PRIVACY POLICYWe are committed to protecting your privacy. In this Privacy Policy, OneBric (“we” or the “Company”) set out howwe collect your personal data, how we use it, and what rights and choices you have in relation to the personaldata we hold and process through our website (www.onebric.com) or applications (“Apps”) for devices (each, a“Device”).In case of updates, we will post the revised Privacy Policy on our website. Changes will take effect as soon asthe revised version is made available on our website. IF YOU DO NOT ACCEPT THE TERMS OF THISPRIVACY POLICY, AS AMENDED FROM TIME TO TIME, PLEASE DO NOT USE OUR SERVICES.THE INFORMATION WE COLLECT AND STOREWe collect different types of personal data for different reasons. This may include:• Contact information: Information such as your name, job title, postal address, home address where youprovide this to us, business address, telephone number, mobile number, fax number and email address.• Payment data: Data necessary for us to process payments and implement fraud prevention measures,including credit/debit card numbers, security code numbers and other such relevant billing details.• Business details: Business information which we necessarily process as part of our instructions orprojects we are involved in or otherwise provided by you voluntarily.• Compliance details: Information we are legally required to collect for compliance purposes, such as "knowyour client" information, details relevant to international sanctions and restrictive measures andinformation about relevant and significant litigation, which may impact our ability to act.• Preferences: Information about your preferences, where it is relevant to the services we provide.• Platform information: Your password and other related log-in details for platforms maintained by theCompany, where you have access to any.• Publicly available information: Information collected from publicly available resources, including but notlimited to information collected from databases we use to carry out compliance checks or credit ratingagencies.• Statutory Register Information: Information about you on account of an interest or office you may hold inor certain relationships you may have with a corporate entity, partnership, trust or other vehicle to whichwe provide services (each such entity, a Third-Party Entity). • Details for events: In some cases, we may collect information about you, which may include sensitiveinformation in relation to your health, for the purpose of tailoring our events to your needs. The processingof such data is based entirely on your consent. In the event that you do not want us to maintain suchdata, we may not be able to take the necessary precautions.You may choose not to provide your Personal Information; however, if you do not provide your PersonalInformation you may not be able to use all the functions offered by the Services.We take appropriate technical and organizational measures to keep your personal data confidential and secure,in accordance with our internal policies and procedures regarding storage of, access to and disclosure ofpersonal data. We may keep your personal data in our electronic systems, in the systems of our contractors, orin paper files.COOKIES AND WEB BEACONSThe Company also uses “cookies” to collect information and improve our Services. A cookie is a small data filethat we transfer to your Device. We may use “persistent cookies” to save your registration ID and login passwordfor future logins to our Services. We may use “session ID cookies” to enable certain features of our Services, tobetter understand how you interact with our Services and to monitor aggregate usage and web traffic routing onour Services. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt youbefore accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not beable to use all aspects of our Services.We also use Web beacons, also called web bugs to collect information and improve our Services. A Web beaconis typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site or in an email.We do not use cookies or Web beacons to collect Personal Information nor do we collect precise geographiclocation. However, some Devices automatically log location information in photos and videos recorded by thatDevice. If you upload any User Content from a Device that does so, you agree that we may use this informationto optimize your experience. If you do not wish to share User Content embedded with your geo-locationinformation with us, please do not upload them. If you don’t want to store location data in your User Content,please consult the documentation for your Device to turn off that feature.ANALYTICSThe Company also collects some information (directly or using third party services) using logging and cookies,such as IP address, which can sometimes be correlated with Personal Information. We use this information forthe above purposes and to monitor and analyze use of our Services, for the Service’s technical administration,to increase our Service’s functionality and user-friendliness, and to verify users have the authorization needed for our Services to process their requests. All the used information is totally non-identifiable and anonymous. Asof the date this policy went into effect, we use Google Analytics and we may use other analytics tools. ThePrivacy Policy of Google Analytics are available online, and information on how to opt out of that service. If youneed to access the Privacy Policy of any other tool that we may use, you can request a copy contacting us to [].WHEN WE COLLECT PERSONAL DATAWe may collect personal data about you in various cases, such as:• When you or your organization seek our services or use any of our online