If you do not agree to these Terms of Use, you may not use any of our Websites or online properties. By clicking a button or checking a box marked “I agree” (or something similar), You signify that You have read, understood, and agree to be bound by this agreement and to the collection and use of your information as set forth in our privacy policy (the “Privacy Policy“, collectively with this agreement, (the “Terms“). In addition, when you use any of our current or future services, you will also be subject to our guidelines, terms, conditions, and agreements applicable to those services. If these Terms of Use are inconsistent with the guidelines, terms, and agreements applicable to those services, these Terms of Use will control. When we say “SIMPLE BUSINESS GROUP” we mean any and all companies affiliated with SIMPLE BUSINESS GROUP and all affiliates. SIMPLE BUSINESS GROUP and all affiliated companies currently provide users with access to stock trading training resources (training videos, training books, educational software, etc.), various reference and communication tools (newsletters, blogs, articles, etc.), forums, online community, advertising and marketing services, social media services, and personalized content (collectively referred to as the “Services”). You also understand and agree that the service may include sponsorships or advertisements. Most of these Services of SIMPLE BUSINESS GROUP are provided free of charge. Unless explicitly stated otherwise, any new features that augment the current service, including the release of new content. Any and all SIMPLE BUSINESS GROUP services shall be subject to the Terms of Use. You understand and agree that any and all service is provided “AS-IS” and that SIMPLE BUSINESS GROUP assumes no responsibility for the timeliness, deletion, delivery problems, or failure to store any user communications or personalization settings. Privacy Policy. Please review our Privacy Policy, which also governs your visit to our website and any purchases made on our website. Terms of Purchase and Refund Policy. Please review our Terms of Purchase and Refund policy as by purchasing from our Company, you agree to be bound by those terms. Restrictions on Use of Our Content. The content contained on this website (collectively, “Content “), such as logos, artwork, text and graphics, widgets, icons, images, audio and video clips, digital downloads, data compilations, and software, is the property of SIMPLE BUSINESS GROUP or the property of our licensors or licensees, and the compilation of the content on the website is the exclusive property of SIMPLE BUSINESS GROUP and protected by the United States and international copyright laws, treaties and conventions. All software used on the website is also the property of SIMPLE BUSINESS GROUP or the property of our software suppliers and protected by the United States and international copyright laws, treaties, and conventions. Any and all logos, service marks, page headers, graphics, trademarks, service marks, widgets, icons, scripts, and trade names (each, a “Mark”) contained on the website are proprietary to SIMPLE BUSINESS GROUP or our licensors or licensees. Permission is NOT granted to use any of the Marks in connection with any product or service that is not ours or, in any manner, that is likely to cause confusion among users, or that disparages or discredits us or anyone else. If you see any other Marks not owned by SIMPLE BUSINESS GROUP that appear on the website are the property of their respective owners, who may or may not be affiliated with, connected to, or sponsored by us. We grant you a limited license to access and make personal use of the website. No Content of the Website or any other Internet site owned, operated, licensed, or controlled by us may be copied, reproduced, republished, downloaded (other than page caching), uploaded, posted, transmitted or distributed in any way, or sold, resold, visited, or otherwise exploited for any commercial purpose, except that you may download one (1) copy of the content that we make available to you for such purposes on a single computer for your personal, noncommercial, home use only, provided that you: (a) keep intact all copyright, trademark and other proprietary rights notices; (b) do not modify any of the content; (c) do not use any Content in a manner that suggests an association with any of our products, services or brands; and (d) do not download content to avoid future downloads from the website. Your use of the content on any other website or computer environment is strictly prohibited. The license granted to you does not include, and specifically excludes, any rights to: resell or make any commercial use of the Website or any Content; collect and use any product listings, descriptions, or prices; make any derivative use of the Website or Content; download or copy account information for the benefit of anyone else; or use any form of data mining, robots, or similar data gathering and extraction tools. You may not frame or utilize framing techniques to enclose any Mark, Content, or other proprietary information, or use any meta tags or any other “hidden text” utilizing any such intellectual property without our and each applicable owner’s express written consent. Any unauthorized use automatically terminates the license granted to you hereunder. You are granted a limited, revocable, and non-exclusive right to create a hyperlink only to our home page provided that the link does not portray us or our licensors or licensees, or their respective products or services, in a false, misleading, derogatory, or otherwise offensive matter. You may not use any of our or any such party’s intellectual property as part of the link without our and each such party’s express written consent Changes to Terms. These Terms, or any part thereof, may be modified by us, including the addition or removal of terms at any time, and such modifications, additions, or deletions will be effective immediately upon posting. Your use of the Websites after such posting shall be deemed to constitute acceptance by you of such modifications, additions, or deletions. Changes to Websites. We may change or discontinue any aspect, service, or feature of the Websites at any time, including, but not limited to, content, availability, and equipment needed for access or use. Registration. You may be given the opportunity to register via an online registration form or by participating in Interactive Areas (as defined below), such as forums and other community features, to create a user account (“Your Account”) that may allow you to receive information from us and/or to participate in certain features on the Websites. We will use the information you provide under the Privacy Policy. By registering, you represent and warrant that all information that you provide is current, complete, and accurate to the best of your knowledge. You agree to maintain and promptly update your