SMART RESPONSE TECHNOLOGY, INC. PRIVACY POLICY 

WEBSITE & APPLICATION 

Last updated May 18, 2022

Smart Response Technologies, Inc. (“we” or “us” or “our”) respects the privacy of our users (“user”  or “you”) and their organizations. This Privacy Policy explains how we collect, use, disclose, and  safeguard your information when you visit the Smart Response Technologies™ website or use  any of our applications (the “Application”). Please read this Privacy Policy carefully. IF YOU OR  YOUR ORGANIZATION DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY,  PLEASE DO NOT ACCESS THE APPLICATION.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We  will alert you about any changes by updating the “Last updated” date of this Privacy Policy. You  are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be  deemed to have been made aware of, will be subject to, and will be deemed to have accepted  the changes in any revised Privacy Policy by your continued use of the Application after the date  such revised Privacy Policy is posted.

This Privacy Policy does not apply to the third-party online/mobile store from which you install the  Application or make payments, including any in-game virtual items, which may also collect and  use data about you. We are not responsible for any of the data collected by any such third party.

COLLECTION OF YOUR INFORMATION 

We may collect information about you in a variety of ways. The information we may collect via  the Application depends on the content and materials you use, and includes:

Personal Data  

Demographic and other personally identifiable information (such as your name and email  address) that you voluntarily give to us when choosing to participate in various activities related  to the Application, such as chat, posting messages in comment sections or in our forums, liking  posts, sending feedback, and responding to surveys. If you choose to share data about yourself  via your profile, online chat, or other interactive areas of the Application, please be advised that  all data you disclose in these areas is public and your data may be accessible to anyone who  accesses the Application.

We will collect data associated with your user profile. This could include emails, contact numbers,  etc. as provided within your user profile.

Derivative Data 

Information our servers automatically collect when you access the Application, such as your  native actions that are integral to the Application, including the IP address the communication  originates from, liking, re-blogging, or replying to a post, as well as other interactions with the  Application and other users via server log files.

Geo-Location Information  

We request access or permission to and track location-based information from your device, either  continuously or while you are using the Application, to provide location-based services. If you  wish to change our access or permissions, you may do so in your device’s settings.

Device Access  

We may request access or permission to certain features from your device, including your  device’s [Bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS  messages, social media accounts, storage] and other features. If you wish to change our access  or permissions, you may do so in your device’s settings.

Device Data  

Device information such as your type of browser, device ID number, model, and manufacturer,  version of your operating system, phone number, country, location, and any related data  necessary to properly display our information.

Push Notifications  

We may request to send you push notifications regarding your account or the Application. If you  wish to opt-out from receiving these types of communications, you may turn them off in your  device’s settings. Certain push notifications are not able to be deleted and are considered  essential for program operations. If you wish to no longer receive these notifications, you must  cease use of our Application.

Third-Party Data  

Information from third parties, such as personal information or network friends, if you connect your  account to the third party and grant the Application permission to access this information.

Data From Contests, Giveaways, and Surveys  

Personal and other information you may provide when entering contests or giveaways and/or  responding to surveys.

USE OF YOUR INFORMATION 

Having accurate information about you permits us to provide you with a smooth, efficient, and  customized experience. Specifically, we may use information collected about you via the  Application to:

  1. Assist law enforcement and respond to subpoena.
  2. Compile anonymous statistical data and analysis for use internally or with third parties.  3. Create and manage your account.
  3. Deliver targeted advertising, coupons, newsletters, and other information regarding  promotions and the Application to you.
  4. Email you regarding your account or order.
  5. Enable user-to-user communications.
  6. Fulfill and manage purchases, orders, payments, and other transactions related to the  Application.
  7. Generate a personal profile about you to make future visits to the Application more personalized.
  8. Increase the efficiency and operation of the Application.
  9. Monitor and analyze usage and trends to improve your experience with the Application. 11. Notify you of updates to the Application.
  10. Offer new products, services, device applications, and/or recommendations to you. 13. Perform other business activities as needed.
  11. Prevent fraudulent transactions, monitor against theft, and protect against criminal activity. 15. Process payments and refunds.
  12. Request feedback and contact you about your use of the Application.  17. Resolve disputes and troubleshoot problems.
  13. Respond to product and customer service requests.
  14. Send you a newsletter.
  15. Solicit support for the Application.
  16. Tag information to data input or provided by you to the system.
  17. [Other]

DISCLOSURE OF YOUR INFORMATION 

We may share information we have collected about you in certain situations. Your information  may be disclosed as follows:

By Law or to Protect Rights  

If we believe the release of information about you is necessary to respond to legal process, to  investigate or remedy potential violations of our policies, or to protect the rights, property, and  safety of others, we may share your information as permitted or required by any applicable law,  rule, or regulation. This includes exchanging information with other entities for fraud protection  and credit risk reduction.

Third-Party Service Providers  

We may share your information with third parties that perform services for us or on our behalf,  including payment processing, data analysis, email delivery, hosting services, customer service,  and marketing assistance.

Marketing Communications

With your consent, or with an opportunity for you to withdraw consent, we may share your  information with third parties for marketing purposes, as permitted by law.

Interactions with Other Users  

If you interact with other users of the Application, those users may see your name, profile photo,  and descriptions of your activity, including sending invitations to other users, chatting with other  users, liking posts, following blogs, posting or providing pictures, video, or other information.

Online Postings 

When you post comments, contributions or other content to the Applications, your posts may be  viewed by all users and may be publicly distributed outside the Application in perpetuity

Third-Party Advertisers  

We may use third-party advertising companies to serve ads when you visit the Application. These  companies may use information about your visits to the Application and other websites that are  contained in web cookies in order to provide advertisements about goods and services of interest  to you.

