Contents

• 1. What Information We Collect and Process
• 2. How We Use Personal Information
• 3. How We Share Personal Information
• 4. How We Transfer Personal Information Internationally
• 5. How We Store and Secure Personal Information
• 6. Cookies and Similar Technologies
• 7. Your Privacy Rights and Choices
• 8. California Privacy Rights
• 9. Contact Us
• 10. Other Important Privacy Information

Introduction

Site Systems is a division of Pacific Digital Industries, Inc. which does business under the following names: Hail Agency, SweepstakesPros, Sweepstakes Monkey, Promotion Trust and Site Systems (collectively "Site Systems").

We at Site Systems are committed to protecting your privacy. This Privacy Policy applies to the personal information and data collected by Site Systems when you interact with our websites, products and services, and any other sites or services that link to this Privacy Policy.

This Privacy Policy describes how we collect, receive, use, store, share, transfer, and process your Personal Information. This Privacy Policy also describes your choices and rights with respect to your Personal Information, including your rights of access and correction of your Personal Information. For the purposes of this Privacy Policy "Personal Information" means any information relating to an identified or identifiable individual. By using websites, products and services you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, you should not use our websites, products and services, or any other sites or services that link to this Privacy Policy.

Site Systems and our customers may collect and manage Personal Information when using our products and services, or what we may refer to as the "Promotions Platform". "Promotions Platform" means all our web-based applications, tools and platforms that we make available to you, and are developed, operated, and maintained by us and any ancillary products and services, including website hosting, that we provide. When you use the Promotions Platform, Site Systems processes Personal Information as a processor under the direction of our customers. Our customers, as data controllers, are responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to collecting their customers' Personal Information using the Promotions Platform. Please see Section 1.b "Information We Process on Behalf of Customers When They Use the Promotions Platform" and Section 1.c "Information We Collect and Process When You Use the Promotions Platform" for more information.

We update this Privacy Policy from time to time and we encourage you to review this Privacy Policy periodically. We will post any Privacy Policy changes on this page.

If you have any questions about this Privacy Policy or to exercise the privacy rights and choices we offer, please contact us using one of the following methods:

• By email at ; or
• By postal mail at Site Systems, P.O. Box 3222, USA, Attn: Privacy Department.

1. What Information We Collect and Process

a. Information You Provide to Site Systems

When you interact with us via our websites or any sites or services that link to this Privacy Policy or use the Promotions Platform, we may collect Personal Information and other information from you, as further described below.

When You Visit Our Websites

We collect Personal Information from you when you submit web forms or interact with our websites, for example by subscribing to a Site Systems newsletter or blog, signing up for a webinar, subscribing to one of our services, or requesting customer support. We may ask for your email address, first and last name, job title, phone number, address, billing information, account information, and other similar business information. You are free to explore some of our websites without providing any Personal Information about yourself.

Registration, Account and User Information

We collect Personal Information when you sign-up for an account, create or modify user information, set preferences, or provide any other related information to access or utilize the Promotions Platform or other products or services. This Personal Information may include, without limitation, name, email address, phone number, email address, mailing address, demographic information (such as age or gender), and billing and credit card information. Without providing Personal Information, you cannot create a Promotions Platform account. We may request or collect Personal Information from you during any registration process which we may use to provide or improve our products, services, the Promotions Platform, or otherwise as provided herein. We may store Personal Information, and it may be included in databases owned and maintained by our agents or service providers.

Payment Information

We collect payment and billing information when you register for paid products or services. For example, we may ask you to provide a billing address, or a billing contact. If you give us payment information, we use it solely as authorized by you in accordance with this Privacy Policy.

You may also provide payment information, such as a credit card number or bank account numbers, when purchasing products or services. We use secure third-party payment service providers to manage payment processing, which is collected through a secure payment process.

Customer Testimonials

We may post customer testimonials and comments on our websites, which may contain Personal Information. We obtain each customer's consent via email or through other agreements between customers and Site Systems prior to posting the customer's name and testimonial.

b. Information We Process on Behalf of Customers When They Use the Promotions Platform

Our products, services, and the Promotions Platform allow our customers to run and host promotions, including, but not limited to, sweepstakes, contests, games, social engagements, and loyalty programs. When customers use our products, services, and the Promotions Platform they may collect Personal Information such as first and last name, email address, physical address, phone number, or other information about you from a variety of online, mobile, and offline sources. We call the information that our customers upload, submit or collect via the Promotions Platform or otherwise provide to us "Customer Data".