client services;• When you or your organization make an enquiry through our website, in person, over email or over thetelephone;• When you attend a the Company seminar or other events we may organize, or sign up to receivecommunications from us, including training;• When a Third Party Entity engages us to provide services and you hold an office or an interest in orhave certain relationships with that Third Party Entity; and/or• When you or your organization provide services to us, or otherwise offer to do so.In some circumstances, we may collect personal data about you from third parties. For example, we maycollect personal data from your organization, other organizations with whom you have dealings including ThirdParty Entities, government agencies, a credit reporting agency, an information or service provider or from apublicly available record.HOW WE USE YOUR INFORMATIONWe will use your personal data for the following purposes (Permitted Purposes):• To provide legal advice or other services or things you may have requested, including online or legaltechnology services or solutions, as instructed or requested by you or your organization;• To manage and administer your or your organization’s business relationship with us, includingprocessing payments, accounting, auditing, billing and collection or support services;• For compliance with our legal obligations (such as record keeping obligations), compliance screening orrecording obligations (such as under antitrust laws, export controls, trade sanction and embargo laws,for anti-money laundering, financial and credit check and fraud and crime prevention and detectionpurposes), which may include automated checks of your contact data or other information you provideabout your identity against applicable sanctioned-party lists and contacting you to confirm your identityin case of a potential match or recording interaction with you which may be relevant for compliancepurposes;• To provide updates, reminders, requests and directions relevant to the role or capacity in which you areinterested in a Third Party Entity.• To analyze and improve our services and communications to you;• To protect the security of and managing access to our premises, IT and communication systems, onlineplatforms, websites and other systems, preventing and to detect security threats, fraud or other criminalor malicious activities;• For insurance purposes;• To monitor and assess compliance with our policies and standards;• To identify persons authorized to trade on behalf of our clients, customers, suppliers and/or serviceproviders;• To comply with our legal and regulatory obligations and requests anywhere in the world, includingreporting to and/or being audited by national and international regulatory, law enforcement and taxreporting bodies;• On instruction or request from your organization or a relevant Third Party Entity;• To communicate with you through the channels you have approved to keep you up to date on the latestlegal developments, announcements, and other information about our services, products andtechnologies, including client briefings, newsletters and other information, as well as events andprojects we may organize;• To comply with court orders and exercises and/or defend our legal rights; and• For any purpose related and/or ancillary to any of the above or any other purpose for which yourpersonal data was provided to us.Where you have expressly given us your consent, we may process your personal data also for the followingpurposes:• For customer surveys, marketing campaigns, market analysis, sweepstakes, contests or otherpromotional activities or events; or• To collect information about your preferences to create a user profile to personalize and foster thequality of our communication and interaction with you (for example, by way of newsletter tracking orwebsite analytics).With regard to newsletters, legal updates and other general communications, we will, where legally required,only provide you with such information if you have opted in. You have the opportunity to opt out of receivingsuch communications at any time. We will not use your personal data for taking any automated decisionsaffecting you or creating profiles other than described above.Depending on for which of the above Permitted Purposes we use your personal data, we may process yourpersonal data on one or more of the following legal grounds:• Because processing is necessary for the performance of a client instruction or other contract with youor your organization or a Third Party Entity;• To comply with our legal obligations (e.g. to keep pension records or records for tax purposes); or• Because processing is necessary for purposes of our legitimate interest or those of any third partyrecipients that receive your personal data, provided that such interests are not overridden by yourinterests or fundamental rights and freedoms.We may also process your data based on your consent where you have expressly given that to us.SPECIAL CONSIDERATION FOR PAYMENT INFORMATIONIf you provide credit card or debit card information to complete a purchase, it is our policy to use third-partypayment processing systems that comply with the Payment Card Industry Data Security Standard (PCI-DSS),which is an industry wide security standard designed to protect the confidentiality and security of your credit cardinformation, by encryption using secure socket layer technology (SSL) and storage with AES-256encryption. We reserve the right to change the service provider at any time for any reason. Although no methodof transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements andimplement additional generally accepted industry standards. Your credit card information