SILMU.IO, INC. PRIVACY POLICY JANUARY 2019

SILMU.IO, INC. PRIVACY POLICY JANUARY 2019
1. GENERAL
Silmu.IO, and its affiliates (“SILMU” or ”We”) respect your privacy and endeavor to safeguard your privacy (“You”) when using Silmu or other SILMU services. This document (“Privacy Policy”) provides You information on our privacy practices and how We process Your data, including personal information, and how We protect such data.

Personal information refers to information which allows You to be specifically identified as
individual person. SILMU may also collect “non-personal information” meaning it can’t be used to specifically identify any persons. Non-personal information may also be the result of removing personally identifiable parts from the information.

We collect and use both types of information and combinations of both types. We are not
responsible for the actions of third-party people, companies or services, the content of third-party sites or services, the use of information You provide to them or any products or services they may offer.

This Privacy Policy applies to the use of the Silmu solution, which consists of a downloadable application and other related connection services enabling You to access easydataload.com, silmu.io, 247trusted.com (“SILMU”), and You should read this Privacy Policy before using Silmu. By using Silmu, You express your agreement to this Privacy Policy and the processing of your personal information in the manner provided in this Privacy Policy. If You do not agree to the terms of this Privacy Policy,
please do not use Silmu.

2. COLLECTING AND USING PERSONAL INFORMATION We will only collect personal information to the extent necessary for providing our services and to enable You to use Silmu. Personal
information may be collected and used for the purposes of creating user accounts, user profiles, using, maintaining and developing Silmu, contacting users, providing services and products, sending customer information and marketing communications (as outlined below and as applicable under the applicable laws) to users, enabling use of Silmu and communication in Silmu and between users, conducting research and creating reports for internal use.

SILMU will pursue to take appropriate measures to prevent unauthorized access to personal
information, any inappropriate use thereof and any possible inaccuracies. All personnel processing personal information are obliged to keep such information strictly confidential. We may store information on servers and equipment in other countries (as outlined below). By using Silmu You always disclose information to SILMU. Your information will be kept private unless You choose to disclose the information to other users (in connection with Your interacting with other users, as outlined below). To enable You to interact with other users, SILMU may at times offer You the ability to post content in connection with Your use of Silmu (including chat or other forums).

By interacting with others, You may choose to disclose information to other users, and any such information is considered public information, and there is no expectation of privacy. SILMU is not responsible for any personal (or other) information You choose to make public in Silmu.

3. COLLECTED PERSONAL INFORMATION AND SOURCES AND ACCURACY OF INFORMATION The type of information We collect and store will vary depending on Your use of Silmu and Your
activity. We may collect the following personal information when You sign up for Silmu, or later in connection with Your use of Silmu:
• Username
• Email or mail address
• Your profile picture, name, age/birthday, gender
• Third-party service ID
• IP (Internet Protocol) address
• Mobile device unique ID (IMEI), hardware type and operating system version
• Chatter profile
• Company name

Silmu may be able to access Your user account(s) in third-party services (including associated data and other material) to allow You to interact with such third-party services
using Silmu. SILMU may be able to connect to Your user account(s) in third-party services
to interact with such third-party services to allow You to use Your data and other material
and, consequently Silmu may be able to input and/or obtain certain information to or from
Your user account(s) in third-party services when such third-party services permit such
interaction.

IP-addresses, operating system, access and usage times and activity logs, browser type and
language and referring website addresses might be collected automatically also when You
use Silmu. SILMU may use this information to monitor and analyse the use of the services,
contact You about Your experience with SILMU sites and notify You about company news
and promotions. SILMU collects data about all of Your interactions with Silmu and with the
other users inside Silmu (including chat) via server log files and other activities in Silmu and within Silmu related services. We may, at our own initiative or upon Your request,
complement, correct or delete incomplete, inaccurate or outdated personal information.

4. DISCLOSING AND TRANSFERRING YOUR INFORMATION
SILMU will not disclose Your personal information stored in the register to third parties for direct marketing, market research, polls or public registers without Your consent. However, the information or profiles might be used for targeted in-service marketing (including serving ads to users) and other similar purposes. Without prejudice to the generality of the foregoing, personal information may be disclosed to third parties if required under any applicable law or regulation or order by competent authorities, or to enforce the Terms of Service of Silmu and to investigate possible infringing use of Silmu as well as to guarantee safety of Silmu.

