MarketSyncer Inc. (“MarketSyncer”, “we”, “us”, “our” and terms of similar meaning) takes your privacy rights very seriously. We are committed to transparently describing our privacy practices, including how we collect, use and disclose (a) your personal or personally identifiable information (“Information”); and (b) data we obtain from your activity on the Services (“Data”) as part of providing the MarketSyncer website (the “Website”) and the MarketSyncer Software as a Service platform (the “Platform”) and the related services made available through the Platform (collectively, the “Services”).

We encourage you to read and understand our Terms and Conditions (“Terms”) and this privacy policy (“Privacy Policy”) and any other agreement you agree to or enter into with MarketSyncer before using the Services. By accepting the Terms and/or Privacy Policy or by accessing the Services, you expressly consent to our collection, use and disclosure of your Information and Data in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to our Terms.

All capitalized terms that are not otherwise defined herein obtain their meaning from the Terms.

1. What Information Do We Collect?

1.1 Our primary purpose in collecting Information and Data from you voluntarily is to provide you with a secure, efficient and customized experience when using the Services. We will only ask for and collect Information and Data that we consider necessary to ensure a positive experience.

1.2 Information and Data.

• When signing up for a Client or User account, Clients and Users of the Services must provide the Information as requested or where indicated. On these forms we indicate which fields are required and which fields are optional where possible. Our primary purpose in collecting Data from you voluntarily is to provide a secure experience. When visiting the Website or using the Services, we may collect, without limitation, Information and Data including: your first and last name, company name, email, address, phone number, password for the Platform, Platform subscription plan and other information inputted by you and Data generated from your use of the Services.

• As you use the Services, you can, or may be required from time to time, to enter or send to us Information, which may include, without limitation, Information that you publish on your account as a Client or User or Data that you upload to the Platform, such as attachments.

• As you use the Services, you may voluntarily provide Information to MarketSyncer’s sales, support or training staff, which may include, without limitation, your requests, questions and responses, information provided in connection with surveys or research studies that you chose to participate, information to verify your identity, your date of birth.

• You represent that you have the right and authority or have obtained all necessary consents and approvals to provide any Information, including any Information of another individual or entity, that is provided by you to MarketSyncer through the Services or otherwise.

1.3 Payment and Banking Information.When you add a credit/debit card, payment method or banking information to any Client account, these payment details will be shared with our third-party payment processor(s). We do not store credit/debit card, payment method or banking information on our servers. If you modify which Administrator account provides payment for the Services, we will require that Information to be updated for your continued access to the Services.

1.4 Information and Data Collected Automatically

• When you use the Platform, MarketSyncer automatically receives and records Data from your device, including but not limited to your IP address, Data uploaded to the Platform, other Platform IDs, emails and appointment information, the page you requested, the timing, frequency and pattern of your use of the Services, metadata and inference information related to your use of the Platform, the Website and Third-Party integrations, and other Data resulting from your use of Services. This usage data may be processed for the purposes of analyzing the use of the Platform. Unless otherwise stated in this Privacy Policy, MarketSyncer only uses this Data in aggregate form.

• “Cookies” and similar technologies are small files placed on your computer and devices that assist us in providing our Services. We and our third-party service providers use cookies and similar technologies to provide and personalize the Service, analyze use, target advertisements and prevent fraud. You can disable cookies in your browser settings, however, if you do so, some parts of the Service may not function properly.

• As you use the Services, you may voluntarily provide Information to MarketSyncer’s sales, support or training staff, which may include, without limitation, your requests, questions and responses, information provided in connection with surveys or research studies that you chose to participate, information to verify your identity, your date of birth.

• Third Parties. The Services may include links to third-party service providers and third-party integrations (collectively, “Third Parties”). Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the Privacy Policy of every website, application, software or plugin you visit. We may receive your Data from our use of services provided by Third-Parties, including but not limited to Data or business contact information processed by Third-Parties.

2. How Do We Use Your Information and Data?

We may use your Information to determine your eligibility to register for a Client or User account or to continue to have a Client or User account on the Platform. We may also use your Information and Data to provide to you the license for the Services; to provide you with the Services; to maintain and improve the Services, to communicate with you, either directly or through one of our partners, including for marketing and promotional purposes and to resolve your support requests; to provide you with reports about usage; to survey your opinions through surveys, research studies and questionnaires; to improve our marketing and promotional efforts; to advise of fee and Service updates; to facilitate transactions and payments (if and as applicable); to resolve service disputes; to identify and fix bugs, and errors; to troubleshoot the Platform; to analyze usage of our Services; to improve our content and product offerings; to deliver information to you that, in some cases, is relevant to your interests; to customize your experience, the content, layout and services; to facilitate reporting and analyze performance of the Platform; to process your information at your direction; to detect and protect us against error, fraud and other criminal activity; to enforce our Terms; to comply with a valid legal request; to provide you with system or administrative messages; and/or as otherwise described to you at the time of collection. These uses improve the Services and better tailor it to meet your needs, so as to provide you with a secure, efficient and customized experience while using the Services.

Unless otherwise prohibited by law, MarketSyncer may combine the information that we collect through your use of the Services with information that we receive from other sources, both online and offline, and use that combined information as set out above.

3. Our Disclosure of Your Information and Data

• General Disclosure. We may share your Information and Data with third parties only in the ways that are described in this Privacy Policy and in accordance with your consent. We will not share, sell or rent your Information or Data to third parties without your explicit consent. You acknowledge and agree that the Data you upload to the Platform may be viewable by other Users part of your Client Account, depending on the settings your Administrator has selected.