information on the Websites so that it remains current, complete, and accurate. You are responsible for obtaining and maintaining all connectivity, computer software, hardware, and other equipment needed to access and use the Websites and all charges related to the same. The purchase of certain products and services on SIMPLE BUSINESS GROUP may require registration for a user account (“User Account”). Should you choose to register, you agree to provide true, complete, and accurate registration information (“Registration Information”). You are responsible for updating and maintaining the accuracy of Registration Information. If you provide any Registration Information that is untrue or inaccurate, not current, or incomplete, or if SIMPLE BUSINESS GROUP suspects that your Registration Information is untrue, inaccurate, or incomplete, then SIMPLE BUSINESS GROUP may, in its sole discretion, suspend, terminate, or refuse future access to SIMPLE BUSINESS GROUP. Registration Information will be subject to the SIMPLE BUSINESS GROUP Privacy Policy (which is incorporated by reference herein). You are responsible for maintaining the secrecy and security of any personal or User Account Information. You are responsible and liable for any conduct on SIMPLE BUSINESS GROUP under your User Account. SIMPLE BUSINESS GROUP is not responsible for any unauthorized use of your User Account. If you believe there has been unauthorized use of your User Account, you must notify SIMPLE BUSINESS GROUP immediately. Only the authorized license user is permitted to use the password-protected account within SIMPLE BUSINESS GROUP. If anyone loans or discloses their Username and Password or otherwise knowingly or unknowingly allows unauthorized access into the fee-based products, the original site license holder shall be responsible for and will be billed for any and all purchases an unauthorized user makes on SIMPLE BUSINESS GROUP. Web Forums and Discord Servers. SIMPLE BUSINESS GROUP may provide its members with access to a forum and/or Discord Server for you and other users an opportunity to submit, post, display, transmit and/or exchange information, ideas, opinions, photographs, images, video, creative works or other information, messages, transmissions or material to SIMPLE BUSINESS GROUP and other users via chat rooms, message boards or other means (“User Submissions”). User submissions do not reflect the views of SIMPLE BUSINESS GROUP (the “Admins”), neither of which have any obligation whatsoever to monitor, edit, or review any User Submissions on the Website and/or Discord Server. The Admins assume no responsibility or liability arising from the content of any User Submissions, any error, defamation, libel, slander, omission, falsehood, obscenity, pornography, profanity, danger, or inaccuracy contained in any information within any User Submission on SIMPLE BUSINESS GROUP. You are strictly prohibited from submitting or transmitting to the Admins any unlawful, threatening, libelous, defamatory, obscene, scandalous, inflammatory, pornographic, or profane material that could constitute or encourage conduct that would be considered a criminal offense, give rise to civil liability, or otherwise violate any law. The Admins will fully cooperate with any law enforcement authorities or court order requesting or directing it to disclose the identity of anyone posting any such information or materials. All User Submissions will be treated as non-confidential and non-proprietary. Anything you submit or transmit to SIMPLE BUSINESS GROUP or post shall be deemed the property of and may be used by the Admins for any purpose, including, but not limited to, reproduction, disclosure, transmission, publication, broadcast, and posting. Furthermore, the Admins are free to use and shall be deemed to own any ideas, concepts, know-how, or techniques contained in any User Submission you submit or transmit to SIMPLE BUSINESS GROUP for any purpose whatsoever, including, but not limited to, developing, manufacturing and marketing products using such information. Disclosure, submission, or offer of any User Submissions to SIMPLE BUSINESS GROUP shall constitute an assignment to the Admins of all worldwide rights, titles, and interests in all copyrights and other intellectual property rights in such User Submission. The Forum Admins may edit, copy, publish, distribute, translate, and otherwise use in any medium any User Submission that you submit or transmit to the Forum Admins and will own exclusively all such rights, titles, and interest and shall not be limited in any way in its use, commercial or otherwise, of the submission. The Forum Admins are and shall continue to be under no obligation to maintain any User Submission in confidence, compensate you or any other user for any User Submission, or respond to any of your or any other user’s User Submission. User Content Guidelines. The following terms apply to content submitted by you: The Websites may contain comments sections, discussion forums, or other interactive features (“Interactive Areas”) in which you may post or upload user-generated content, comments, video, photos, messages, other materials or items (collectively, “User Content”). You are solely responsible for your use of any Interactive Areas, and you use them at your own risk. Interactive Areas are available for individuals aged 13 years or older. By submitting User Content to an Interactive Area, you represent that you are 13 years of age or older and, if you are under the age of 18, you either are an emancipated minor or have obtained the legal consent of your parent or legal guardian to enter into these Terms, submit content, and participate on the Websites. By submitting any User Content or participating in an Interactive Area within or in connection with the Websites, you agree that you will not upload, post, or otherwise transmit any User Content that: violates or infringes in any way upon the rights of others, including any statements which may defame, harass, stalk or threaten others;you know to be false, misleading, or inaccurate;contains blatant expressions of bigotry, racism, racially or ethnically offensive content, hate speech, abusiveness, vulgarity, or profanity;contains or advocates pornography or sexually explicit content, pedophilia, incest, bestiality, or that is otherwise obscene or lewd;violates any law or advocates or provides instruction on dangerous, illegal, or predatory acts, or discusses illegal activities with the intent to commit them;advocates violent behavior;poses a reasonable threat to personal or public safety;contains violent images of killing or physical abuse that appear to have been captured solely, or principally, for exploitative, prurient, or gratuitous purposes;is protected by copyright, trademark, trade secret, right of publicity, or other proprietary rights without the express permission of the owner of such copyright, trademark, trade secret, right of