We do not control the content of our customers' webpages or the types of Personal Information that our customers may choose to collect or manage using our products, services, or the Promotions Platform. We store our customers' information on our service providers' servers but process it as a processor under our customers' instructions and in accordance with our agreements with our customers, which prohibit us from using the information except as necessary to provide and improve our products, services, and the Promotions Platform and as required by law.

Our customers control and are responsible for correcting, deleting, or updating the Customer Data and for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring the Personal Information to Site Systems for processing purposes.

c. Information We Collect and Process When You Use the Promotions Platform

Usage Data

We collect usage data when you, or your users of the Promotions Platform, use and interact with the Promotions Platform. Usage data includes metrics and information regarding your use and interaction with the Promotions Platform such as what product features you use the most, when an object (like a ticket) is opened and closed, and how often certain features (like workflows) are triggered in your account.

Like most websites and technology services delivered over the Internet, we may collect and store Personal Information and usage data about you and/or your computer hardware and software when you visit our websites, use our products, services the Promotions Platform, or visit other sites or services that link to this Privacy Policy. This information can include cookies, your IP address, browser type, domain names, internet service provider (ISP), and the files viewed on our websites (e.g., HTML pages, graphics, etc.), the files viewed on our, or our customer's websites (if those websites are hosted on Site Systems or the Promotions Platform) (e.g. HTML pages or graphics, etc.), your operating system, access times, referring website addresses and other statistical data involving your use of the Promotions Platform and/or our products and services. When you use the Promotions Platform, we may collect and store the categories of information listed above:

• When a user logs into their account and accesses tools in the Promotions Platform;
• When an individual visits a customer's website, if the website is hosted by the Promotions Platform; or
• When an individual visits a customer's self-hosted website, if the customer uses the Promotions Platform scripts, plug-ins, and/or content (such as embedded forms).

We may engage third-party providers to collect usage data. For more information about how we protect your information with these service providers, please see Section 3 "How We Share Personal Information"

Information You Collect in the Promotions Platform or Provide to Us.

We have access to all the data and information collected though our products, services, the Promotions Platform, and data and information you provide to us or upload in the Promotions Platform.

Email Data

When emails are sent by us or though the Promotions Platform, we may track information about email bounces, who has opened the emails and clicked the links. We can collect the following information for each email address an email is sent to: bounces, when the email is opened, when it was opened, how many times it was opened, what link(s) were clicked, when the links were clicked, and how many times each link was clicked. This information is used to evaluate the performance of the emails sent.

Mobile

When you access or use the Promotions Platform via mobile applications, we may automatically collect information such as your device model and version, operating system, or device identifiers.

YouTube

Pulling in YouTube videos to a promotion hosted on the Promotions Platform uses YouTube's API services and/or links. When using YouTube in conjunction with the Promotions Platform, we may cache/store the desired YouTube videos' URLs. Beyond YouTube video URLs, no other information is collected or stored from YouTube. Visit the Google Privacy Policy for more information at https://policies.google.com/privacy .

d. Information We Collect from Other Sources

Site Systems Partners

We may receive information about you or other users of your Site Systems account from our partners. We may receive this data from our affiliate program and/or lead registration process through our partners.

Third Parties

We may receive information from third-party service providers, from related companies, and from our business and solution partners.

Personal Information from Other Sources

We may combine the personal information we collect from you with personal information we receive from other sources, such as third-party providers of business information and publicly available sources (like social media platforms). This may include physical mail addresses, job titles, email addresses, phone numbers, IP addresses, and social media profiles. This helps us to update and improve our records, identify new customers, create more personalized advertising, suggest products and services that may interest you, deliver personalized communications and promote events. The collection of your Personal Information by these other third-party providers is governed by the provider's privacy policy.

