This Privacy Policy describes the privacy practices of SimpleReach, Inc. and its subsidiaries and affiliates (collectively, “SimpleReach” or “us” or “we“).This Privacy Policy describes how SimpleReach collect sand uses the personal information you provide. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information. This Privacy Notice applies to:

·     The simplereach.com website and any other websites or online services controlled by us and which display this Privacy Notice, and

·     Marketing analytics services that we provide to our customers, including via applications, dashboards, and platforms.

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COLLECTION OF INFORMATION

Information We Collect for SimpleReach’s Own Business Purposes

Whose information we collect

SimpleReach may collect information about individuals who interact with SimpleReach when using our websites or services (such as employees of our customers), job applicants, and other individuals.

How we collect the information

We may collect information:

•Directly from individuals

•From our customers, regarding their employees or authorized users

•From recruiters

Types of information we collect

The types of information we collect include:

•Personal and business contact information (such as name, business name,address, telephone number, email address, and mailing address)

•Profile information, such as your username and password that you may set to establish an online account with us

•Payment information (such as credit card or other financial account numbers).We use a third-party payment processor to process credit and debit card transactions and do not collect or store payment card information ourselves.

Information We Collect from or on Behalf of Our Customers

SimpleReach provides marketing analytics services to other businesses – our customers. To take advantage of our services, our customers install our technology on their websites, which enables us to collect certain information regarding individuals’ visits to our customers’ websites. We analyze the personal information that we obtain only at the direction of our customer, and only onthat customer’s behalf.

W may collect information about individuals who visit the digital mediaproperties that have installed our technology at the direction of our customers(“end users”). SimpleReach, Inc. collects information under the direction of its customers on certain digital media properties. SimpleReach has no direct relationship with its customers’ end users. Our customers determine the scope of the information we receive, and the information we receive may vary by customer. If you are a customer of one of our customers and would no longer like to be contacted by one of our customers that use our service, please contact the company that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers.

Typically,when end users access our customers’ webpages, we automatically collect information about end users’ devices, as described further in the section titled “Cookies and Other Information Collected by Automated Means.”

We acknowledge that you have the right to access your personal information.SimpleReach has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend,or delete inaccurate data should direct his query to the relevant customer of SimpleReach’s (the data controller). If requested to remove data we will respond within a reasonable timeframe.

We will retain personal data we process on behalf of our customers for as long as needed to provide services to our customers. SimpleReach will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

COOKIES AND OTHER INFORMATION COLLECTED BY AUTOMATED MEANS

We,our service providers, and our business partners, may collect certain information about the use of our websites by automated means, such as cookies,or similar technologies. Likewise, as part of our services, we may offer our customers the ability to install these types of technologies on their websites;and if a customer does so, we collect information on its behalf.

A“cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. We use both “session” and“persistent” cookies to collect, store, and sometimes track various types of information on our website and on our customers’ websites. A session cookie is one that disappears after you close your browser. While a persistent cookie remains after you close your browser (and may be used by your browser when you later return to the Service), persistent cookies generally can be removed. A“web beacon,” also known as an Internet tag, pixel tag or clear GIF, is used to transmit information back to a web server. Web browsers may offer individuals the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites or our customers’ websites may not function correctly. We and our service providers and business partners may collect information about your online activities over time and across third-party websites when you use our websites.

Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to webbrowser-based DNT signals at this time. Please see the “Privacy Preferences,Rights and Choices” section below for information about how you may opt out of,or limit the use of, your browsing behavior for online behavioral advertising purposes.

The information we collect by automated means varies based on whether we are collecting information for our own business purposes or whether we are collecting information from or on behalf of our customers to provide our services.

Automated Data Collection

As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP)addresses, browser type, Internet service provider (ISP), referring/exit pages,the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or information about how our websites are used(such as the content that is viewed on our websites, how users navigate on and between our webpages).   We also gather information about how individuals interact with our emails (such as whether the email is opened and which links are clicked in the email).

