RAEDEN, INC.

PRIVACY NOTICE

Effective Date: July 1, 2022

At Raeden, maintaining the trust of our online users is of the utmost importance to us. Therefore, we have developed this Privacy Notice (the “Notice”) to show our commitment to fair information practices and the protection of our users’ privacy, and to explain how we collect, process, use and share information about our users. This Notice applies only to information we collect, process, and use through (1) our company website, Raeden.com, (2) to all other websites that are owned or operated by Raeden, Inc. or its subsidiaries (referred to collectively herein as “Raeden”, (“our”, “us”, or “we”) that have this Notice posted, including any software hosted on any such websites (collectively, the “Site” or “Sites”), and (3) any other interactions (e.g., customer support inquiries, etc.) you may have with Raeden. For purposes of this Notice, Personal Data shall mean any information relating to an identified or identifiable natural person.

This Notice does not apply to any third party applications or technology that integrate with the Sites, or any other third party products, services, or businesses (“Third-Party Services”). While using the Sites, you may be directed to a third party website via links or other references, which may take you to that third party website (“Third-Party Websites”). This Notice does not apply to any data collected from or provided by you to Third Party Websites. You should review such Third-Party Services’ or Third-Party Websites’ privacy policy (and such other terms and conditions) to determine how your data will be used before sharing any Personal Data (as defined below).

NOTICE TO END USERS

By visiting, accessing, or using the Sites, or interacting with any aspect of our business, you accept the terms of this Privacy Notice and expressly consent to our collection, use, and disclosure of data, including Personal Data, provided to or otherwise received by us for the purposes and in the manner described in this Privacy Policy and the applicable Client Agreement.

A separate agreement, if applicable, governs the delivery, access, and use of our platform or software available on the Sites (the “Client Agreement”), including the processing of any “Client Data,” which is defined in the applicable Client Agreement but generally includes all data, files, messages, content, or information that Client and/or Authorized Users transmit, upload, transfer, process, store, or submit on or through the Sites. The organization (e.g., your employer or another entity or person) that entered into the Client Agreement (“Client”) controls their instance of the platform on the Sites (their “Platform”) and any associated Client Data. Client, and individuals who have been authorized by Client, who access or use the Sites via their Platform (e.g., Client’s employees, managers, and administrators) are “Authorized Users”. Your use of the Sites may be subject to your Client’s (e.g. your employer’s) policies, if any. If you have any questions about your specific Platform settings and privacy practices, please contact the Client with whom you have a direct relationship and whose Platform you use. We are not responsible for the privacy or security practices of our Clients, which may differ from those set forth in this Notice.

WHAT WE COLLECT

Sometimes you provide us with data and sometimes data about you is collected automatically. To the extent data is associated with an identified or identifiable natural person and is protected as personal data or personal information under applicable data protection and privacy laws, it is referred to in this Notice as “Personal Data”. You acknowledge and agree we may collect, process, store, access, and disclose Personal Data disclosed by you or the Client you are associated with (e.g., your employer) to facilitate the provision of the Sites and related services in the manner described in this Notice and the applicable Client Agreement.

We get information about you in a range of ways:

Information You Give Us. We collect information about you to provide our services. In order for us to best provide our services, we may collect your‎ name, postal address, email address, phone number, fax number, username, password, demographic information (such as your gender and occupation) as well as any other information you may elect to give to us directly in connection with your use of our Sites or related services. Depending on how you interact with the Sites, the Personal Data we collect from you may vary. We retain the Personal Data you provide unless or until you request that we delete it.

Information We Get From Others. We may get information about you from other sources, such as your employer, or publicly available information. We may add this to information you have given to us via the Sites.

Information Automatically Collected. When you use the Sites, your device is automatically providing information to us so we can respond and customize our services to you. The type of information we collect by automated means generally includes technical information about your computer, such as your IP address or other device identifier, the type of device you use, and operating system version. Therefore, we may automatically log information about you and your computer. For example, when visiting a Site, we may log your computer operating system type, browser type, browser language, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site.