Buttons, tools, and content from other companies

Our websites may include features and widgets (such as the share and/or "like" button or interactive mini-programs) that run on our websites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. These features and widgets are either hosted by a third-party, hosted directly on our websites or hosted on the Promotions Platform. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

We may implement Google reCAPTCHA, Cloudflare Turnstile, and/or Cloudflare Bot Management on our websites, the Promotions Platform, or other sites or services that link to this Privacy Policy to prevent malicious software from engaging in abusive activities. You can learn more about data collected by Google and what this data is used for in Google's Privacy Policy. Additional information on Google services and products is available in Google's Terms of Service. You can learn more about data collected by Cloudflare and what this data is used for in Cloudflare's Privacy Policy. Additional information on Cloudflare's services and products is available in Cloudflare's Terms of Use.

Other Site Systems Companies

We may receive information about you from other companies that are owned or operated by our company.

2. How We Use Personal Information

a. To Communicate with You About our Product and Services

We use the Personal Information you provide to Site Systems when signing up for our services or the Promotions Platform to send you transactional emails or in-app notifications about billing, account management, and other administrative matters. We may also send you updates regarding our legal agreements, policies, terms, and security incidents via email or in-app notification.

We use your information to provide customer support, such as resolving technical issues you encounter and analyzing product outages or bugs.

b. To Provide the Promotions Platform

We use your Personal Information and Customer Data to provide our products and services to you. For example, we may use the email address you provide when signing up for the Promotions Platform to create your user account, and we use your payment information to process payments for our products, services and the Promotions Platform. We also use this information to authenticate you when you log in and to provide customer support.

c. To Improve and Develop Our Product and Services

We collect usage data about how you or your users interact with our product and services. We use this data to develop and improve our products and services. For example, we may use usage data to assess trends and usage across the Promotions Platform to help us determine what new features or integrations our users may be interested in.

We may publish data about how our products and services are being used across our customer base. When we share statistical information externally in this way, the data will be aggregated, and we will not identify individual users or customers. For example, we may publish blog posts on trends or insights into how users are interacting with our products and services.

d. To Secure and Protect our Products, Services and Promotion Platform Users

We use your Personal Information to investigate and help prevent security incidents. We may also use this information to meet legal requirements. We use your information to verify user accounts, new sign-ups, to detect and prevent abuse, and to enforce our policies.

We use usage data to provide general statistics regarding use of the websites by you, including how you use our websites, what country you are logging in from (for analytics, export control and regulatory purposes) and to help improve the navigation experience. Your cookies and IP addresses may also be collected and logged for security and debugging purposes, for example to track access patterns, investigate security events and incidents. For these purposes we may also link this collected data to other Personal Information provided by you such as name, email address, address, and phone number.

e. To Market and Promote Site Systems

We use the information you provide to Site Systems to market and promote our products, services, and other offerings. For example, we may use the information, like your email, phone number, or physical address, to send information or Site Systems content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business.

You may opt out of receiving this promotional content by following the instructions contained in each communication that we send to you or by contacting Site Systems through one of the methods listed in Section 9 "Contact Us" below. If you unsubscribe from our marketing lists, we will continue to contact you regarding administrative matters, and to respond to your requests.

We may also reach out to you via telephone to ask about other Site Systems products or services you may be interested in. If you have a call with a Site Systems representative, we may record and transcribe the call. You will be notified prior to the call that the call is being recorded, and you will be offered an opportunity to opt-out of having the call recorded.

Where required by law, we will only send marketing communications with your consent. Otherwise, we will market and advertise our products and services on the basis of our legitimate business interests.

We may receive information from third-party service providers and other sources such as third-party providers of business information and publicly available sources. We may receive and use this information from these service providers and other sources in combination with other information we collect through other means described in this Privacy Policy for the purposes of providing you with updates and improving our products, services, and the Promotions Platform, like personalized communications, event promotion, and tailoring the websites, products or services to improve user experience.

f. For Corporate Events or Transfers

We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about is among the assets transferred.

g. Other Purposes if We Obtain Your Consent

We may share your data with third parties when you give us consent to do so.

h. Legal Basis for Processing Personal Information (EEA and UK visitors only)

If you are a website visitor located in the European Economic Area ("EEA") or United Kingdom ("UK"), we are the data controller of your Personal Information. Site Systems' Data Protection Officer can be contacted through one of the methods listed in Section 9 "Contact Us" below.