Affiliates  

We may share your information with our affiliates, in which case we will require those affiliates to  honor this Privacy Policy. Affiliates include any subsidiaries, joint venture partners or other  companies that we control or that are under common control with us.

Business Partners  

We may share your information with our business partners to offer you certain products, services, or promotions.

Social Media Contacts  

If you connect to the Application through a social network, your contacts on the social network  will see your name, profile photo, and descriptions of your activity.

Other Third Parties 

We may share your information with advertisers and investors for the purpose of conducting  general business analysis. We may also share your information with such third parties for  marketing purposes, as permitted by law.

Sale or Bankruptcy  

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another  entity, we may transfer your information to the successor entity. If we go out of business or enter  bankruptcy, your information would be an asset transferred or acquired by a third party. You  acknowledge that such transfers may occur and that the transferee may decline honor  commitments we made in this Privacy Policy.

We are not responsible for the actions of third parties with whom you share personal or sensitive  data, and we have no authority to manage or control third-party solicitations. If you no longer  wish to receive correspondence, emails, or other communications from third parties, you are  responsible for contacting the third party directly.

TRACKING TECHNOLOGIES 

Cookies and Web Beacons 

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the  Application to help customize the Application and improve your experience. When you access the  Application, your personal information is not collected through the use of tracking technology.  Most browsers are set to accept cookies by default. You can remove or reject cookies but be  aware that such action could affect the availability and functionality of the Application. You may  not decline web beacons. However, they can be rendered ineffective by declining all cookies or  by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting  you to accept or decline cookies on an individual basis.

Website Analytics  

We may also partner with selected third-party vendors such as [Adobe Analytics,] [Clicktale,]  [Clicky,] [Cloudfare,] [Crazy Egg,] [Flurry Analytics,] [Google Analytics,] [Heap Analytics,]  [Inspectlet,] [Kissmetrics,] [Mixpanel,] [Piwik,] and others, to allow tracking technologies and  remarketing services on the Application through the use of first party cookies and third-party  cookies, to, among other things, analyze and track users’ use of the Application, determine the  popularity of certain content, and better understand online activity. By accessing the Application,  you consent to the collection and use of your information by these third-party vendors.

You should be aware that getting a new computer, installing a new browser, upgrading an existing  browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt out cookies, plug-ins, or settings.

THIRD-PARTY WEBSITES 

The Application may contain links to third-party websites and applications of interest, including  advertisements and external services, that are not affiliated with us. Once you have used these  links to leave the Application, any information you provide to these third parties is not covered by  this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before  visiting and providing any information to any third-party websites, you should inform yourself of  the privacy policies and practices (if any) of the third party responsible for that website, and should  take those steps necessary to, in your discretion, protect the privacy of your information. We are  not responsible for the content or privacy and security practices and policies of any third parties,  including other sites, services or applications that may be linked to or from the Application.

SECURITY OF YOUR INFORMATION 

We use administrative, technical, and physical security measures to help protect your personal  information. While we have taken reasonable steps to secure the personal information you  provide to us, please be aware that despite our efforts, no security measures are perfect or  impenetrable, and no method of data transmission can be guaranteed against any interception or  other type of misuse. Any information disclosed online is vulnerable to interception and misuse  by unauthorized parties. Therefore, we cannot guarantee complete security if you provide  personal information.

POLICY FOR CHILDREN 

We do not knowingly solicit information from or market to children under the age of 13. If you  become aware of any data we have collected from children under age 13, please contact us using  the contact information provided below.

CONTROLS FOR DO-NOT-TRACK FEATURES  

Most web browsers and some device operating systems [and our mobile applications] include a  Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to  have data about your online browsing activities monitored and collected. No uniform technology  standard for recognizing and implementing DNT signals has been finalized. As such, we do not  currently respond to DNT browser signals or any other mechanism that automatically  communicates your choice not to be tracked online. If a standard for online tracking is adopted  that we must follow in the future, we will inform you about that practice in a revised version of this  Privacy Policy.

OPTIONS REGARDING YOUR INFORMATION 

Account Information 

You may at any time review or change the information in your account or terminate your account  by:

  • Contacting your organization’s administrator
  • Contacting us using the contact information provided below

Upon your request to terminate your account, we will deactivate or delete your account and  information from our active databases. However, some information may be retained in our files to  prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use  and/or comply with legal requirements.

Emails and Communications 

If you no longer wish to receive correspondence, emails, or other communications from us, you  may opt-out by:

  • Noting your preferences at the time you register your account with the Application ● Logging into your account settings and updating your preferences.
  • Contacting us using the contact information provided below

If you no longer wish to receive correspondence, emails, or other communications from third

parties, you are responsible for contacting the third party directly.

CALIFORNIA PRIVACY RIGHTS 

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users  who are California residents to request and obtain from us, once a year and free of charge,  information about categories of personal information (if any) we disclosed to third parties for direct  marketing purposes and the names and addresses of all third parties with which we shared  personal information in the immediately preceding calendar year. If you are a California resident  and would like to make such a request, please submit your request in writing to us using the  contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the  Application, you have the right to request removal of unwanted data that you publicly post on the  Application. To request removal of such data, please contact us using the contact information  provided below, and include the email address associated with your account and a statement that  you reside in California. We will make sure the data is not publicly displayed on the Application,  but please be aware that the data may not be completely or comprehensively removed from our  systems.

CONTACT US 

If you have questions or comments about this Privacy Policy, please contact us at:

Smart Response Technologies, Inc.

info@smartresponsetech.com