publicity, or other proprietary rights. The burden of determining that any User Content is not protected by copyright, trademark, trade secret, right of publicity, or other proprietary right rests with you. You shall be solely liable for any damage resulting from any infringement of copyrights, trademarks, trade secrets, rights of publicity or other proprietary rights, or any other harm resulting from such a submission. Any person determined by SIMPLE BUSINESS GROUP, in its sole discretion, to have violated the intellectual property or other rights of others shall be barred from submitting or posting any further material on the Websites; (j) does not generally pertain to the designated topic or theme of any Interactive Area; (k) contains any unsolicited or unauthorized advertising or promotional materials concerning products or services, “junk mail,” “spam,” “chain letters,” “pyramid schemes,” or any other form of solicitation; or (l) uses the name or likeness of an identifiable natural person without such person’s consent. The burden of determining that any User Content is not protected by copyright, trademark, trade secret, right of publicity, or other proprietary right rests with you. You shall be solely liable for any damage resulting from any infringement of copyrights, trademarks, trade secrets, rights of publicity or other proprietary rights, or any other harm resulting from such a submission. Any person determined by SIMPLE BUSINESS GROUP, in its sole discretion, to have violated the intellectual property or other rights of others shall be barred from submitting or posting any further material on the Websites. You agree not to upload, post or otherwise transmit any User Content, software, or other materials which contain a virus or other harmful or disruptive component. You agree not to use any technology, service, or automated system to post more User Content than an individual could upload in a given time. You also agree not to direct any third party to use these services, technologies, or automated systems on your behalf. In our sole discretion, any conduct that we believe restricts or inhibits anyone else from using or enjoying the Websites will not be permitted. At our sole discretion, we reserve the right to remove or edit User Content submitted by you. We are not responsible for the accuracy or credibility of any User Content and do not take any responsibility or assume any liability for any actions you may take as a result of reading User Content posted on the Websites. Through your use of Interactive Areas, you may be exposed to content that you may find offensive, objectionable, harmful, inaccurate, or deceptive. There may also be risks of dealing with underage persons, people acting under false pretense, international trade issues, and foreign nationals. By using Interactive Areas, you assume all associated risks. We have the right, but not the obligation, to monitor User Content posted or uploaded to the Websites to determine compliance with these Terms and any operating rules established by us and to satisfy any law, regulation, or authorized government request. Although we have no obligation to monitor, screen, edit or remove any of the User Content posted or uploaded to the Websites, we reserve the right, and have absolute discretion, to screen, edit, refuse to post, or remove without notice any User Content posted or uploaded to the Websites at any time and for any reason, and you are solely responsible for creating backup copies of and replacing any User Content posted to the Websites at your sole cost and expense. The decision by SIMPLE BUSINESS GROUP to monitor and/or modify User Content does not constitute nor shall it be deemed to constitute any responsibility or liability in any manner on our part in connection with or to arise from your use of Interactive Areas on the Websites. By submitting User Content to the Websites and/or Discord Server, you automatically grant us a royalty-free, perpetual, irrevocable, non-exclusive, worldwide right and license to use, publish, reproduce, modify, adapt, edit, translate, create derivative works from, incorporate into other works, distribute, sublicense (through multiple tiers) and otherwise exploit such User Content (in whole or in part) in any form, media or technology now known or hereafter developed, without payment to you or to any third parties. Additionally, to the fullest extent permitted under applicable law, you waive your moral rights in the User Content and agree not to assert such rights against us. You represent and warrant to us that you have the full legal right, power, and authority to grant to us the license provided for herein, that you own or control the complete exhibition and other rights to the User Content you submitted for the purposes contemplated in this license and that neither the User Content nor the exercise of the rights granted herein shall violate these Terms, or infringe upon any rights, including the right of privacy or right of publicity, or constitute a libel or slander against, or violate any common law or any other right of, or cause injury to, any person or entity. You further grant to us the right, but not the obligation, to pursue at law any person or entity that violates your or our rights in the User Content by a breach of these Terms. User Conduct Guidelines. The following terms apply to your conduct when accessing or using the Websites: You agree not to interfere with or disrupt the Websites or the servers or networks connected to the Websites or disobey any requirements, procedures, policies, or regulations of networks connected to the Websites.You agree not to reproduce, duplicate, copy, sell, resell or exploit for any commercial purpose, any portion of the Websites, use of the Websites, or access to the Websites.You agree not to engage in any activity that would constitute a criminal offense or give rise to civil liability.You agree not to impersonate any person or entity, including, but not limited to, SIMPLE BUSINESS GROUP or any SIMPLE BUSINESS GROUP employee, or falsely state or otherwise misrepresent your affiliation with any person or entity.You agree not to interfere with any other user’s right to privacy, including by harvesting or collecting personally identifiable information about users of the Websites or posting private information about a third party. NO GUARANTEE OF RESULTS. We don’t guarantee results or offer legal and/or investment advice. Stock Trading and investing, in general, involve risk and hard work. Always consult with your professionals. Any testimonials showing our success or our students’ success are not to be interpreted as common, typical or expected. It takes education, drive, and hard work to reach your goals. LIABILITY DISCLAIMER. Stock Trading involves risk, and the Company is not responsible for any liability, loss, or damage as a result of the use of our training, resources, or products. As further described in