When our customers install our technology on their websites, we collect the same type of information as described above on behalf of our customers.

INFORMATION USE

Our Use of Personal Information for SimpleReach’s Own Business Purposes

SimpleReach may use personal information to:

•Provide our services to our customers

•Communicate about the products and services we offer, and respond to requests,inquiries, comments, and suggestions, Analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read)

•Operate, evaluate and improve our business, our websites, and other products and services we offer (including to improve our algorithms and develop new products and services)

•Invoice and collect payment for our services

•Establish and maintain an individual’s profile on our websites

•Tailor the content we display in our communications and on our websites

•To conduct research about SimpleReach or our services,

•To notify you of technical updates or changes in policy,

•To contact you for marketing and promotional purposes,

•In response to lawful requests by public authorities, including to meet national security

or law enforcement requirements.

•Comply with legal requirements, judicial process, and our company policies(including to verify users’ identity in connection with access or correction requests),

•Protect against, identify, investigate, and respond to fraud, illegal activity(such as incidents of hacking or misuse of our websites), and claims and other liabilities, including by enforcing the terms and conditions that govern the services we provide,

•Process employment applications,

•Monitor recruiting statistics, to inform our recruitment activities.

In addition, we may aggregate and/or de-identify any information that we collect,such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.

OurUse of Personal Information on Behalf of Our Customers

We use personal information we collect from or on behalf of our customers to provide services to our customers at their direction.  We do not use this personal information for SimpleReach’s own purposes. We use personal information only as directed or authorized by our customer. Typically, we are directed or authorized to use personal information collected on behalf of the customer to provide analytics regarding use of our customers’ websites and end user interactions with our customers’ content.

INFORMATION SHARING AND DISCLOSURE

We will not sell or rent customers’ or end users’ personal information to third parties except as described in this Privacy Policy. We may disclose your personal information to:

•SimpleReach affiliates and subsidiaries

•Service providers that perform services on our behalf, such as customer service and support providers, technology providers (including providers of payment processing, technology support, web hosting, and email communications)

•Survey and market research providers

•Advertising and marketing partners

•Analytics organizations

Unless prohibited by applicable law, we reserve the right to transfer the information we maintain in the event we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will – where required by applicable law – make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Privacy Notice.After such a sale or transfer, you may contact the recipient with any inquiries concerning the processing of your personal information.

In addition, we may share your information to comply with legal and regulatory requirements, and protect against and prevent fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities.

CAREERS

If you submit your information in connection with job opportunities at SimpleReach, we will use and disclose the information to process your application (including to contact you and/or your references and former employers if appropriate), to monitor recruitment statistics, and to comply with government reporting requirements. We also retain statistical information about applicants to help inform our recruitment activities. We will process this information based on our legitimate interest of evaluating job candidates or, when you provide us with sensitive information, based on your consent.

SimpleReachuses RecruiterBox to manage a pipeline of job candidates including interview scheduling, evaluations, interview stages, messaging, and candidate profiles.RecruiterBox acts at our direction when it hosts our jobs page containing job descriptions, where candidates can submit applications for consideration for employment with SimpleReach.

PRIVACY PREFERENCES, RIGHTS, AND CHOICES

Marketing emails

You may unsubscribe from receiving marketing or other commercial emails from SimpleReach by following the instructions included in the email. However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as important product safety information,or changes in website on mobile application terms).

Privacy preferences and rights

Individuals in certain jurisdictions, like the EEA, have certain rights and choice regarding SimpleReach’s processing of their personal information. Please seethe “How to Contact Us” section below for our contact information to exercise those rights and choices. In some cases where your personal information is accessible through an online portal or platform, you may be able to directly exercise these rights by following the instructions on the portal or platform.

Please note that if the exercise of these rights limits our ability to process personal information, we may be precluded from providing our products or services to individuals who exercise these rights, or from otherwise engaging with such individuals going forward.