will also be subject toour payment processor’s privacy policy in addition to ours. PLEASE READ THE PRIVACY POLICY ON THEWEBSITE OF ANY PAYMENT PROCESSOR THAT YOU ARE DIRECTED TO REGARDING THE USE,STORAGE AND PROTECTION OF YOUR CREDIT CARD INFORMATION BEFORE SUBMITTING ANYCREDIT CARD INFORMATION.All information that you provide to us or our third-party payment processor must be accurate, current andcomplete. In the event of a dispute, we may issue you with a provisional credit to your card until the dispute isresolved. If we issue a provisional credit and the dispute is resolved and the charges were correct, we shallrecharge your debit or credit card to reverse this provisional credit. You expressly consent to this reversal if youfalsely or incorrectly dispute a charge. If you wish to dispute a charge by mail or telephone please contact usat info@onebric.com or +1(786)220-0330. If we elect at any time to charge any convenience fee for making apayment via a debit card, credit card, or electronic check, these fees will be stated at the time of payment beforeyou finalize your charge. In the event of an unauthorized charge using a debit card or electronic check, pleaseconsult your bank’s rules regarding refunds and reversals. The Company complies with all legal requirementsof your State’s applicable laws regarding providing refunds for unauthorized charges. When you make a charge,we shall display a completed charge screen. This is your electronic receipt. You should print or save thiselectronic receipt for your records. YOU REPRESENT AND WARRANT THAT YOU HAVE THE LEGAL RIGHT TO USE ANY CREDIT CARDS, DEBIT CARDS OR OTHER PAYMENT MEANS USED TO INITIATE ANYTRANSACTION.INFORMATION SHARING AND DISCLOSUREFurther, you agree that the Company may transfer the anonymous information we collect in the event of anycorporate restructuring or any sale, assignment or transfer of substantially all of its rights in the Apps.We may disclose information about you if we become subject to a subpoena or court order, or if we are otherwiselegally required to disclose information. We may also use and disclose information about you to establish orexercise our legal rights, to enforce the Terms of Use, to assert and defend against legal claims, or if we believesuch disclosure is necessary to investigate, prevent, or take other action regarding actual or suspected illegal orfraudulent activities or potential threats to the physical safety or well-being of any person. If we are involved ina merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of thattransaction, but we will notify you (for example, via email and/or a prominent notice on our website) of any changein control or use of your Personal Information or User Content, or if either become subject to a different PrivacyPolicy. We will also notify you of choices you may have regarding the information.The Company will display your Personal Information in your profile page and elsewhere on our Servicesaccording to the preferences you set in your account. Any information you choose to provide should reflect howmuch you want others to know about you. Please consider carefully what information you disclose in your profilepage and your desired level of anonymity. You can review and revise your profile information at any time. Wedo not sell your personal information to third parties. We may also share or disclose your information with yourconsent, for example if you use a third-party application to access your account. Through certain features of ourServices, you may also have the ability to make some of your information public. Public information may bebroadly and quickly disseminated.Service Providers, Business Partners and Others. The Company may use certain trusted third-partycompanies and individuals to help us provide, analyze, and improve our Services (including but not limited todata storage, maintenance services, database management, web analytics, email communication, paymentprocessing, and improvement of the Service’s features). These third parties may have access to your informationonly for purposes of performing these tasks on our behalf and under obligations similar to those in this PrivacyPolicy. As of the date this policy went into effect, we use:• RACKSPACE, AMAZON WEB SERVICES and DROPBOX storage service to store some of yourinformation (for example, your User Content).• MAILCHIMP marketing platform to perform personalized email communication.• Google Analytics to collect and report usage data. Third-Party Applications. The Company may share your Information with a third-party application with yourconsent, for example when you choose to access our Services through such an application. We are notresponsible for what those parties do with your information, so you should make sure you trust the applicationand that it has a privacy policy acceptable to you.Non-private or Non-Personal Information. The Company may disclose your non-private, aggregated, orotherwise non-personal information, such as usage statistics of our Services. However, in such cases, yourusage data is aggregated with the usage data of others and does not identify you individually.TERMWe delete your personal data once it is no longer reasonably necessary for us to keep it for the PermittedPurposes, or, where we have relied on your consent to keep your personal data, once you withdraw your consentfor us to do so, and we are not otherwise legally permitted or required to keep the data.Importantly, the Company will keep your personal data as necessary for the purposes of defending or makinglegal claims until the end of the period during which we may retain the data and otherwise until the settlement ofany such claims, as relevant.YOUR RIGHTSSubject