Sync Data. We may make tools available to integrate data from Third-Party Services used by Clients into the Sites (“Sync Data”). For example, Client may integrate its Platform instance with an instance from another of Client’s data hosts. When the Services are integrated with a Third-Party Service for Sync Data, we will receive all data selected by the Client to sync with the Services.

Cookies. We may log information using “cookies.” Cookies are small data files stored on your computer or mobile device that relate to a website you have visited or used. We may use both session cookies (which are stored in temporary memory, are not retained after a browsing session ends, and do not collect information from a user’s device) and persistent cookies (which remain in a browser’s sub-folder after the user closes their browser, are activated again once the user visits the online location that created the particular cookie, and remain for the duration period set within the cookie’s file or until deleted) to provide you with a more personal and interactive experience on our Sites. Cookies may help make the Site more useful to you and tailor the experience with us to meet your special interests and needs.

Promotions, advertisements, or other third-party content displayed on the Sites may also contain cookies, and Raeden does not have access to or control over information collected by outside advertisers when a user clicks on any such promotions or advertisements.

You can typically remove and reject cookies from our Site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Site works for you.

Pixel Tags. “Pixel Tags” are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, Pixel Tags are embedded invisibly on web pages. We may use Pixel Tags (also referred to as web beacons or clear GIFs), in connection with our services to, among other things, track the activities of users of our services, help us manage content, and compile statistics about usage of our services. We and our third-party service providers may also use Pixel Tags in HTML emails to our customers, to help us track email response rates, to identify when our emails are viewed, and to track whether our emails are forwarded.

Do Not Track. Raeden understands that some users may have enabled a “do not track” feature or other mechanism intended to provide consumers with a choice regarding the collection of their personally identifiable information; however, consistent with our rights under applicable law, our Sites do not support or respond to do-not-track requests or other signals sent from a web browser.

USE OF PERSONAL DATA

We use Client Data to perform services in accordance with Client instructions (including as set forth in a Client Agreement) and in accordance with applicable law. We use other information our provide us, including Personal Data, to operate our business, provide the Sites, and render our services with a lawful basis for processing, such as with your express consent for a specific purpose, to perform our contractual obligations, to comply with legal obligations, or otherwise in furtherance of our legitimate interests. Specifically, where you have provided us with your Personal Data, we may use that information in the following ways:

• To operate, maintain, and improve our sites, products, and services;
• To provide you with personalized content, services, and offers of services by Raeden, as well as to determine relevant search results and provided you with recommendations as part of our services;
• To respond to comments and questions and provide customer service;
• To send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
• To communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners;
• To further develop your user profile (which may include information collected elsewhere), or to update other user information we may have about you;
• To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity; or
• To provide and deliver products and services in response to our customers’ requests.

When we collect any information that does not identify you as a specific natural person, we are permitted to use and disclose this information for any purpose, notwithstanding anything to the contrary in this Notice, except where we are required to do otherwise by applicable law. Similarly, if applicable law requires that we treat such non-Personal Data as Personal Data, we will use and disclose this information as Personal Data in accordance with this Notice.

STORAGE OF PERSONAL DATA

When we share your Personal Data with our trusted partners, they may store some of your Personal Data in their databases in the United States, or elsewhere in the world. If you are accessing this website from jurisdictions outside the United States, please be advised that you may transferring your Personal Data to us in the United States where data protection and privacy laws may be less stringent than the laws of your country.

NO SENSITIVE PERSONAL DATA

Raeden does not intentionally collect, process, or store, and we request that you do not post, upload, store, display, transmit, or submit Sensitive Personal Data to our Sites or in Client Data. “Sensitive Personal Data” includes, but is not limited to, government-issued identification numbers; financial account numbers; credit or debit card numbers; consumer reports; background checks; any code or password that could be used to gain access to personal accounts; genetic data or biometric data; any Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; or data concerning health or sex life or sexual orientation. Raeden is not responsible and will not be liable for any loss or damages you or another individual may experience due to your disclosure of Sensitive Personal Data while using the Services.

BY USING OUR WEBSITE, YOU CONSENT TO THE TRANSFER AND USE OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY NOTICE.