• Anonymized Aggregated Data. We may aggregate and anonymize your Data and use and disclose it for a variety of purposes, including analytics, to improve our algorithms, measure service usage, publish summaries and develop new features. We will not display or otherwise disclose aggregated information where a Client or User can be identified. In addition, we do not display or otherwise disclose any Information. Furthermore, we may need to occasionally review raw data and the results for system maintenance. If this review is necessary, we will only see the unique identifier number with the data.

• Subsidiaries, Affiliates & Service Providers. We may use the services of Third Parties in connection with our provision of the Services, including, without limitation, for the processing of payments, off-premise data hosting, communication services, account hosting, integrations, and Information collecting and analysis services. We may disclose your Information and Data to the Third Parties in the course of our use of their services. We take care to use Third Parties that we believe are reputable and capable of performing the services we require of them, including, without limitation, the handling of confidential information and Information and Data and the compliance with all applicable laws. This Privacy Policy does not apply to Data processed by Third Parties through your use of any Third-Party integrations available through the Platform. Please visit the Third-Party websites for more information regarding their privacy and data protection practices.

• Sale of Business. We may disclose Information and Data to the acquiror or its agents in the course of the sale of our business. If we do this, the disclosure will be subject to confidentiality arrangements customary in such transactions. In addition, if the ownership of all or substantially all of our business changes, or all or some of our assets are sold as part of a bankruptcy or other proceeding, we may transfer your information to the new owner so that the services can continue to operate. In such case, your information would remain subject to the commitments contained in this Privacy Policy until the acquiring party updates it. If such transfer is subject to additional mandatory restrictions under applicable laws or agreements, MarketSyncer will comply with those restrictions.

• Storing and Processing Your Information and Data. In some cases, Information and Data that we collect may be stored or processed outside of the jurisdiction it is received. When that occurs, we continue to protect the Information and Data with appropriate safeguards and data export requirements, but it may be subject to the legal jurisdiction of those countries and governmental authorities in those countries.

4. Communication Preferences

You can always unsubscribe from our commercial and promotional emails, but we may still send you communications relating to your status as a Client and your Users and your use of the Services in accordance with applicable anti-spam legislation.

5. How Do We Use Your Information and Data?

• General Retention Policy. We will periodically de-identify (a) Information from collected Data in unused User Accounts; and (b) unnecessary Information from Data collected elsewhere on and/or through the Services.

• Termination of Client or User Account. If your Client or User Accounts are terminated, we will deactivate them, but we may retain your Information and Data for a certain period of time, in accordance with applicable privacy laws, and disclose it in a manner consistent with our practices under this Privacy Policy.

• Do-Not-Track. Do-Not-Track is a privacy preference that Clients and Users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our websites for Third Party purposes, and therefore, we provide you with the ability to opt out, if needed, and adjust your cookie preferences. We do not currently recognize or respond to browser-initiated Do-Not-Track signals.

• Marketing Practices and Choices. You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding services, promotions, and special events that might appeal to your interests by contacting us at info@marketsyncer.com. For commercial email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain transactional, operational, or service-related emails, such as those reflecting our relationship or transactions with you.

6. Your Information and Data Rights

In accordance with the applicable privacy laws, you may have the following rights with respect to your Information and Data:

• Right of Access and Portability. You may ask for an overview or copy of your Information and/or Data to be provided to you; and/or transferred to another organization.

• Right to Rectification. You may review your Information and delete and/or update it through your User Account or by contacting us, to ensure it is accurate and complete on the Services.

• Right to Erasure and Restriction. You may ask us to remove and/or restrict our processing of your Information and/or Data in certain circumstances (e.g. if you believe we have processed your Information and/or Data unlawfully, if you believe that your Information and/or Data is no longer necessary for the purposes in which it was collected or processed, you withdraw your consent (as discussed below). Notwithstanding the foregoing, despite such request, subject to all applicable laws and the terms and conditions of this Privacy Policy, we may still retain your Information and Data for legitimate business interests, to collect any fees owed (if and as applicable), resolve disputes, troubleshoot problems, analyze usage of the Services, assist with any investigations, prevent fraud, enforce our Terms and/or take other actions as required or permitted by law.

• Right to Withdraw Consent. Where we have asked for your consent to use and/or process your Information and Data, you can withdraw this consent at any time. We will do our best to accommodate your request, subject to applicable laws and the terms and conditions of this Privacy Policy.

Please contact us at info@marketsyncer.com if you would like to exercise any of the above rights. Upon your request, we will need to verify your identity and may need to verify your relationship with MarketSyncer for security and fraud prevention. Further, we may take additional steps to verify that you are an authorized Client or Administrator to make the request. If you are a User, you should direct requests relating to your information to the Administrator of the Client account.

7. Security

We strive to protect your Information and Data by putting in place a range of technical and organizational measures to safeguard and secure the Information and Data we receive from you, including without limitation, security technologies. We are continuously utilizing security measures to protect your Information and Data from unauthorized access or against loss, misuse or alteration. Despite our efforts, we cannot guarantee the security of your Information and Data. Unauthorized entry or use, hardware or application failure and other factors, may compromise the security of your Information and Data at any time. We reserve the right, without any limitation, to investigate any suspected breaches of the Services’ security or information technology or other systems or networks.

8. Changes to This Privacy Policy

MarketSyncer may amend this Privacy Policy from time to time. The use of Information and Data we collect is subject to the Privacy Policy in effect at the time the Information or Data is used. If we make any material changes in the way we use your Information or Data, we will notify you by (a) posting a notice on the Client and User account page of the Platform or elsewhere on the Services; or (b) e-mailing you at your e-mail address associated with your Client, Administrator or User account. Clients and Users of the Services are bound by any changes to the Privacy Policy when they use the Services after such changes have been first posted.

9. Questions?

It is our goal to make our privacy practices easy to understand. If you have questions, concerns or if you would like more detailed information, please email our data controller at info@marketsyncer.com.