to certain conditions under applicable legislation, you have the right to:• Obtain information regarding the processing of your personal data;• Request a copy of the personal data which we hold about you;• Have any inaccurate data we hold about you corrected;• Object or restrict our use of your personal data;• Ask that we not subject you to automated decision making that uses your personal data;• Object to us using your personal data for direct marketing purposes;• Submit a complaint if you have concerns about the way in which we are handling your data.To do any of the above, please contact us at info@onebric.com. To enable us to process your request, we mayrequire that you provide us with proof of your identity, such as by providing us with a copy of a valid form ofidentification. This is to ensure that we appropriately protect the personal data we hold from unauthorized accessrequests and comply with our security obligations.We may charge you a reasonable administrative fee for any unreasonable or excessive requests we may receive,and for any additional copies of the data you may request.In relation to complaints, we will promptly respond to your requests and complaints. In the event that you areunhappy with our response, you may submit a complaint to the relevant privacy regulator.CORRECTING AND UPDATING YOUR PERSONAL DATAWhere any personal data you have provided us with has changed, or where you believe the personal data wehold is inaccurate, please let us know at info@onebric.com. In addition, please note that if you hold an officeor are interested in or have certain relationships with a Third Party Entity to which we provide services, youand/or the Third Party Entity may have a contractual or legal obligation to notify us of any change within aprescribed time period. We cannot be responsible for any loss that may arise due to us having any inaccurate,incomplete, inauthentic or otherwise deficient personal data which you or a Third Party Entity have provided tous. Please also let us know if you wish to withdraw any request.CORPORATE ACCOUNTIf you have a Corporate account, your Administrator may be able to:• access information in and about your Corporate account;• disclose, restrict, or access information that you have provided or that is made available to you whenusing your Corporate account; and• control how your Corporate account may be accessed or deleted.Please refer to your organization's policies if you have questions about your Administrator's rights.LINKED SITESOur Services may contain links to other Web sites whose privacy practices may differ from those of the Company.If you submit personal Information to any of those sites, your Information is governed by their privacy statements.We encourage you to carefully read the privacy statement of any Web site you visit.OUR POLICY TOWARDS CHILDRENIn compliance with the Children’s Online Privacy Protection Act (COPPA) of 1998, the Services are not intendedfor use if you are under 18 years of age unless you have the consent of your parent or legal guardian. In orderto use the Services, you need to be over 18 years old or you will need to have the consent of your parent orguardian.We may use any of the following methods to verify that you have your parents’ consent:· At registration, we will require that you provide your first name and a parent’s valid email address. We will sendyour parent a notification email stating that you have requested to create an account on our Website and receive our e-newsletters on an ongoing basis and describing the information you provided at registration and contactinformation for your parent to respond and request that we stop sending you any emails, cancel your account,and/or delete, modify or edit your information. We will also use your parent’s email address to let your parentknow about any changes to our Privacy Policy. Your parents may at any time review, change and/or delete anyinformation that we have collected about you by emailing info@onebric.comIf your account is being created by a teacher, your teacher must first obtain your parent’s consent. If your teachercreates a student account for you without your parent first signing a consent form, please inform your parentimmediately so that they can instruct us to remove your information from our files.WARNING: any personal information (e.g., name, email address, personal photographs) that youvoluntarily disclose in any video may be collected and used by parties other than us and may result inunsolicited messages from other parties. If you believe that any child under the age of 18 has postedany personal information anywhere on our website, please contact us immediately at info@onebric.comand provide as much information as you can to help us locate and delete the personal information. Ifyou post personal information in any video, we have no control over this use of your personalinformation and, as such, cannot be responsible for it. We reserve the right, but not the obligation, to: (a)delete any personal information we discover or which is brought to our attention, at any time, for anyreason whatsoever; (b) immediately terminate your account and/or (c) contact your parents regardingthe video.YOUR CONSENTIf you reside outside the U.S., the anonymous information we collect will be transferred to the U.S. and processedand stored there under U.S. privacy standards. By using the Services and providing Information to the Company,you consent to the use, transfer and processing of the anonymous information we collect as set forth in thisPrivacy Policy, all of which activities will take place in the U.S.CONTACTING USIf you have any questions about this Privacy Policy, please contact us at info@onebric.com