SHARING OF PERSONAL DATA

Except as described in this Notice or an applicable Client Agreement, Raeden will not use, share, or disclose your Personal Data for any purpose other than to the extent necessary to provide the Sotes and render our services, unless you expressly consent to any other use or disclosure. We may share Personal Data as follows:

• We may share Personal Data with your consent. For example, you may consent to our sharing of Personal Data with others for their own marketing uses. Those uses will be subject to their privacy policies;
• We may share Personal Data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding;
• We may share Personal Data for legal, protection, and safety purposes;
  • We may share information to comply with laws.
  • We may share information to respond to lawful requests and legal processes.
  • We may share information to protect the rights and property of Raeden, Inc., our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
  • We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
• We may share information with those who need it to do work for us; or
• Or any other legally permitted purposes.

We may also share aggregated and/or anonymized data with others for their own uses.

LINKS

Our Sites may include links to third-party websites. We are not responsible for the content or privacy practices of those other sites, which are governed by their own privacy policies and practices.

YOUR LEGAL RIGHTS OVER YOUR PERSONAL DATA

Where allowed under local law, you may have the right to submit a request for access to the data we hold about you. Further, Raeden will correct inaccurate or out-of-date information about you at your request or when we become aware of the error. You can request that your data be made available for you to download or other export as well. Finally, you may request that Raeden delete certain data we hold about you. However, your data will not be deleted in the following situations:

• If you have any open or ongoing matter with Raeden’s customer service or technical support personnel; or
• When retention is required by applicable law or for legal enforcement purposes.

To exercise these rights where allowed under your applicable local law, please contact us by email or postal mail using the information set forth under “Contact Information” below. Raeden will respond to your request within a reasonable timeframe in accordance with the applicable law.

Your California Privacy Rights

If you are a California resident, you may request a list of all third parties to which we have disclosed certain Personal Data during the preceding year for those third parties’ direct marketing purposes. If you are a California resident and want to obtain such a list, please contact us by email or postal mail using the information set forth under “Contact Information” below. Please ensure that you include the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code.

Under the California Consumer Privacy Act of 2018 (“CCPA”), California consumers have the right to request:

• the deletion of the Personal Data we have about them;
• additional information about whether and how we have collected, used, disclosed, and sold Personal Data about them;
• the specific pieces of Personal Data we have about them; or
• that we opt them out of the “sale” of their Personal Data.

California consumers also have the right not to receive discriminatory treatment if they exercise the California privacy rights listed above.

California consumers may exercise their right to opt-out by emailing Raeden at the address listed in the “Contact Information” below with subject line “Exercising the Right to Deletion and to Know About Information Collected.”

NOTICE CONCERNING CHILDREN

The Sites are not specifically directed at or intended for children under the age of 13. Therefore, Raeden does not knowingly collect Personal Data via the Sites from anyone under 13. Any user that believes that Raeden has in its database the Personal Data of a child under the age of 13 should contact us using the email or postal address set forth under “Contact Information” below, so that, if necessary, Raeden can have such information removed in compliance with the Children’s Online Privacy Protection Act (“COPPA”).

INFORMATION CHOICES AND CHANGES

Our marketing emails provide the ability for you to “opt-out.” If you choose to opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.

You may send requests about Personal Data by email or postal mail to the address listed in our Contact Information below. Such requests can include requests to update your Personal Data, change contact choices, and opt-out of our sharing information with third parties.

As noted above, you can typically remove and reject cookies from our Sites with your browser settings. Many browsers are set to accept cookies until you change your settings. Please note that removing or rejecting cookies may affect your ability to use features of our Sites to their fullest potential.

CONTACT INFORMATION

We welcome your comments or questions about this Notice. You may contact us at the following addresses:

Raeden, Inc.
8 The Green, Suite 12728
Dover, DE 19901

legal@raeden.com

CHANGES TO THIS NOTICE.

We reserve the right to revise this Notice from time to time (e.g., to keep up with changes in the law, or to reflect changes in how we are doing business). In the event that this Notice is modified in any way, we will use commercially reasonable efforts to notify users of any changes. Therefore, we suggest you review this Notice periodically to ensure you are aware of our current privacy practices.