Privacy Policy Last Updated: August 23, 2018 The Suretly (the “Suretly,” “we,” “us,” and “our”) is committed to treating your personal information with respect and sensitivity. This privacy policy (this “Privacy Policy”) explains how we may collect, store, use, and disclose personal information when you access or use (1) our website and all of our other websites to which this Privacy Policy is posted (collectively, the “Website”) and (2) any services, content, and features made available by us through the Website or the Programs (together with the Website and the Programs, the “Services”). YOUR ACCEPTANCE OF THIS PRIVACY POLICY By accessing or using the Services, you consent to our collection, storage, use, and disclosure of your information as described in this Privacy Policy. The provisions contained in this Privacy Policy supersede all previous notices and statements regarding our privacy practices with respect to the Services. If you do not agree to every provision of this Privacy Policy, you may not access or use the Services. We may revise this Privacy Policy from time to time in our sole discretion, subject to applicable law. When we revise this Privacy Policy, we will post a revised version on the Website. The revised Privacy Policy will be effective upon posting on the Website, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for your continued access and use of the Services. If you do not agree to this Privacy Policy or any revised version of this Privacy Policy, your sole recourse is to terminate your access and use of the Services. Except as otherwise expressly stated by us, your access and use of the Services are subject to the version of this Privacy Policy in effect at the time of your access or use of the Services. TYPES OF INFORMATION WE COLLECT When you use the Services, we may collect information that allows you to be identified (“Personal Data”), and we may also collect information that does not identify you (“Anonymous Information”). When Anonymous Information is, directly or indirectly, associated or combined with Personal Data, such Anonymous Information will be considered Personal Data for purposes of this Privacy Policy. In addition, to the extent Internet Protocol (“IP”) addresses or similar identifiers or information are considered personally identifiable information by applicable law, we will treat such identifiers and information as Personal Data under this Privacy Policy. Information You Provide to Us In general, you may visit the Website without telling us who you are or sharing any Personal Data with us. When you register for an account for the Services (an “Account”), use other aspects of the Services, or communicate with us for customer service or technical support for the Services, we may ask you to provide certain Personal Data, such as your name, email address, postal address or telephone number, date of birth, gender, and ethnicity. You may also have the opportunity to voluntarily provide additional Personal Data to us, such as information pertaining to your educational background or personal and professional goals, or other biographical information, which may or may not be associated with your Account. We may ask you whether you want to receive autodialed and prerecorded message calls and/or text messages relating to the Services. If you consent to such use of your phone number for these purposes, you may, if permissible under applicable laws and regulations, receive autodialed and prerecorded message calls and/or text messages from us, as applicable, relating to the Services, at that number. Information Collected From Devices When you access the Services using a computer or mobile device, including a desktop computer, laptop, mobile phone, tablet, smartwatch or other consumer electronic device (each, a “Device”), we may collect information from your Device, such as your Device type and manufacturer, your mobile carrier, your device software version, your Device identifiers, your mobile phone number, your IP address, your browser type, your network connection type, information about the webpage that referred you to the Website or that you visited prior to the Website, and your behavior and activity on the Website. Your behavior and activity on the Website may include the amount of time you spend using the Services and your login and log out times. Information Collected From Cookies and Similar Technologies When you access or use the Services, we may place small data files on your Device that assign random, unique numbers to your Device to enable us to recognize your Device when you use the Services. These data files may be cookies, pixel tags, other local shared objects, or similar technologies provided by your browser or associated applications (collectively, “Cookies”). We may use Cookies to recognize your Device, manage and store your settings and preferences for the Services, improve the Services, offer targeted products and services to you, and collect and analyze information about your use of the Services. The Cookies we use in connection with the Services may include the following: HOW WE USE INFORMATION We may use Anonymous Information as described elsewhere in this Privacy Policy and for research and commercial purposes, such as to improve the Services. We may use Personal Data for the purposes described elsewhere in this Privacy Policy and internally for our general commercial purposes, including, among other things, to: We may use Personal Data in other ways that we expressly disclose at the time you provide it. We do not use your Personal Data to make automated decisions about you without any human input. In we ever begin to do so, if and as applicable, and to the extent required by applicable law, we will endeavor to implement suitable safeguards, including, for example, an opportunity for you to request human intervention, express your point of view, contest any decisions made, and request that we restrict the use of your personal data for the purposes of these automated decisions. HOW WE SHARE INFORMATION We may share Anonymous Information with third parties as described elsewhere in this Privacy Policy and for our commercial purposes. We may share Personal Data for the purposes described elsewhere in this Privacy Policy and as follows: YOUR RIGHTS AND CHOICES ABOUT YOUR PERSONAL DATA You may opt not to receive promotional emails from us by contacting us as indicated below or by following the “unsubscribe” instructions in any promotional email you receive from us. Please note, however, that we may still send you non-promotional emails about your relationship with us. You have the right to: (i) request confirmation of whether we store, use or share any of your personal data; (ii) obtain access to or a copy of your personal data; (iii) receive an electronic copy of personal data that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your personal data or object to those uses; (v) seek correction of inaccurate, untrue or incomplete personal data; or (vi) request erasure of personal data held about you by us, subject to certain exceptions prescribed by law. Where we are relying on consent to process your personal data, you have the right to withdraw that consent at any time. However, withdrawing consent will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you would like to exercise any of these rights, please contact us at the email or physical address set out below. You will not have to pay a fee to exercise any of these rights. HOW WE PROTECT YOUR PERSONAL DATA We have, and require our third-party service providers to have, administrative, technical, and physical safeguards in place in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, and alteration. The measures we utilize may include storing Personal Data on secured servers, transmitting Personal Data using encryption technologies, and auditing and reviewing our data collection practices. No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Data. You also play a role in protecting your Personal Data. Please safeguard your username and password for your Account and do not share them with others. If we receive instructions using your Account login information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your Account or any other breach of security related to the Services. We reserve the right, in our sole discretion, to refuse to provide the Services, terminate your Account, and to remove or edit content. PROTECTING CHILDREN'S PRIVACY The Services are not directed, or intended to be attractive, to children younger than 13 years old. We do not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, do not use the Services or submit any information to us. THIRD-PARTY LINKS When you use the Services, you may be directed to other websites and applications that are beyond our control. We may also allow third-party websites or applications to link to the Services. We are not responsible for the privacy practices of any third parties or the content of linked websites and applications, but we do encourage you to read the applicable privacy policies and terms and conditions of such parties, websites, and applications. This Privacy Policy only applies to the Services. INTERNATIONAL TRANSFERS Your Personal Data may be stored on computers and systems in the United States and other countries. By using the Services, you consent to the collection, transfer, processing, and storage of your Personal Data in such countries in the manner described in this Privacy Policy. You also acknowledge that the privacy laws of such countries may differ from the laws in the country where you are located and may not provide you the same rights or protections for your Personal Data. When we transfer personal data outside of the European Union or EFTA States, we ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country’s data protection laws, contractual obligations placed on the recipient of the data (model clauses may be requested by inquiry as described below), or EU-US and Swiss-US Privacy Shield principles. We have appointed a data protection officer who is responsible for overseeing questions related to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below. SURETLY, LLC. OGRN: 1175476087016 Address: 22, Krasniy prospect, 2th floor, Novosibirsk, Russia, 630007 [email protected]