these Terms of Use, you assume all risks associated with the application of our training, resources, or products. You agree that Company cannot be held responsible in any way for your results, or lack thereof. CONSULT PROFESSIONALS. We recommend that you always consult with your tax, legal and financial advisors before making any financial decisions. The company does not give investment advice or recommendations. Before making a financial decision, you are advised to consult with your tax, legal and financial advisors. GENERAL PROVISIONS Jurisdiction. This agreement is governed by and shall be construed under the laws of the State of Delaware without regard to its principles of conflicts of law. If a dispute arises under or relating to this agreement, the Site or the Materials, you agree to the exclusive jurisdiction of the federal and state courts located in the State of Delaware and waive any jurisdictional, venue, or inconvenient forum objections to such courts. The Site is controlled and operated by SIMPLE BUSINESS GROUP LLC from its principal office in Wilmington, Delaware, and is not intended to subject SIMPLE BUSINESS GROUP to the laws or jurisdiction or any state, country, or territory other than that of Delaware and the United States of America. If any provision of this agreement is found for any reason to be unlawful, void, or unenforceable, then that provision will be deemed severable from this agreement and will not affect the validity and enforceability of any remaining provision. Any heading, caption, or section title contained herein is inserted only as a matter of convenience and in no way defines or explains any section or provision hereof. A party’s failure to insist upon or enforce strict performance of any provision of this agreement shall not be construed as a waiver of any provision or right. This, together with any of our policies referred to herein, constitutes the entire agreement between you and SIMPLE BUSINESS GROUP relating to your use of the Site; this agreement supersedes any and all prior or contemporaneous written or oral agreements between you and SIMPLE BUSINESS GROUP regarding the same subject matter (except other written, fully-executed contracts between you and us). Neither the course of conduct between you and us nor trade practice shall act to modify any provision of this agreement. This agreement is not assignable, transferable, or sub-licensable by you except with our prior written consent. Account Status If your account is in arrears or not in good standing for any reason, then any special offers, flash sales, deals, bonuses, gifts with purchase, coupons, discounts, and incentives are not available for use. Again, be sure to return to these Terms periodically to review the most current version of the policy. We reserve the right at any time, at our sole discretion, to change or otherwise modify this policy without prior notice; however, the date of any effective changes shall be reflected at the bottom of this page, and upon request, we will provide you with information regarding any changes made. Electronic Communications: When you visit the website or send e-mails to us, you communicate with us electronically. You consent to receive communications from us electronically. We will communicate with you by e-mail or by posting notices on the website. You agree that all agreements, notices, disclosures, and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing. We may discontinue the website at any time and for any reason, without notice. We may change the contents, operation, or features of the website at any time for any reason, without notice. You agree that no joint venture, partnership, employment, or agency relationship exists between you and us as a result of these Terms of Use or your use of the website. Nothing contained in these Terms of Use is in derogation of our right to comply with governmental, court, and law enforcement requests or requirements relating to your use of the website or information provided to or gathered by us with respect to such use. A printed version of these Terms of Use and of any notice given in electronic form shall be admissible in judicial or administrative proceedings based upon or relating to these Terms of Use to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form. Our failure to enforce any provision of these Terms of Use or respond to a breach by you or others shall not constitute a waiver of our right to enforce any other provision of these Terms of Use as to that breach or any other. Suppose any provision of these Terms of Use is invalid or unenforceable under applicable law. In that case, the remaining provisions will continue in full force and effect, and the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision. These Terms of Use constitute the entire agreement between you and us regarding the website and supersedes any prior or contemporaneous agreement regarding that subject matter. By purchasing any item, product, or event from this website, you acknowledge and agree to be bound by the terms and conditions outlined in this Policy as well as the Terms of Purchase and Refund Policy and Privacy Policy. If you do not agree to these Policies, please do not purchase anything and don’t enter into any transaction with us. Be sure to return to these Terms periodically to review the most current version. We reserve the right at any time, at our sole discretion, to change or otherwise modify these Terms without prior notice; however, the date of any effective changes shall be reflected at the bottom of this page, and upon request, we will provide you with information regarding any changes made. This policy was last updated on July 13, 2021. × Privacy Policy 1. SIMPLE BUSINESS GROUP LLC (the “Company,” “we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy sets out how we collect, store, process, transfer, share, disclose and use data and personal information that identifies or is associated with you (“personal information”) and information regarding our use of cookies and similar technologies. 2. We collect personal information about our direct customers and, where our customer is a business or similar entity, we collect personal information about our customers’ employees, agents, and other representatives. These individuals about whom we collect personal information are referred to as “you” and “your” throughout this Privacy Policy. 3. The Company provides information and links that allow customers to browse, subscribe, and access sales copy pages, checkout pages, enrollment pages, advertisements, and other marketing messages (the “Services”) located at Simple.Trade or any other websites operating by SIMPLE BUSINESS GROUP LLC, its subsidiaries, or affiliates (together known as our “Websites”). 4. This Privacy Policy applies to our websites and services. Before accessing our websites or using the services, please ensure that you have read and understood this Privacy Policy. 