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Privacy Notice

Last updated: July 12, 2018.

This Notice provides information about data we collect, use, and share, and our commitment to using the Personal Information that we collect in a respectful fashion.

OVERVIEW

You expressly consent to the collection, use and disclosure of your information in accordance with this Privacy Notice by clicking the “I accept” box upon creating your account with us or by otherwise accessing or the Services.

Exochain, PBC and our affiliates with whom you have a business relationship (“Exochain”, “we”, “us”) care about your privacy, security, and online safety. This Privacy Notice (“Notice”) is designed to inform you about how we collect, use, and share users’ of our products and services (“you”, “your”) data that could be used to identify a particular individual (“Personal Information”).

This Privacy Notice details our practices regarding the personal information we obtain from individuals through our websites, products, services, web-based, mobile, and other applications, and media channels (collectively, the “Services”).

When you access or use our Services, you acknowledge that you have read this Notice and understand its contents. Your use of our Services and any dispute over privacy is subject to this Notice and our Terms of Service (including any applicable limitations on damages and the resolution of disputes).

We may update this Notice, or other privacy notices that we establish for individual products, at any time. We will alert you about any changes by posting the updated version of this Privacy Notice on our Site. Any changes or modifications will be effective immediately upon such posting and you hereby waive the right to receive specific notice of each such update. You are encouraged to periodically review this Privacy Notice to stay informed of any updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Notice by your continued use of the Services after the date such revised Privacy Notice is posted.

DATA TRANSFERS

Our headquarters are in the United States, and we operate there as well as in other countries; either through our own subsidiaries or third-parties. Therefore, we, ourselves of via third-parties, may transfer your Personal Information to, or process or gain access to it from, jurisdictions that may not provide the same level of protections as your home jurisdiction. However, we undertake industry standard measures to try to ensure that your Personal Information receives an adequate level of protection in such jurisdictions. If your Personal Information is being transferred from the European Economic Area or Switzerland, we provide adequate protection for the transfer of Personal Information to countries outside of the EEA or Switzerland through a series of intercompany agreements based on the Standard Contractual Clauses authorized under the EU Data Protection Directive 95/46/EC.

You may contact our Data Privacy Officer at:

COLLECTION OF YOUR INFORMATION

Why Do We Collect Your Information?

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, collected data about you via the Services to:

What Personal Information Do We Collect?

The Personal Information we may collect through the Services includes:

How Do We Collect Information?

We may collect information that is provided automatically from your use of the Services, from certain third-parties, or that you provide.

Information Provided Automatically: We may use cookies, web beacons, tracking pixels, and other tracking technologies (collectively "Cookies") on the Services to help customize the Services and improve your experience. By using the Services, you agree our use of such Cookies. We may also partner with selected third-party vendors, such as Google Analytics, and CrazyEgg, to allow tracking technologies and remarketing services on the Services by first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Services, determine the popularity of certain content and better understand online activity. By accessing the Services or any portion thereof, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions, we have provided direct links to the applicable privacy policies above. We do not transfer personal information to these third-party vendors.

You should be aware that getting a new computer or device, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

Information from Other Third-Parties: We may collect information (e.g. page view, search term and search result information, etc.) about you from other third-parties such as from a list of subscribers to a third-party publication.

Information That You Provide: The information that you provide directly to us generally consists of your contact details, billing data, customer service queries, reviews, or survey and questionnaire responses. Except for certain minimum data (e.g. your name and e-mail address) which is required to establish your account on the Services, you are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Services.

USE AND DISCLOSURE OF YOUR INFORMATION

How Do We Use Your Information?

We may use your Personal Information to protect you from security and other risks and our own business purposes such as:

When Do We Share Personal Information?

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

By Law or to Protect Rights. If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

Marketing Communications. With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by applicable law.

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

Business Partners. We may share your information with our business partners, including the developer of third-party software applications that you are using in conjunction with our products to offer you certain products, services, or promotions. You are encouraged to review the applicable supplier’s privacy policy and contact them directly for responses to your question.

Social Media Contacts. If you connect to the Services through a social network, your contacts on the social network may see your name, profile photo, and descriptions of your activity.

Sale or Bankruptcy. If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur, and that the transferee will then be solely responsible for any commitments we make in this Privacy Notice.

Anonymous Data. While we would never disclose your personally identifiable information to any third-party without your express consent, except as provided for in this Privacy Notice, we reserve the right to use any aggregated statistical or other such data, which is transmitted and stored separately from any of your Personal Information and cannot be reasonably used to identify you (“Anonymous Data”), collected and/or aggregated for any purpose and disclose, share, or otherwise transfer Anonymous Data to third parties, including via the license or sale thereof, at its sole and absolute discretion. By accepting the terms and conditions of this Privacy Notice, you are expressly consenting to such sharing, disclosure, or transfer.

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from our systems.

Please Note. We are not responsible for the actions of third-parties with whom you share personal or sensitive information, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails, or other communications from third-parties, you are responsible for contacting the third party directly.

THIRD-PARTY WEBSITES

The Services may contain links to third-party websites and applications of interest including advertisements, website analytics providers, social network sites, and other external services, that are not affiliated with us. Once you have used these links to leave the Services, this Privacy Notice does not cover any information you provide to these third-parties, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Services.

SECURITY OF YOUR INFORMATION

We use a variety of industry standard administrative, technical, and physical security measures to help protect your personal information. We also require you to enter a password to access your account information. It is your responsibility to safeguard your password and other login credentials, please do not disclose your account password to unauthorized people. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

YOUR CHOICES REGARDING YOUR INFORMATION

Account Information. You may at any time review or change the information in your account by Logging into your account settings and updating your information.

You may at any time terminate your account by:

Emails and Communications. If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:

DATA RETENTION

Notwithstanding the “Your Choices” section above, the time periods for which we retain your Personal Information may vary dependent upon the reason for its collection and use. Generally, we will retain Personal Information: (i) for as long as you are using our products or services; or (ii) for as long as we have a legitimate business purpose (such as those described in the “How Do We Use Personal Information” section above), but we will do so only as is necessary to meet our legitimate business needs and obligations or as permitted by applicable law. The information we collect may be stored and processed in servers in the United States and wherever we and our service providers have facilities around the globe.

POLICY FOR CHILDREN

We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.

CONTACT US

If you have questions or comments about this Privacy Notice or otherwise need to contact us, please contact us at:

Legal Department

Exochain PBC

5 Bragdon Lane, Suite 4

Kennebunk, ME 04043 - USA

legal@exochain.com

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