Our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. However, we will normally collect and use Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, when it is necessary to protect your vital interests or those of another natural person, when it is related to a task that is carried out in the public interest or in the exercise of official authority vested in us, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect and use Personal Information from you.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

3. How We Share Personal Information

a. Service Providers

We may share Personal Information with our third-party service providers to support our websites, products, services, and the Promotions Platform. For example, we may use service providers for data hosting, application development, marketing, sales support, and customer support. We may need to share your information with service providers to provide information about products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data, or performing statistical analysis on your use of the Promotions Platform or interactions on our websites, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, developing and improving the product and services, and providing customer service or support. These service providers are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.

b. Partners

We may share data with trusted Site Systems partners to contact you based on your request to receive such communications, help us perform statistical analysis, provide sales support, or provide customer support. Partners are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your data.

c. Business Transfers

We may share or transfer your Personal Information in connection with, or during negotiations of, any merger, sale of our assets, financing, bankruptcy, or acquisition of all or a portion of our business to another company.

d. Public Forums

Our websites may offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums (including profile information associated with the account you use to post the information) it may be read, collected and used by any member of the public who accesses these websites. Your posts and certain profile information may remain even after you terminate your account. We urge you to consider the sensitivity of any information you may disclose in this way. We will correct or delete any information you have posted on the websites if you so request, as described in Section 7 "Your Privacy Rights and Choices" below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.

e. Compelled Disclosure

We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.

4. How We Transfer Personal Information Internationally

a. International Transfers within Site Systems and to Third Parties

Your Personal Information is processed where we have operations and in any other places where third parties, which provide services to us under contract, are involved in the processing are located. This means that this information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer and this Privacy Policy will apply even if we transfer Personal Information to other countries.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and Personal Information.

b. Data Privacy Framework Notice

Site Systems complies with the EU-U.S. Data Privacy Framework ("EU-U.S. DPF"), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework ("Swiss-U.S. DPF") as set forth by the U.S. Department of Commerce (collectively the "Data Privacy Framework").

Site Systems has certified to the U.S. Department of Commerce that it adheres to the EU-US DPF Principles with regard to the processing of Personal Information received from the European Union in reliance on the EU-U.S. DPF, and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF, and to the Swiss-US DPF Principles with regard to the processing of Personal Information received from Switzerland in reliance on the Swiss-U.S. DPF (collectively the "DPF Principles"). If there is any conflict between this Privacy Policy and the DPF Principles, the DPF Principles shall govern. To learn more about the Data Privacy Framework, and to view our certification, please visit the Data Privacy Framework website.

If you are located in the EU, UK or Switzerland, you have the right to request access to the Personal Information that we hold about you and request that we correct, amend or delete your Personal Information if it is inaccurate or processed in violation of the DPF Principles. We will give you an opportunity to opt out where Personal Information we control about you is to be disclosed to an independent third-party or used for a purpose that is materially different from those set out in this Privacy Policy. If you would like to exercise any of your rights, please contact us via the details provided in Section 9 "Contact Us" below.

In compliance with the DPF Principles, Site Systems commits to resolve DPF Principles-related complaints about our collection and use of your Personal Information. We will investigate and attempt to resolve any DPF Principles-related complaints within 45 days. EU, UK and Swiss individuals with inquiries or complaints regarding our handling of Personal Information received in reliance on the DPF Principles should first contact Site Systems through one of the methods listed in Section 9 "Contact Us" below.

In compliance with the Data Privacy Framework, Site Systems commits to refer unresolved complaints concerning our handling of Personal Information received in reliance on the Data Privacy Framework to an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please contact JAMS, our U.S.-based third-party dispute resolution provider, (free of charge) at https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint.

Under certain conditions, more fully described on the Data Privacy Framework website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted. The Federal Trade Commission has jurisdiction over Site Systems' compliance with the DPF Principles.

In the context of an onward transfer, Site Systems is responsible for the processing of Personal Information it receives under the DPF Principles and subsequently transfers to a third-party acting as an agent on our behalf. Site Systems will remain liable under the DPF Principles if our agent processes your Personal Information in a manner inconsistent with the DPF Principles, unless Site Systems is not responsible for the event giving rise to the damage.

Please note that under certain circumstances, we may be required to disclose your Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

5. How We Store and Secure Personal Information

a. Data Storage and Security

The security of your Personal Information is important to us. We store the Personal Information you provide on secure computers and servers, and we use a variety of commercially acceptable security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. For more on Security at Site Systems, please see Site SystemsSecurity Practices page.

b. Retention of Personal Information

How long we keep the information we collect about you depends on the type of information and how we collect and store it. After a reasonable period of time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.