We may share Your information in connection with any merger, sale of our assets, or a
financing or acquisition of all or a portion of our business. We may engage other entities
and individuals to perform services on our behalf. e.g. for analyzing data and in connection
with the performance of services these service providers may have access to your personal
information.

We reserve the right to use anonymized data for the purposes outlined in the Terms of
Service, including to enhance Silmu. Anonymized data means that data is made anonymous
(e.g. aggregated data from statistical analyses of users’ aggregate behavior) and cannot be
used to identify individual users. Such aggregate or anonymous information about You may
be shared with advertisers, publishers, business partners, sponsors, and other third parties.

If You give your consent to share your information with third parties for their own marketing purposes, such marketing is governed by their separate privacy policies.

We use external service providers to provide technical solutions for processing stored information and access the stored information by using a technical interface. We host the service in and may transfer information for this purpose to and from countries outside the European Union (EU) or the European Economic Area (EEA). Please note that We may transfer Your information, including personal information, to countries (including the United States) and jurisdictions that do not have the same data protection laws as in the EU/EEA. We will always transfer personal information about You in accordance with the mandatory legislation and this Privacy Policy. Our service providers and other partners in the United States comply with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention when We transfer personal information to such service providers and partners.

5. OUR POLICY REGARDING CHILDREN
We are a general audience service directed to and intended for users 13 years of age and over, and We will not knowingly collect personal information from anyone under the age of 13. If You are under 13, please do not attempt to use Silmu or send any information about yourself to us, including Your name, address, telephone number, or email address. If We learn that We have collected personal information from a child under age 13, We will take all reasonable efforts to delete that information as quickly as possible. If You believe that We might have any information from or about a child under the age of 13, please contact us at [email protected]

6. PROTECTING PERSONAL INFORMATION (DATA SECURITY)
The register will be maintained in external service providers’ servers with appropriate safeguards, such as password protection, granting the access to the stored information only to SILMU. The register is protected by appropriate industry standard, technical and organizational safety measures. The information base will be accessible only to those persons expressly authorized by SILMU. Although We make good faith efforts to store the information collected on the services in a secure operating environment that is not available to the public and use only reliable partners (such as Salesforce, ServiceNow, Microsoft and Amazon), We cannot guarantee the absolute security of that information during its transmission or its storage on our systems. We do not represent or warrant that Your personal information will be protected against, loss, misuse, or alteration by third parties.

7. COOKIES AD THIRD-PARTY SERVICES
A cookie is a string of information or a small text file that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. SILMU uses cookies to help it identify and track visitors, their usage of Silmu and website, and their website access preferences, improving quality, tailoring recommendations, and developing Silmu related services.

Users who do not wish to have cookies placed on their computers should set their browsers to
refuse cookies before using Silmu and/or website, with the drawback that certain features of the website may not function properly without the aid of cookies. The cookies will not enable SILMU to access and review information stored on a user’s computer.

Silmu may contain third-party tracking tools from our service providers, examples of which include Google Analytics and Mixpanel. Such third-party services are governed by separate privacy policies and this Privacy Policy does not apply to such third-party information collection.

Third party service providers may use cookies, APIs, and SDKs in Silmu to enable them to collect and analyze user information on our behalf. Our service providers may have access to, for example, the following information:
• your device identifier
• MAC address
• IMEI
• locale
• geo-location information
• IP address

There may also be other third-party services available for Your use in Silmu. All such thirdparty services is governed by separate privacy policies (and Terms and Conditions) and this Privacy Policy does not apply and SILMU will not be responsible for such third party
information collection.

8. ACCESS TO AND CONTROL OVER PERSONAL INFORMATION
You are entitled to review any information collected on You and stored in the register, if
any. Should You wish to exercise the above right to review stored information, you should
send a signed request thereof to SILMU using the contact details below.

Users may opt-out of receiving promotional emails by following the instructions in those
emails. If You opt-out, SILMU may still send You non-promotional customer information,
such as emails about Your account or SILMU’s ongoing business relations.

9. CHANGES TO PRIVACY POLICY
SILMU may change this Privacy Policy from time to time. All changes hereto will be made
available on the SILMU website. The changes will be effective when made available and Your continued use of Silmu indicates your consent to the changed Privacy Policy posted at the time of use. Changes hereto will not substantially prejudice Your rights without Your consent.

CONTACT INFORMATION North America:
Silmu.IO, Inc.
470 Ramona Street Palo Alto, 94301 CA USA
https://silmu.io
[email protected]