5. By submitting your personal information to the company, you consent to collecting, using, storing, processing, and disclosing your personal information under this Privacy Policy. If you do not consent to collecting, using, and disclosing your personal information under this Privacy Policy, please do not provide any personal information to the company. 6. This Privacy Policy does not cover third-party websites, services, applications, or payment gateways and payment transaction processes that may be accessed via our websites. We accept no responsibility or liability in respect of third-party websites. Please check the privacy policies published on any third-party websites which you may access through our websites before submitting your personal information to them. PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT 7. We collect personal information about you when you voluntarily submit information directly to us when you access our websites or use the services. This can include information you provide to us when you register for an account, fill in a form, correspond with us via our websites, social media account, phone, email or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, respond to surveys or use some other feature of the services as available, from time to time. 8. In general, personal information may include but is not limited to, your name, date of birth, financial information, home address, phone number, IP address, location data, weblogs, date, time, browser used, referring web addresses, other communication data, searches conducted, and pages visited, and other details such as your occupation and title. 9. Certain services can only be offered to you if you provide personal information to the company. Accordingly, the company may not be able to offer you the services if you choose not to provide it with the required personal information. 10. Annex 1 attached hereto sets out the categories of personal information we collect about you and the purposes for which we collect and use your personal information. The table also lists the legal basis we rely on to process the personal information, the categories of recipients to whom we may lawfully disclose the personal information, and details on how we determine applicable retention periods regarding the personal information we collect about you. 11. We also automatically collect personal information about you indirectly about how you access and use the services and information about the device you use to access the services. We may link or combine the personally identifiable personal information we collect about you directly and the information we collect indirectly. This allows us to provide you with a personalized experience regardless of how you interact with us. 12. The Company strives to limit the amount of personal information we collect to such personal information that is necessary and appropriate for the purposes identified in Annex 1 attached hereto. The company will not use or disclose your personal information for purposes other than those for which it was collected, except with your consent or as permitted or required by applicable law. 13. We may anonymize and aggregate any of the personal information we collect, including information about individuals that are your subscribers, websites visitors, or customers (so that it does not directly identify you or them). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving the services, and developing new products and features. We may also share such anonymized information with third parties. CUSTOMER DATA WE MAY COLLECT THROUGH THE PROVISION OF OUR SERVICES 14. During the provision of the services, we may also collect personal information about individuals that are subscribers, websites visitors, or customers of our customers (the “Customer Data”). 15. By submitting or causing to be submitted Customer Data to us, you hereby grant, and represent and warrant that you have all rights necessary to grant all rights and licenses to the Customer Data required for the Company and its subcontractors and service providers to provide the services. Suppose the Company shares or publicly discloses information (including in marketing materials or in application development) that is derived from Customer Data. In that case, such data will, to a commercially reasonable extent, be aggregated or anonymized to reasonably avoid identification of a specific individual. You further agree that the company will have the indefinite right to use, store, transmit, distribute, modify, copy, display, sublicense, and create derivative works of the above mentioned anonymized, aggregated data. 16. In connection with Customer Data, you hereby represent, warrant and agree that: (a) you have obtained or will obtain the Customer Data lawfully and/or have not engaged in material misrepresentation, deception or other fraudulent or improper means to cause the Customer Data to be collected by the company; (b) the Customer Data does not and will not violate any applicable laws or any person or entity’s proprietary or intellectual property rights; (c) all Customer Data has and will be collected by you in accordance with a privacy policy that permits the company to collect, use, and disclose such Customer Data as contemplated under and in accordance with, this Privacy Policy, and if required by applicable law, pursuant to consents obtained by you to do each of the foregoing; (d) you are solely responsible for ensuring compliance with all privacy laws in all jurisdictions that may apply to Customer Data; (e) the company may exercise the rights in Customer Data granted hereunder without liability or cost to any third party; and (f) the Customer Data complies with this Privacy Policy. For purposes of clarity, we take no responsibility and assume no liability for any Customer Data, and you will be solely responsible for Customer Data and the consequences of collecting or sharing it hereunder. You may not submit, or cause to be submitted, any Customer Data that includes a social security number, passport number, driver’s license number, or similar identifier, credit card or debit card number, employment, financial or health information, or any other information which may be subject to specific data privacy and security laws. 17. In the event that Customer Data is disclosed to or accessed by an unauthorized party, the company will promptly notify you and use reasonable efforts to cooperate with your investigation of the incident. In the event we have a reasonable, good faith belief that an unauthorized party has accessed Customer Data, we will promptly notify you and will use reasonable efforts to cooperate with your investigation of the incident. Suppose such incident triggers any third-party notice requirements. In that case, you (not the company) shall be solely responsible for the timing, content, cost, and method of any such notice and compliance with applicable laws. You (not the company) bear sole responsibility for adequate security, protection, and backup of Customer Data when in your or your representatives’ or agents’ possession or control. We are not responsible, and you are fully responsible for what your authorized Users do with Customer Data. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION 18. We implement commercially reasonable physical, technical and organizational security safeguard measures to preserve and protect the integrity and security of your personal information against accidental or unlawful destruction, loss, change, or damage. All personal information we collect will be stored on secure servers. All electronic transactions entered into via our websites will be protected by SSL encryption technology. Where you register for an account on the services, you are responsible for maintaining your account’s security, including by implementing “strong” passwords, as more specifically explained in our Terms of Service. We cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use your personal information for improper purposes. You acknowledge that you provide your personal information at your own risk. 19. We do not sell or rent your personal information to non-affiliated third parties except as permitted by law or as outlined within this Privacy Policy. However, in the event of a sale of all or substantially all of our business or another similar transaction, we may transfer or disclose your personal information to a purchaser or prospective purchaser, who may collect, use and disclose such information to evaluate the proposed transaction or operate and manage the affairs of the acquired business, or for other purposes identified in this Privacy Policy. 20. The personal information we collect may be transferred to and stored, and processed in countries outside of the jurisdiction you are in, depending on where our third-party service providers and we have operations. If you are located in the European Union (“EU”), your personal information will be processed outside of the EU, including in the United States; these international transfers of your personal information are necessary for the performance of our agreement with you in order to provide the services. General Data Privacy Regulation (GDPR) 21. The GDPR takes effect on May 25, 2018, and is intended to protect the data of European Union (EU) citizens. As a company that markets its site, content, products, and/or services online, we do not specifically target our marketing to the EU or conduct business in or to the EU in any meaningful way. If the data you provide to us during your use of our site, content, products, and/or services is governed by GDPR, we will abide by the relevant portions of the regulation. If you are a resident of the European Economic Area (EEA) or are accessing this site from within the EEA, you may have the right to request access to, correction of, deletion of; portability of; and restriction or objection to processing, of your personal data, from us. This includes the “right to be forgotten.” To make any of these requests, please contact our GDPR contact at [email protected] 22. To the extent we employ third-party service providers to store, handle or process personal information on our behalfs, such as data processing or office services, we will use contractual and other means to provide an appropriate level of protection while the information is being stored, handled or processed by them. 23. We are not liable for any security incident that may result in loss, disclosure, or alteration of your personal information. Further, the submission of information via the internet is never entirely secure. We cannot guarantee the security of information you submit while it is in transit over the internet. Any submission of personal information is at your own risk. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA 24. You have certain rights in respect of your personal information that we hold under certain applicable privacy laws: a. Right of access and portability. The right to obtain access to and to receive your personal information. b. right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete. c. right to erasure. The right to obtain the erasure of your personal information from our websites without undue delay in certain circumstances, such as where the personal information is no longer necessary concerning the purposes for which it was collected or processed. d. Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information. e. Right to object. The right to object, on grounds relating to your particular situation, to the processing of your personal information, and to object to the processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing. 25. If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy. 26. You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. COOKIES AND SIMILAR TECHNOLOGIES 27. When you use our services, read our emails, use our websites or otherwise engage with us through a computer or mobile device, we and our third-party service providers, automatically collect information about you, the device you use to access the services and track your preferences and activities on our websites. We use this information to enhance and personalize your user experience, monitor and improve our websites and services, and other internal purposes. 28. We typically collect this information through various tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”). We may combine this information with other personal information we collect directly from you. 29. Our websites use cookies to distinguish you from other users of our websites. Cookies are pieces of code that allow for the personalization of our websites by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your device’s hard disk (such as your computer or smartphone) for record-keeping purposes. 30. We use the following types of cookies: a. Strictly necessary cookies. These are cookies required for the essential operation of our websites, such as authenticating users and preventing fraudulent use. b. Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our websites when they are using it. This helps us improve the way our websites work, for example, by ensuring that users find what they are looking for easily, and helps us understand what interests our users have and measures how effective our content is. c. Functionality cookies. These are used to recognize you when you return to our websites. This enables us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region). These cookies may be set by third-party providers whose services we have added to our pages. d. Targeting cookies. These cookies record your visit to our websites, the pages you have visited, and the links you have followed. We will use this information to make our websites and the advertising displayed on them more relevant to your interests. We may also share this information with third parties for this purpose. 31. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the services and understand more about our users’ demographics. You can learn more about Google’s practices at https://policies.google.com/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout. 32. We may also work with third-party partners to employ technologies, including applying statistical modeling tools, allowing us to recognize and contact you across multiple devices. 33. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time. 34. The cookies we use are designed to help you get the most from our websites, but if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse cookies, you may not be able to use the full functionality of our websites. These settings will typically be found in your browser’s “options” or “preferences” menu. In order to understand these settings, the following links may be helpful; otherwise, you should refer to your browser instructions or help screen to learn more about these functions. ○ Cookie settings in Internet Explorer ○ Cookie settings in Firefox ○ Cookie settings in Chrome ○ Cookie settings in Safari web and iOS 35. Deleting cookies does not delete non-cookie technologies such as Local Storage Objects (LSOs) such as Flash objects and HTML5. You can learn more about Flash objects – including how to manage privacy and storage settings for Flash cookies – on Adobe’s website or by clicking here. Various browsers may offer their own management tools for removing HTML5 LSOs. For more information about cookies and how to disable cookies, visit http://www.allaboutcookies.org. 36. When we send emails to our contact lists, it will sometimes track who opened the emails and who clicked the links to measure email campaigns’ performance. To do this, we may include single-pixel gifs, also called web beacons, in emails it sends. Web beacons allow us to collect information about when you open the email, your IP address, browser or email client type, and other similar details. 37. We may also use the capability to track when a URL has been clicked inside an email message sent by its system. The company uses this functionality to track which links were clicked and in what quantity and the aggregate number of links clicked. This click tracking functionality does not collect any personal information. MARKETING AND ADVERTISING 38. From time to time, we may contact you with relevant information about the services. We may use the personal information we collect about you to help us determine the most relevant information to share with you. Most messages will be sent by email. 39. If you do not want to receive such messages from us, you may opt-out by clicking on the unsubscribe link at the bottom of our emails. You are not permitted to unsubscribe or opt-out of non-promotional messages regarding your account, such as account verification, changes, updates to features of the services, or technical or security notices. THIRD-PARTY DATA COLLECTION AND INTEREST-BASED ADVERTISING 40. We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your browsing history. We permit third-party online advertising networks, social media companies, and other third-party services to collect information about your use of our websites and mobile apps over time so that they may play or display ads on our websites, apps or other services and other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, and other information. We may share a common account identifier (such as an email address or user ID) with our third-party advertising partners to help identify you across devices. 41. Our third-party partners and we use this information to make the advertisements you see online more relevant to your interests and provide advertising-related services such as reporting, attribution, analytics, and market research. 42. To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s (“NAI”) online resources, at https://www.comworkadvertising.org/choices, the Direct Advertising Alliance’s (“DAA”) resources at www.aboutads.info/choices and/or Your Online Choices at https://www.youronlinechoices.com/uk. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (“Android”). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting https://youradchoices.com/appchoices and downloading the mobile AppChoices app. 43. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s or Your Online Choices online resources will only opt-out a user from receiving interest-based ads on that specific browser or device. However, the user may still receive interest-based ads on their other devices. You must perform the opt-out on each browser or device you use. 44. Furthermore, some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again. CONSENT 45. To the extent possible, we will obtain express consent to collect, use and disclose personal information about an individual directly from such individual. However, depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism), or express. Suppose you provide personal information concerning another individual to us. In that case, you represent that, before submitting such information, you have obtained the necessary consent or authority to permit the company to collect, use and disclose such personal information for the purposes set out in the Privacy Policy, or the collection, use, and disclosure is permitted by applicable law. 46. You may withdraw your consent to the use and disclosure of your personal information or opt-out of certain uses and disclosures. To contact us about withdrawing consent or opting out, please contact us using the contact details at the end of this Privacy Policy. LINKS TO THIRD PARTY SITES 47. Our websites may, from time to time, contain links to and from third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies, that we do not accept any responsibility or liability for their policies, and you release us of any responsibility for the actions, practices, and omissions of third parties. Please check the individual policies before you submit any personal information to those websites. OUR POLICY TOWARDS CHILDREN 48. Our websites may be used only by persons who are at least the age of majority under applicable law and are legally capable of entering into a binding contract and consenting to the processing of their personal data. Our websites and the services may not be used by persons in jurisdictions where access to or use of our websites and the services or any part of them may be illegal or prohibited. Our websites will only be used for lawful purposes and not for any unauthorized purpose or in contravention of any applicable law or regulation. 