BELLWETHR PRIVACY POLICY

Date: March 30, 2020

1. PURPOSE OF POLICY

This Privacy Policy (“Policy”) describes how we collect, use, store, and share information in connection with the Bellwethr website currently available at https://www.bellwethr.com (the “Site”), the Bellwethr proprietary consumer retention software (the “Software”), and any other services provided by us (together with the Site and the Software, the “Services”). The provisions of our Terms of Use, including, without limitation, with respect to limitation of our liability, governing law, and dispute resolution, apply to this Policy as well.

2. APPLICABILITY

This Policy applies to any use of the Services, whether you visit and interact with the Site, use the websites, applications or other services of one of our customers (each, a “Customer”) into which the Software integrated, or otherwise engage with us for any purpose.

3. DEFINITIONS

As used in this Policy, the following terms have the meaning given to them below.

3.1.We. The terms “we,” “us,” or “our” means Bellwethr Inc., a Delaware corporation.

3.2. You. The terms “you”, “your,” or “user” means any user that accesses, uses, or attempts to access or use the Services, including through the integrated services of our Customers (each, an “Integrated App”).

3.3. Personal Information. The term “personal information” means any information that can be used to identify any natural person, either directly or indirectly.

4. HOW WE COLLECT INFORMATION

4.1. Information You Voluntarily Provide to Us. When you use the Services, you may choose to provide us with certain personal information about you. This may be the case, for example, when you visit the Site and sign up for our newsletter or for a product demonstration. We use this information to provide you with the Services you have requested.

4.2. Information We Collect From Third Parties. When a user accesses the Software through an Integrated App, we will collect certain information about such user from the Customer that is operating the Integrated App. This information allows us to provide the functionality of the Software to our Customers.

4.3. Information Collected Automatically. We may also use cookies, web bugs, and other tracking technologies to automatically collect certain information as users interact with certain aspects of the Services. This may include information that, while not directly identifying an individual, may be considered personal information in certain circumstances, such as a user’s IP address. Some of this automated collection is done through third-party services, such as Google Analytics and others. We use this information for analytics purposes to better understand how users interact with the Services and to improve the Services and our product offerings.

4.4. User Choices. Users may choose to disable cookies through browser settings, in which case certain aspects of the Services may not work. To the extent applicable, users may also be able to opt out of tracking by Google Analytics and other ad networks by visiting AdChoices.

5. HOW WE USE INFORMATION

We use the information we collect for any of the purposes described above and as further listed below.

5.1. Providing the Software. We use personal information to provide the functionality of the Software to our Customers.

5.2. Communicating With You. We may use your personal information to contact you about aspects of and updates to the Services, including changes to our Terms of Use and/or this Policy, and our products and services in which you may be interested.

5.3. With Your Consent. We may use your personal information for any other purpose with your permission.

6. HOW WE SHARE INFORMATION

We may disclose and share information as set forth below. Under no circumstances will we sell user personal information to third party advertisers for their marketing purposes.

6.1. With Our Customers. As part of the functionality of the Software, we share user information with our Customers. This includes your choices with respect to the Integrated App through which you access the Services. Any user information shared with our Customers will be subject to such Customers’ privacy policies and practices. If you have any questions about the privacy policies or practices of a Customer that operates an Integrated App through with you access the Services, we encourage you to contact such Customer directly.

6.2. With Our Vendors. We may disclose your information to our contractors, vendors, and other agents, to the extent that such persons or entities have a need-to-know such information in furtherance of the Services. This includes, without limitation, third-party vendors that assist us with certain aspects of the Services, such as hosting, customer support, email marketing, etc. We will use commercially reasonable efforts to ensure such vendors are obligated to treat personal information pursuant to the terms of this Policy. However, we make no guarantees about, and assume no responsibility or liability for, the information, data, or privacy practices of such vendors.

6.3. Sale of Company or Assets. In the event that we sell all or substantially all of our company or its assets, including the user information collected through our Services, we may transfer your information, upon reasonable notice to you, to the acquiring company.

6.4. Government Requests. We may disclose your personal information if we believe in good faith such disclosure is necessary to comply with any subpoenas, court orders, or other similar legal process, provided that, to the extent permitted by law, we may provide you with notice prior to disclosing such information.

6.5. Other Circumstances. We may share your information if we have a good-faith belief that such action is necessary to protect and defend our rights or property, or to prevent an emergency involving personal or financial injury to any person or entity.

7. HOW WE SECURE PERSONAL INFORMATION

We use reasonable efforts to secure the personal information we obtain in the course of providing the Services and to prevent the loss, misuse, and alteration of such information. For example, we rely on the technical measures such as encryption and safeguards provided by the third-party vendors we use to host, store, and process personal information on our behalf; we review the privacy practices of new products and services that we integrate into our Services; and we restrict access to personal information to our employees, contractors, vendors, and other agents who need access to such information. However, loss, misuse, and alteration may occur despite our efforts to protect personal information. We are not responsible to our users or to any third party due to any such loss, misuse, or alteration.

8. RETENTION OF INFORMATION

We will retain user information for as long as necessary to provide our Customers with functionality of the Software, to comply with our legal obligations, to resolve disputes, to prevent abuse, and to enforce our legal rights. In addition, we may retain information in aggregated and anonymized form perpetually for the purpose of improving the Services. If you believe we have personal information about you, you may contact us at the address below to request that we delete such information, provided that we reserve the right to reject such request if we reasonably determine that we should retain such information pursuant to the foregoing data retention policy.

9. CHANGES TO THIS POLICY

We reserve the right to change this Policy from time to time, with or without notice. Any changes to this Policy will become effective on the date indicated above, and any further use of the Services will be subject to the new Policy. We will always have the latest version of the Policy posted on the Site.

10. CONTACTING US

If you have any questions about this Policy or our Services, feel free to contact us at help@bellwethr.com.