We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).

When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymize it or, if this is not possible, securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request, as described in Section 7 "Your Privacy Rights and Choices" below.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your Site Systems account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

The data our customers process in connection with the Promotions Platform is retained according to the agreements Site Systems has with our customers.

6. Cookies and Similar Technologies

a. Cookies

When you:

• Visit one of our websites,
• Sign up or log into a Promotion Platform account and accesses tools in the Promotions Platform;
• Visit a customer's website, if the website is hosted by the Promotions Platform;
• Visit a customer's self-hosted website, if the customer uses the Promotions Platform scripts, plug-ins, and/or content (such as embedded forms),
• Attend a Site Systems virtual meeting or event, or
• Request more information about Site Systems,

we may collect information automatically using tracking technologies, like cookies and tracking pixels. For more information, and to learn how to opt out, please refer to our Cookie Policies below.

Site Systems and our partners use cookies or similar technologies (such as web beacons and JavaScript) to analyze trends, administer the website, monitor how visitors navigate around the websites, and to gather demographic information about our user base as a whole. To find out more about how we use cookies on our websites and how to manage your cookie preferences please see Site Systems Cookie Policy page.

b. Advertising

We may partner with third-party ad networks to display advertising on our websites or to manage our advertising on other sites. Our ad network partner uses cookies and web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by using these services: https://optout.networkadvertising.org/ or https://optout.aboutads.info/ (or if located in the European Union, by clicking here: https://www.youronlinechoices.eu/ ). Please note this does not opt you out of being served advertising you will continue to receive generic ads.

7. Your Privacy Rights and Choices

a. Personal Information Requests

You have the following data protection rights:

• Access, Correction or Deletion. You can request access, correction, updates, or deletion of your Personal Information.
• Objection. You can object to our processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information.
• Withdraw Consent. If we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
• Complaint. You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the EEA.

To exercise any of these rights for Site Systems, including our websites and product or services, please contact us through one of the methods listed in Section 9 "Contact Us" below.

Please note that to protect personal information, we may verify your identity by a method appropriate to the type of request you are making. Depending on where you reside, you may be entitled to empower an "authorized agent" to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

We will respond to your request to change, correct, or delete your data within a reasonable timeframe and notify you of the action we have taken. In some instances, your rights may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights.

If you are a customer, prospect, or otherwise interact with a Site Systems customer that uses our Promotions Platform and would like to access, correct, amend, or delete your data controlled by the customer, please contact the relevant customer directly. Site Systems acts as a processor for our customers and will work with our customers to fulfill these requests when applicable.

b. Anti-Spam Policy

Our policies prohibit use of our products, services and the Promotions Platform to send unsolicited commercial email in violation of applicable laws, and requires the inclusion in every email sent using the Promotions Platform of an "opt-out" mechanism and other required information.

c. To Unsubscribe from Our Communications

You may unsubscribe from our marketing communications through one of the methods listed in Section 9 "Contact Us" below.

Customers cannot opt out of receiving transactional emails related to their account with us or the Promotions Platform.

d. To Unsubscribe from Our Customers' Communications

Our customers are solely responsible for their own marketing emails and other communications; we cannot unsubscribe you from their communications. Individuals who interact with a Site Systems customer can unsubscribe from our customers' marketing communications by clicking on the "unsubscribe" link located on the bottom of their emails, or by contacting them directly.

8. California Privacy Rights

a. Applicability

This section applies only to California consumers. For purposes of this section "Personal Information" has the meaning given in the California Consumer Privacy Act ("CCPA"). It describes how we collect, use, and share California consumers' Personal Information in our role as a business, and the rights applicable to such residents. The California Consumer Privacy Act ("CCPA") requires businesses to disclose whether they sell Personal Information. Site Systems is a business and does not sell Personal Information. We may share Personal Information with authorized service providers or business partners who have agreed to contractual limitations as to their retention, use, and disclosure of such Personal Information.