We reserve the right to verify the identity of the individual in connection with any requests regarding personal information to help ensure that we provide the information to individuals to whom the information pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information.

For information about the rights and choices users have with respect to cookies and online tracking, please see the “Cookies and Other Information Collected by Automated Means” section of this Privacy Notice.

General objections to the processing of personal information

To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your personal information. In some circumstances, withdrawing your consent to SimpleReach’s use or disclosure of your personal information will mean that SimpleReach will not be able to provide products or services to you or to otherwise engage with you.

Access to personal information

Upon request SimpleReach will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by emailing privacy@simplereach.com. We will respond to your request within a reasonable timeframe.  If we grant your request,we will provide you with a copy of the personal information we maintain about you in the ordinary course of business, in a commonly used format. We may reject your request to access, correction or deletion of your information, as permitted by applicable law.  If we reject your request, we will notif you of the reasons for the rejection.

Portability of personal information

You may request that we transfer your personal information to another datacontroller. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reasons for therejection.

Online Behavioral Advertising

We partner with a third party to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.

INTERNATIONAL DATA TRANSFERS

We may transfer personal information to countries other than the country in which the data was originally collected for the purposes described in this Privacy Policy. For example, if you are located outside of the United States, we typically transfer your personal information to the United States, where SimpleReach is headquartered. The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the information. As described below, we have certified compliance with the EU-US Privacy Shield Framework.

EU-U.S.PRIVACY SHIELD

SimpleReach participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. SimpleReach is committed to subjecting all personal information received from European Union (EU) member countries, in reliance on the Privacy Shield Frameworks, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification,visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.

SimpleReach is responsible for the processing of personal information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. SimpleReach complies with the Privacy Shield Principles for all onward transfers of personal information from the EU,including the onward transfer liability provisions.

With respect to personal information received or transferred pursuant to the Privacy Shield Frameworks, SimpleReach is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, SimpleReach may b required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at  https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

DATA RETENTION

We will retain your information for as long as necessary to fulfill the purpose(s)for which the information was collected, depending on the purpose(s) for which the information was collected, the nature of the information, any contractual relationship that may governs the retention of the data, and our legal or regulatory obligations.

BLOG HOSTED BY A THIRD PARTY

Our blog is managed by a third party application that may require you to register to post a comment. We do not have access or control of the information posted to the blog. You will need to contact or login into the third party application if you want your personal information that was posted to the comments section removed. To learn how the third party application uses your information, pleasereview their privacy statement.

TESTIMONIALS

Wedisplay personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at info@simplereach.com.

SOCIAL MEDIA WIDGETS

Ourwebsite includes Social Media Features, such as the Facebook Like button, and Widgets,such as the Share This button or interactive mini-programs that run on ourwebsite. These Features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it.

THIRD PARTY SITES

The Site may contain links to other sites. SimpleReach is not responsible for the privacy practices of such other sites. We encourage our users to be aware when leaving the Site to read the privacy statements of each site that collects personal information.

SECURITY

We are committed to protecting personal information from loss, misuse, disclosure,alteration, unauthorized access, and destruction. SimpleReach takes reasonable precautions to safeguard the confidentiality of personal information. Weprotect the security of your personal information by using Secure Sockets Layer(SSL) software, which encrypts information during transmission between ourserver and an individual’s device. While we strive to protect your personal information, we cannot ensure the security of the information you transmit tous in all cases.

UPDATES TO THIS PRIVACY POLICY

We may occasionally update or modify this Privacy Policy, at our sole discretion.The date of the most recent update of this document will always be displayed at the beginning of this page. If we change our Privacy Policy, we will post those changes on the Site located at http://www.simplereach.com/privacy. If we decide to use personal information in a manner different from that stated at the time it was collected, we will notify users via email (if an email address has been provided) or display a notice on the Site. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personal information we collect.