49. We do not knowingly collect any personal information from children under the age of majority. Those under the age of majority should not use the websites or provide the company with any personal information. The company encourages parents and legal guardians to monitor their children’s Internet usage, and if you have reasons to believe that a child under the age of majority has provided personal information to us, please email us at [email protected]. CHANGES TO THIS POLICY 50. We may update this Privacy Policy from time to time, and so you should review this page periodically. When we change this Privacy Policy materially, we will update the “last modified” date at the end of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on our websites. NOTICE TO YOU 51. If we need to provide you with information about something, whether for legal, marketing, or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our websites. The fact that we may send notices to you will not stop you from being able to opt-out of certain types of contact as described in this Privacy Policy. CONTACTING US 52. Regardless of your location, any questions, comments, and requests regarding this Privacy Policy are welcome and should be addressed to [email protected]. This Privacy Policy was last modified on July 13, 2021. ANNEX 1 – PERSONAL INFORMATION WE COLLECT WHEN YOU USE THE SERVICE CATEGORIES OF PERSONAL INFORMATION 1. CONTACT INFORMATION AND BASIC PERSONAL DETAILS For example: your full name, phone number, postal address, email address, zip code.How we use it. We use this information to:communicate with you, including sending statements and invoices, communications, news, alerts, and marketing communications;deal with inquiries and complaints made by or about you relating to the services;authentication purposes; andCreate customer accounts and operate, maintain and provide to you the features and functionality of the services.Legal basis for the processing. The processing is necessary for:the performance of a contract and to take steps before entering into a contract;our legitimate interests, namely administering the services, for marketing purposes and communicating with users; and to comply with certain legal obligations; andTo comply with certain legal obligations. 2. WEBSITES, BUSINESS AND MARKETING INFORMATION For example: company websites, IP address, current email list size, e-commerce software in use, email marketing software, product usage information, demographic data, data about customer’s 3rd party services, other business information (Facebook ad spend, the status of business, industry, business goals).How we use it. We use this information to:operate, maintain and provide to you the features and functionality of the services;provide you with services to deal with any requests or inquiries you may have and to carry out the company’s obligations arising from any contracts it has entered into with you;ensure that content is presented in the most effective manner; anddetermine relevant advertising/marketing activities.Legal basis for the processing. The processing is necessary for:the performance of a contract and to take steps before entering into a contract; andour legitimate interests, namely administering the services and for marketing purposes. 3. PAYMENT INFORMATION For example: your credit card information, account information, billing address, shipping address, and related information.How we use it. We use this information to facilitate payment for the use of the services and to detect and prevent fraud.Legal basis for the processing. The processing is necessary for the performance of our contract with you and our legitimate interests, namely the detection and prevention of fraud. 4. CORRESPONDENCE AND COMMENTS For example: comments recorded when you contact us directly, e.g., by email, phone, mail, when you post on message boards, blogs, or complete an online form or provide quality survey input.How we use it. To address your questions, issues, and concerns and improve the services, determine products and services that may be of interest to you and send you news, alerts, and marketing communications according to your marketing preferences.Legal basis for the processing. The processing is necessary for our legitimate interests, namely communicating with users and for marketing purposes. 5. ALL PERSONAL INFORMATION SET OUT ABOVE How we use it. We will use all the personal information we collect to prevent and detect fraud, to operate, maintain and provide to you the features and functionality of the services, to communicate with you, to monitor and improve the services, our websites, and business, and to help us develop new products and services.Legal basis for the processing. The processing is necessary for our legitimate interest, namely administering and improving the services, our website, and our business and developing new services. CATEGORIES OF POTENTIAL RECIPIENTS OF DISCLOSED PERSONAL INFORMATION 6. CATEGORIES OF POTENTIAL RECIPIENTS OF DISCLOSED PERSONAL INFORMATION As required under the uses of personal information outlined above, we may share and disclose your personal information with the following categories of recipients: Group of companies. Personal information may be disclosed to any member of our group of companies (this means our subsidiaries, our ultimate holding company, and all its subsidiaries) insofar as reasonably necessary for the purposes and legal basis set out in this policy.Service providers and advisors. Personal information may be disclosed to third-party vendors and other service providers that perform services for us, on our behalf, which may include providing mailing or email services, tax, and accounting services, payments processing, data enhancement services, fraud prevention, web hosting, or providing analytic services. Your personal information is never transferred to any third party for the purposes of re-marketing to you.Partners. We may disclose your personal information to partners of the company, so that they can communicate with you (whether by email, post or otherwise) and provide you with promotional materials and additional information about their products, services, contests, promotions, and special offers that may be of interest to you, or and use that information subject to and for other purposes contemplated by this policy.Purchasers and third parties in connection with a business transaction. Personal information may be disclosed to third parties connected with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control, or acquisition of all or a portion of our business.Law enforcement, regulators, and other parties for legal reasons. Personal information may be disclosed to a government or regulatory entity that has asserted its lawful authority to obtain the information or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) enforce our Terms of Service or to protect the security or integrity of our services or websites; and/or (c) exercise or protect the rights, property, or personal safety of the company, our customers or others. 7. RETENTION PERIOD We retain personal information for no longer than is necessary for the purposes set out above and under our legal obligations and legitimate business interests. ×