If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us through one of the methods listed in Section 9 "Contact Us" and we will arrange to supply you with the information you need in an alternative format that you can access.

b. How We Collect, Use, and Share your Personal Information

We may collect the following categories of personal information (as defined in the California Consumer Privacy Act (CCPA) and the California Customer Records statute), including sensitive personal information (as defined in the CCPA):

We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device. The following is a list of categories of personal information (as defined in the California Consumer Privacy Act (CCPA) and the California Customer Records statute), including sensitive personal information (as defined in the CCPA) which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of each category of personal information were in fact collected by us, but this list reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to us.

Under CCPA, personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA's scope, such as:
• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
• Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from the forms you complete on our website or associated with our services or the Promotion Platform, preferences you express or provide to us, or from your purchases.
• Indirectly from you. For example, from observing your activity on a website or the Promotions Platform.
• Automatically from you or your devices. For example, through cookies we or our service providers set on your device as you navigate through our website or the Promotions Platform.
• From third parties. For example, from third-party vendors to monitor and analyze the use of our websites, products, services and the Promotions Platform, from third-party vendors for payment processing, or from other third-party vendors that we use.

The business and commercial purposes for which we collect this information are described in Section 2 "How We Use Personal Information" of this Privacy Policy. The categories of third parties to whom we "disclose" this information for a business purpose are described in Section Section 3 "How We Share Personal Information" of this Privacy Policy. The period of time for which we retain this information is described in Section 5 "How We Store and Secure Personal Information" of this Privacy Policy.

c. Your California Rights

You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.

• The right of access means that you have the right to request that we disclose what Personal Information we have collected, used, and disclosed about you in the past 12 months.
• The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.
• The right of correction means that you have the right to request that we correct any inaccurate personal information that we maintain about you.
• The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.

d. How to Exercise your California Rights

You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your Personal Information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent's identity to protect your Personal Information.

Please use the contact details below, or see Section 7 "Your Privacy Rights and Choices" above, if you would like to:

• Exercise your rights;
• Learn more about your rights or our privacy practices; or
• Designate an authorized agent to make a request on your behalf.

9. Contact Us

To exercise any of your rights or send us a request regarding your Personal Information, or if you have any questions about this Privacy Policy or our privacy practices, or if you have a disability and need to access this notice in a different format, please contact us using one of the following methods:

• By email at ; or
• By postal mail at Site Systems, P.O. Box 3222, USA, Attn: Privacy Department.

10. Other Important Privacy Information

a. We Never Sell Personal Information

We will never sell your Personal Information to any third-party.

b. Information About Children

Our websites, products and services are not intended for or targeted at children under 13, and we do not knowingly or intentionally collect Personal Information about children under 13 without verified parental consent. If you are a parent or guardian and you are aware that your child under 13 has provided us with Personal Information without your consent, please contact Site Systems through one of the methods listed in Section 9 "Contact Us" above. If we become aware that we have collected Personal Information from anyone under the age of 13 without verification of parental consent, we will take steps to remove that information from our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before we collect and use that information.

c. Questions and Third-party Dispute Resolution

If you have questions or concerns regarding our compliance with this privacy policy, or if you feel that Site Systems is not in compliance with the Data Privacy Framework you should first contact Site Systems through one of the methods listed in Section 9 "Contact Us" above. Site Systems will respond to any such inquiries or complaints within forty-five (45) days. We will investigate and attempt to resolve questions and any concerns regarding use and disclosure of personal information in accordance with this policy.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact JAMS, our U.S.-based third-party dispute resolution provider, (free of charge) at https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint.

d. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We reserve the right to amend, restate or otherwise modify this Privacy Policy at any time without notice to you. However, we will notify you of any changes by posting the new Privacy Policy on this page and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

d. Miscellaneous

Any claim under this Privacy Policy or otherwise related to Site Systems, our products and services or the Promotions Platform shall be governed by the laws of the State of California without regard to its conflict of law provisions and shall be exclusively resolved by a state or federal court located in Santa Clara County, California. You agree to submit to the personal jurisdiction of the courts located within Santa Clara County, California, for the purpose of litigating all such claims.

If any provision of this Policy is found by a court of competent jurisdiction or arbitrator to be illegal, void, or unenforceable, the unenforceable provision will be modified so as to render it enforceable and effective to the maximum extent possible in order to effect the intention of the provision; and if a court or arbitrator finds the modified provision invalid, illegal, void or unenforceable, the validity, legality and enforceability of the remaining provisions of this Privacy Policy will not be affected in any way.